EPA Superfund
Record of Decision:
PB94-963714
EPA/ROD/R01-94/088
September 1994
Central Landfill Site,
Johnston, RI,
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUilDING. BOSTON, MASSACHUSETTS 02203-2211
DECLARATION FOR THE RECORD OF DECISION
CENTRAL LANDFILL SITE
JOHNSTON, RHODE ISLAND
STATEMENT OF PURPOSE
This Decision Document presents the selected remedial action for
the Central Landfill Superfund Site in Johnston, Rhode Island,
developed in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended, 42 U.S.C. ~~ 9601 et ~ and the National oil and
Hazardous Substances Pollution Contingency Plan (NCP) , as
amended, 40 C.F.R. Part 300. The Environmental Protection
Agency, New England Division Administrator has been delegated the
authority to approve this Record of Decision (ROD).
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 Marion J. Mohr
Memorial Library, 1 Memorial Avenue, Johnston, Rhode Island, and
at the New England Division Records Center, 90 Canal Street,
Boston, Massachusetts. The Administrative Record Index (Appendix
E to the ROD) identifies each of the items comprising the
Administrative Record upon which the selection of the remedial
action is based.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
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.
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DESCRIPTION OF THE SELECTED REMEDY
The components of the selected source control remedy are
presented and discussed in Section VIII of this ROD. In summary,
the selected source control remedy consists of:
.
Constructing a mUlti-layer RCRA C cap over the existing 121
acre Phase I area and incorporating the existing 32 acres of
RIDEM approved cap on the side slopes;
.
Hydraulic containment and treatment of groundwater in the
hot spot area of the landfill and discharging the treated
groundwater to either on-site surface water or the Cranston
Waste Water Treatment Plant;
.
Implementing deed restrictions on groundwater use and land
development within property owned by the RISWMC;
.
Initiating a long-term program of sampling and analysis of
groundwater, surface water and air;
.
Conducting a detailed evaluation of the existing landfill
gas collection and combustion system; and
.
Installing a chain link fence to prevent access.
DECLARATION
The selected source control 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 source control 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
source control remedy utilizes permanent solutions and
alternative treatment technologies to the maximum extent
practicable.
L \ 11
Date
1 ~ t
d ~ \
John P. DeVillars
Regional Administrator
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u.s. ENVIRONMENTAL PROTECTION AGENCY
Region I
RECORD OF DECISION
CENTRAL LANDFILL SUPERFUND SITE
JOHNSTON, RHODE ISLAND
OPERABLE UNIT ONE
SOURCE CONTROL
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I.
II.
RECORD OF DECISION
CENTRAL LANDFILL SUPERFUND SITE
TABLE OF CONTENTS
SITE NAME, LOCATION AND DESCRIPTION
..........
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use and Response History. .
B. Enforcement History. . . . .
. . . . .
. . .
. . . .
. . . . .
........
IV.
III. COMMUNITY PARTICIPATION
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION. . .
V.
VI.
VII.
. .. .
..........
SUMMARY OF SITE CHARACTERISTICS
. . . .
........
SUMMARY OF SITE RISKS
. . . . .
. . .
DEVELOPMENT AND SCREENING OF ALTERNATIVES. . . . . . .
A. Statutory Requirements/Response Objectives. . . .
B. Technology and Alternative Development and
screening. . . . . . . . . . . . . . . . . . . . .
IX.
VIII. DESCRIPTION OF SITE WIDE SOURCE CONTROL ALTERNATIVES. .
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
X.
XI.
THE SELECTED REMEDY. . . .
A. Groundwater containment. . . . . .
B. Design Issues. . . . . . . . . . . .
. . . . .
. . .
. . . . .
. . . .
. . .
STATUTORY DETERMINATIONS. . . . . . . . . .
A. The Selected Remedy is Protective of Human Health
and the Environment. . . . . . . . . . . . . . . .
The Selected Remedy Attains ARARs . . . . . . . . .
The Selected Remedial Action is Cost-Effective
The Selected Remedy utilizes Permanent Solutions
and Alternative Treatment or Resource Recovery
Technologies to the Maximum Extent Practicable
The Selected Remedy satisfies the Preference for
Treatment Which Permanently and significantly
Reduces the Toxicity, Mobility or Volume of the
Hazardous Substances as a Principal Element. . . .
B.
C.
D.
E.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES.
. . . .
. . . . .
XIII. STATE ROLE. . .
. . . . . .
. . . . .
. . . .
. . . . .
i
1
2
2
3
5
6
7
9
18
18
19
20
33
43
44
45
46
46
47
53
55
57
59
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LIST OF APPENDICIES
APPENDIX A: LIST OF FIGURES
APPENDIX B: LIST OF TABLES
APPENDIX C: STATE OF RHODE ISLAND CONCURRENCE LETTER
APPENDIX D: RESPONSIVENESS SUMMARy
APPENDIX E: ADMINISTRATIVE RECORD INDEX
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I.
SITE NAME, LOCATION AND DESCRIPTION
The Rhode Island Solid Waste Management Corporation (RISWMC)
owns and operates the active Central Landfill which is
situated on a 610-acre parcel located at 65 Shun Pike in
Johnston, Rhode Island. The Central Landfill is about 10
miles southwest of Providence Rhode Island. The Superfund
Site is defined as the 154 acres located in the central
portion of RISWMC property which has been licensed for
landfilling by the State of Rhode Island. The 154 acre
Central Landfill Site is comprised of two areas: a 121 acre
area also known as the Phase I area; and a 33 acre expansion
area also known as the Phase II and III areas (see Figure 1,
Appendix A). The 121 acre Phase I area is the area of the
site where disposal of hazardous and nonhazardous wastes
historically took place. Waste disposal activities in the
Phase I area stopped in April 1993. Twelve acres of the 33
acre expansion area are currently being used for the
disposal of nonhazardous municipal solid waste.
The area surrounding the site is composed of
property, residential development, and small
Scattered and single clustered single family
present along all sides of the Site.
undeveloped
businesses.
dwellings are
The State has classified the groundwater in this area in
general as GA (suitable for public or private drinking water
use without treatment). The groundwater under the 154 acre
site is classified as GC (areas which, because of present or
past land use or hydrological conditions, the Director of
the RIDEM has determined to be more suitable for certain
waste disposal practices than for development as a drinking
water supply). The State has also established a GB
(groundwater resources which the Director has designated not
suitable for public or private drinking water use) buffer
zone around the landfill. The limit of the GB classifi-
cation was set at 100 feet from the GC boundary in the up-
grad~ent direction. In the down-gradient direction, the GB
classification is defined as the closest of the following:
property boundary, surface water boundary or wetland, or 500
feet from the GC boundary. The Federal groundwater
classification is, however, more stringent. For groundwater
at and beyond the edge of the waste management area. the Site
groundwater is classified as Class II, current or potential
drinking water.
A more complete description of the Site can be found in
Section 3.10 of the March 1993 Remedial Investigation Report
and section 2.10 of the December 1993 Feasibility Study
Report.
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II.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A.
Land Use and Response History
The Central Landfill, has been owned and operated by the
Rhode Island Solid Waste Management Corporation (RISWMC)
since 1980, and currently receives approximately 85% of
Rhode Island's municipal solid waste. Prior to 1980, the
site was owned by the Silvestri Brothers who, from 1952 to
1955 used a portion of the current Central Landfill site as
a combination sand and gravel/quarry stone operation. From
1955 to 1962 the Site was operated as a refuse burning dump.
The Site has been used as a solid waste disposal area since
1962. Also shown in Figure 1, Appendix A, is an approximate
0.5 acre area, located within the Phase I area, where large
volumes of liquid industrial waste were accepted for
disposal by the Silvestri Brothers in the mid to late 1970's
in trenches excavated into bedrock. This area is commonly
referred to in the Remedial Investigation/Feasibility Study
Reports (RI/FS) as HWDA2 or the hot spot.
Waste manifests on file at the Rhode Island Department of
Environmental Management (RIDEM) indicate that during the
period of December 3, 1976 to May 30, 1979 industrial wastes
were accepted and disposed of in the hot spot. Because
neither federal nor state hazardous waste regulations were
in effect at this time, there is limited information
available concerning the types and quantities of waste
accepted for disposal prior to January 1978.
Between January 1978 and May 1979, Industrial Waste
Manifests were submitted to the RIDEM. The manifests
indicate that wastes disposed of at the Site include aqueous
solutions of latex waste, acid waste, corrosive waste, water
soluble oils and waste solvents, such as methylene chloride,
toluene, l,l,l-trichloroethane and tetrachloroethylene.
From May, 1979 to February, 1981, approximately 5-10 acres
in the northeast portion of the Site in the vicinity of the
hot spot received large volumes of untreated liquid sewerage
sludge. That area was subsequently covered with about
fifteen feet of landfill debris and daily soil cover. since
RISWMC took over operation of the landfill in 1980, the
waste stream has been as high as 6,000 tons per day. In
1991 solid waste disposal averaged approximately 2,500 tons
per day.
In 1984, the Central Landfill site was proposed for
inclusion on EPA's National Priorities List (NPL). The Site
was added to the NPL in June 1986 and field work for the
completed on-site Remedial Investigation (RI) commenced in
1987, after the RISWMC signed an agreement with the EPA to
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study the nature and extent of contamination at the site.
During the field work, on-site investigations were divided
into two operable units: Operable unit 1 (OUl) addresses
source control; Operable unit 2 (OU2) addresses management
of off-site migration of contamination.
In 1986, RISWMC, in conjunction with the RIDEM and the Town
of Johnston initiated a project to provide public drinking
water to area residents. The project was completed in 1990.
A 12-megawatt landfill gas to electricity facility has been
constructed at the site and has been in operation since
1990. RISWMC has expended approximately $23,000,000
acquiring residentially zoned property located within 1,000
feet of the licensed landfill area and offered residents
within the next 1,000 feet the option of selling their
property to RISWMC. This property acquisition was mandated
by the Rhode Island Legislature.
B.
Enforcement History
state Enforcement Activities
On December 10, 1979, RIDEM advised the Silvestri Brothers
that the Site must comply with the newly adopted Hazardous
Waste Facility Rules and Regulations to maintain its status
as an existing but inactive hazardous waste management
facility. In response, the Silvestri Brothers applied for
continued status as an existing hazardous waste management
facility.
In December 1980, the RISWMC purchased the Silvestri
Brothers Landfill renaming it the Central Landfill. After
the site was transferred to the RISWMC, RIDEM determined
that the site was and is a hazardous waste management
facility and in February, 1981, ordered RISWMC to close the
hazardous waste disposal area. The hazardous waste disposal
area (HWDA1) was identified and closed in July 1982 in
accordance with closure plans developed by RISWMC.
Subsequent site work indicated that the closure did not
cover the actual hazardous waste disposal area.
Consequently, a second area was located and designated as
HWDA2, or the hot spot, and is now being addressed as part
of this remedy.
RIDEM/Wetlands Division issued a Notice of Violation to
RISWMC on November 9, 1983, for violations of the Fresh
Water Wetlands Act. This violation related to excavation
and stream diversion of Cedar Swamp Brook and placement of
earth fill in and within 100 feet of Cedar Swamp Brook and
its associated wetlands.
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On December 9, 1983, the Solid Waste Management Facility
License for the Central Landfill expired. RIDEM did not
renew the license for the facility because RISWMC was not in
compliance with various solid waste management facility
regulations including the violations identified in the
November 9th Notice of violation.
On August 10, 1984, and again on August 28, 1984, RIDEM and
RISWMC entered into Consent Agreements to remedy violations
of the state Rules and Regulations for Solid Waste
Management Facilities. The August 10 Agreement addressed
several solid waste violations including the need for a
closure plan for the entire site. The August 28 Agreement
addressed the concerns of the November 9, 1983 Notice of
violation.
RIDEM issued a Notice of Violation and Order to RISWMC on
March 15, 1985, for alleged violations of R.I.G.L. 2-1-21.
RISWMC was ordered to take certain corrective actions and
pay an administrative fine. By an amended Consent Agreement
executed on November 3, 1986, RISWMC agreed to resolve 'the
issues in the Notice of Violation and Order.
By a Notice of Intent to Enforce dated April 3, 1989, RISWMC
was again notified of alleged violations of R.I.G.L. 2-1-21.
The Notice required RISWMC to take specific actions to stop
alterations of wetlands and to submit necessary reports and
studies relating to the restoration of alleged altered
wetlands. By Consent Agreement executed on July 6, 1989,
RISWMC agreed to resolve the issues raised in the Notice of
Intent. A Consent Agreement dated July 23, 1991, supersedes
the above mentioned Consent Agreements dated November 3,
1986, and July 6, 1989.
On March 3, 1988, RIDEM/Division of Air and Hazardous
Materials issued a Decision and Order associated with
RISWMC's application for an interim license to continue
operations at the site. The Order granted the operating
permit to RISWMC and contained significant operational/
management requirements. In response, RISWMC prepared a
work plan for sediment and surface water sampling of surface
water on or near the site as well as a groundwater
monitoring plan.
Federal Enforcement Activities
In June 1984, EPA issued an Administrative Order to RISWMC
pursuant to the authority granted the Agency under Section
3013 of the Resource Conservation and Recovery Act (RCRA),
42 U.S.C. ~ 6934. The Order required RISWMC to produce a
proposal for the monitoring, sampling, testing, analysis,
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and reporting at the Central Landfill. The Order was based
on EPA's determination that the landfill may have presented
and may present a substantial hazard to human health and the
environment. This proposal formed the basis for the
performance of the Remedial Investigation under the
Administrative Order on Consent between RISWMC and EPA in
1987.
The site was added to the NPL in June 1986. The EPA and
RISWMC entered into a Consent Order to perform a Remedial
Investigation and Feasibility Report (RIfFS) in April 1987.
The RI for OU1 was completed in March 1993. The FS for OU1
was completed in December 1993. Both documents are part of
the Administrative Record for OU1. The RI for OU2 is
currently underway and will be the subject of a separate
Record of Decision.
The current owner, RIS\~C, has expressed a willingness to
conduct the remedial design and remedial action (RDfRA) for
the OU1, source control remedy. EPA is currently conducting
negotiations with RISWMC and, in a limited capacity, with
the State of Rhode Island to voluntarily perform the
remedial design and remedial action for OU1.
III. COMMUNITY PARTICIPATION
Throughout the Site's history, community concern and
involvement has been high. EPA has kept the community and
other interested parties apprised of the Site activities
through informational meetings, fact sheets, press releases
and public meetings.
In February, 1994, EPA made the administrative record
available for public review at EPA's offices in Boston and
at the Marion J. Mohr Library in Johnston, Rhode Island.
EPA published a notice and brief analysis of the Proposed
Plan in the Providence Journal on February 8, 1994 and made
the plan available to the public at the Marion J. Mohr
Library.
In September 1993, EPA issued a fact sheet which summarized
the results of the Remedial Investigation. On February 22,
1994, EPA held an informational meeting to discuss the
results of the Remedial Investigation and the cleanup
alternatives presented in the Feasibility Study Report and
to present the Agency's Proposed Plan. Also during this
meeting, the Agency answered questions from the public.
From February 13 to March 14, 1994, the Agency held a 30 day
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.
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V.
On February 28, 1994, the Agency held a informal public
hearing to again 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 Appendix 0 of this ROD.
IV.
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
The selected remedy is the first operable unit of at least a
two operable unit approach to remediation of the
environmental contamination caused by the Site. The first
operable unit will control the sources of contamination at
the Site. Source control remedies prevent or minimize the
continued release of hazardous substances to the
environment. Source control alternatives rely on the
prevention of exposure for the protection of human health
and the environment. The second operable unit will address
any impacts to off-site areas caused by contaminants that
have already migrated from the Site and beyond the RISWMC
property boundary. During the second operable unit
additional studies will be undertaken to characterize the
extent of off-site contamination and to develop and evaluate
alternatives for remediation should it be required.
In summary, the selected source control remedy for the first
operable unit consists of the following components: capping
the landfill; extracting and treating contaminated
groundwater from the hot spot area; implementing deed
restrictions on groundwater and land use; an evaluation of
the existing landfill gas collection and combustion system;
long-term environmental monitoring; and preventing access.
Exposure to and ingestion of contaminated groundwater is the
principal threat posed by the Site. The combination of
capping the landfill and extracting and treating groundwater
from the hot spot area will prevent or minimize this threat
by containing contaminants on-site. Long-term environmental
monitoring will ensure that the selected source control
remedy remains protective of human health and the
environment.
SUMMARY OF SITE CHARACTERISTICS
Chapter 2 of the Feasibility Study contains an overview of
the Remedial Investigation. A summary of the Remedial
Investigation field activities and the major findings are
summarized below.
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The RISWMC under EPA direction
field activities during the RI
extent of contamination at the
included:
and oversight, conducted
to determine the nature and
Site. These activities
1.
Surface and sub-surface geological and hydrogeological
studies designed to locate bedrock faults and fracture
zones (commonly called lineaments), describe subsurface
geologic conditions, and determine the direction of
groundwater movement;
2.
Extensive sampling and analysis of Site groundwater
from 67 monitoring wells at 41 locations surrounding
the existing landfill within the property owned by
RISWMC to determine the concentration of groundwater
contaminants including volatile organic compounds
(VOCs), semi-volatile organic compounds (SVOCs) and
inorganics;
3.
Sampling and analysis of sludges in the hot spot area
and Dense Non Aqueous Phase Liquid (DNAPL) found in the
fractured bedrock below the hot spot area;
4.
Air sampling and analysis for VOCs on-site and adjacent
to the Site; and
5.
Limited sampling and analysis of surface water and
sediments in Cedar Swamp Brook, Upper Simmons
Reservoir, and Almy Reservoir.
The major findings of the field activities are summarized
below:
2.
1.
Hydrogeological Studies: Groundwater flow in bedrock
was identified as the major pathway for migration of
contaminated groundwater. Results of studies
undertaken during the remedial investigation found no
evidence to suggest that contaminated groundwater
underneath the site is migrating to the Scituate
Reservoir located about 2.5 miles west of the 121 acre
landfill. Rather, the studies concluded that the Upper
Simmons Reservoir, located about 1,200 feet southeast
of the landfill, is the major receptor of groundwater
which passes beneath the Central Landfill. The studies
also indicate that a small portion of the flow beneath
the landfill migrates to the Almy Reservoir, located
about 2,400 feet northeast of the landfill.
Groundwater sampling and Analysis: Groundwater samples
were taken from 67 on-site monitoring wells at 41
locations. The chemical analysis of groundwater
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4 .
samples collected around the perimeter of the landfill
area showed elevated concentrations of many volatile
organic compounds (VOCs), semi-volatile organic
compounds (SVOCs) and inorganics. The analysis of
groundwater samples collected in the vicinity of the
hot spot area showed much higher concentrations of VOCs
and SVOCs. The chemical analysis of groundwater taken
from monitoring wells close to the Central Landfill
property line detected only slightly elevated levels of
a few VOCs, SVOCs, and inorganics.
3 .
Hot Spot Area Studies: The Remedial Investigation
identified the relatively small hot spot area (about
0.5 acre) near the eastern perimeter of the 121 acre
Phase I area (see Figure 1, Appendix A). Large volumes
of liquid industrial hazardous waste are known to have
been accepted for disposal by the previous owner in
several trenches that were excavated into the bedrock
in this area. The liquids have long since penetrated
into the underlying fractured bedrock leaving behind an
approximately one foot thick layer of a rubbery
chemical sludge. Presently, the trenches and chemical
sludge are covered with about thirteen feet of septage
sludge and fifteen feet of landfill debris and daily
soil cover.
Dense non-aqueous phase liquids (DNAPLs) were found in
the fractured bedrock beneath the trenches at the hot
spot. The presence of these DNAPLs are the result of
the disposed liquids penetrating into the underlying
fractured bedrock. These DNAPLs are believed to be a
major source of contamination found in the groundwater
at the Site.
Air Sampling: The studies included air quality
sampling on-site and adjacent to the Central Landfill
Site. As presented in the RI report, air monitoring
for VOCs on-site and adjacent to the Central Landfill
was completed in three phases. Phase I occurred
between September 1987 and March 1988, prior to the
existence of the landfill gas collection and combustion
system. Phase I monitoring data indicated that 14 of
132 analyzed compounds were detected in the samples.
Since Phase I data was collected prior to the
installation of the landfill gas collection and
combustion system, the data is not indicative of
current Site conditions.
Phase II and III data was collected at the request of
RIDEM after the landfill gas collection and combustion
system was installed. EPA analyzed this data to
evaluate any potential on-site or off-site impacts.
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VI.
Phase II involved fifteen consecutive monthly sampling
rounds that occurred between June 1989 and August 1990.
Phase III involved two quarterly sampling rounds
conducted in April and July 1991. Of the 156 compounds
analyzed for, 144 substances were found as constituents
in both upwind and downwind samples. A statistical
comparison of on-site, upwind and downwind data
indicated that on-site concentrations of twelve
compounds were statistically higher than upwind
concentrations; downwind perimeter concentrations of
two compounds were higher than upwind concentrations;
and no compounds were detected at concentrations at
downwind residential locations that were higher than
detected concentrations at upwind, off-site locations.
Air monitoring results are presented in Appendix H of
the RI Report and summarized in Table 2-17 of the Risk
Assessment Report. The significance of these findings
are discussed in Section VI of this ROD.
5.
Surface Water and Sediment Sampling: A limited amount
of surface water and sediment samples were collected
and analyzed from Cedar Swamp Brook, Upper Simmons
Reservoir and Almy Reservoir. Trace levels of VOCs,
SVOCs and metals were detected in both surface water
and sediment samples. Sufficient data has not been
collected to properly characterize contaminant
distribution in the surface water and sediments.
Additional data is being collected as part of the off-
site studies currently being conducted by the RISWMC
for OU2.
SUMMARY OF SITE RISKS
A human health Risk Assessment (RA) was performed to
estimate the probability and magnitude of potential adverse
human health effects from exposure to contaminants
associated with the Site. The human health RA 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 possible exposure;
3) toxicity assessment, which considered the types and
magnitude of adverse health 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 and non-carcinogenic risks
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to human health. A summary of the results of the RA at the
Central Landfill Site is presented in this Section of the
ROD.
Twenty six (26) groundwater contaminants of concern, listed
in Table 1 were selected for evaluation in the RA. The
contaminants of concern include nine VOCs, six SVOCs, and
eleven inorganics. These contaminants constitute a
representative subset of the groundwater contaminants
identified at the Site during the Remedial Investigation.
The groundwater contaminants identified in the Remedial
Investigation are presented in Tables 1 thru 5 in Appendix
B. The twenty-six contaminants of concern were selected to
represent potential Site related hazards based on
concentration, frequency of detection, and mobility and
persistence in the environment. A summary of the health
effects of each of the contaminants of concern can be found
in Section 4.2 and Appendix 0 of the RA.
Potential human health effects associated with exposure to
the contaminants of concern were estimated either
quantitatively or qualitatively 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 Site is presently an active
solid waste management facility. The expected future use of
the landfill itself is continued use as a solid waste
management facility. EPA does not consider the future use
of the landfill as residential property to be a plausible
scenario. The future use of the 1,000 to 2,000 foot area
surrounding the landfill is assumed to continue as presently
zoned for mixed residential and commercial use. Each of the
residences within the 1,000 to 2,000-foot buffer zone are
considered to be potentially habitable. The following is a
discussion of the rationale for selecting those exposure
pathways that may be potentially complete under current and
future use Site conditions.
Soils
Contaminants that may be present in surficial soils and
wastes within the landfill may pose conditions for direct
contact exposure, if accessible to human receptors
(including Site workers and trespassers) and ecological
receptors (including terrestrial plants and animals). A
limited number of surficial soil samples have been collected
from the landfill, with low levels of a small number of
contaminants detected. Under current conditions, the
locations at which surface soil samples were collected
appear to be capped with vegetated soil cover or liner
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TABLE
CONTAMINANTS OF CONCERN
CENTRAL LANDFILL SITE
CONCENTRATION (ug/l)
CHEMICALS
Status(2)
EXPOSURE POINT CONCENTRATION
AVERAGE MAXIIUI
FEDERAl(1)
MCls MClGs
Volatile Organic Compounds
Benzene
Chlorobenzene
1,1- Dichloroethane
Methylene Chloride
Methyl Ethyl Ketone
Toluene
1,1,1-Trichloroethane
T ri ch loroethene
Vinyl Chloride
Semi-Volatile Orqanic Comcounds
Bis(2-ethylhexyl)Phthalate
1,2-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
Naphthalene
1,2,4-Trichlorobenzene
lnorganics
Arsenic
Beryl I i um
Cadmium
Chromium
Cyanide
Lead
Manganese
Mercury
Nickel
Nitrates
Vanadium
13* 31*
383* 610*
15 1'0
12* 50*
9 39
80* 200*
19 79
16 23
12 30
8.5 28
11* 15*
54 130
35 109
53 102
15956* 127000*
0.29 0.73
101* 160*
120 580
51 270
5 zero
100 100
5 zero
1000 1000
200 200
5 zero
2 zero
6 zero
600 600
75 75
70 70
50
4 4
5 5
100 100
200 200
TT(3) zero
200
2 2
100 100
10000 10000
F
F
L
F
L
F
F
F
F
F
F
F
R
F
F
F
P
F
L
F
F
F
L
Notes:
1. US EPA, 1993. Drinking ~ater Regulations and Health Advisories. Office of ~ater-
2. Status: F- Final; P - Proposed; L - Listed for regulation; R - Under review.
3. TT - Treatment technique. Action level of 15 ug/l.
4. -- - Not detected/Not available.
5. * - Exceeds MCL or Non-zero MCLG_on toxicity,
11
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material. Only a small portion of the wastes in the
landfill at the working face, which is currently receiving
refuse, is exposed.
Access to the Site by vehicle is limited to a secured
entrance gate located on Shun Pike. The landfill could
potentially be accessed by foot. Since the landfill is an
operating facility, persons trespassing on the site during
the day are likely to be noticed. Landfill workers employed
to pick up fugitive refuse may incidentally contact soils.
Refuse transporters are not likely to contact soils. Given
the limited potential access to possibly contaminated
surficial soils, it is not likely that direct contact with
soils is a significant exposure pathway. Contaminants in
subsurface soils and wastes would be a potential source of
exposure only if soils are exposed during excavation, such
as during remediation activities. These potential exposures
would be expected to be controlled by worker health and
safety procedures as potential risks during remediation and
are evaluated as part of the Feasibility Study.
Plants may uptake contaminants present in the root zone of
on-site surficial soils or off-site soils receiving runoff.
Animals and birds may directly contact soils or ingest
plants or smaller organisms at the landfill. Presently not
enough data is available on the identification and
characterization of biota at the Site to evaluate the
significance of these pathways. These pathways will be
further evaluated in the OU2 RI.
Groundwater
Under past conditions, residential wells located in areas
surrounding the site may have received groundwater migrating
from the site as well as from several off-site sources of
contamination in the area. Under current conditions, all
residences and businesses surrounding the Site have been
offered public water and almost all have accepted.
Therefore, the exposure pathway of Site groundwater used as
a current water supply is not complete for most locations
surrounding the Site under present conditions.
As previously described, although the State has classified
the groundwater underlying the landfill and areas
immediately surrounding the landfill as GC and GB,
respectively, under the federal classification, all
groundwater at and beyond the edge of the waste management
area is considered current or potential drinking water.
As part of the risk assessment, the risks associated with
the potential potable use of groundwater in off-site areas
downgradient of the Site were evaluated. Exposure routes
associated with this use include ingestion of water,
-------
inhalation of volatiles during showering, and dermal
absorption during showering.
The RI found no evidence to suggest that contaminated
groundwater underneath the Site is migrating to the Scituate
Reservoir. Therefore, this pathway is not considered to be
complete.
Surface Water and Sediment
As previously discussed, the Upper Simmons Reservoir is a
receptor of the majority of shallow groundwater flow from
the Site and the Almy Reservoir a receptor of a small
component of shallow groundwater flow. These reservoirs are
classified by RIDEM for primary and secondary recreation,
such as swimming, fishing and boating, and could be used for
these activities. Potential exposure routes that may be
associated with these activities are direct contact with and
incidental ingestion of surface water and sediments, and
ingestion of fish. To a lesser extent, VOCs may be released
from surface water and inhaled.
Sufficient data has not been collected to characterize the
contamination caused by past Site activities in off-site
surface water, sediment, and fish; therefore, current
exposure to these media cannot be adequately evaluated.
Additional data will be collected in the OU2 RI to allow for
an adequate evaluation of the current exposure to these
media. However, using on-site groundwater contamination
data collected in the OUI RI, the future impacts of the Site
on the Upper Simmons and Almy Reservoirs, assuming no
remedial action was taken at the Site, was estimated. These
estimates were used to evaluate the potential future
exposure to human receptors caused by releases from the Site
as it exists today. The estimate of future exposures does
not account for historical impacts from the Site or other
sources of contamination in the vicinity of the Site to the
Upper Simmons and Almy Reservoirs. Characterization of
ecological habitats and biota associated with these surface
waters has not been completed. Therefore, exposure pathways
including uptake of and contact with contaminants from
surface water and sediments, and transfer through the food
chain cannot be addressed at this time and will be evaluated
in the OU2 RI.
Air
Volatiles and dusts may be released into the ambient air
from refuse and soils and as emissions from the gas recovery
facility on the landfill. These emissions may potentially
be transported to on-site or off-site receptors. As
-------
previously discussed, RI monitoring data for volatiles do
not indicate an impact on air quality at off-site
residential areas. On-site concentrations were below limits
established under the Occupational Safety and Health Act
(OSHA) to be protective of worker exposures. Therefore,
under present conditions, the exposure to VOCs potentially
released from the Site does not appear to be a significant
pathway.
Possible Exposure Pathways
There are no complete exposure pathways for human receptors
under present Site conditions. The potentially complete
exposure pathways evaluated for human receptors under future
use conditions at the Central Landfill Site are:
1.
Ingestion and dermal absorption of compounds and
inhalation of volatiles in shower air from groundwater
originating from the site that supplies off-site wells
located in areas outside the toe of the landfill
(future), and
2 .
Direct contact with and incidental ingestion of surface
water in the Upper Simmons Reservoir and Almy Reservoir
(future) .
For each pathway evaluated, an average and a reasonable
maximum exposure point concentrations (EPC) was generated
corresponding to exposure to the average and the maximum
concentration detected or calculated in that particular
medium. The EPC represents the amount of a chemical in an
environmental medium to which a receptor may be exposed at
the location of potential contact. EPCs are determined
based on site sampling data. or on modeling results specific
to the exposure pathway of concern. A summary of the method
used to estimate EPCs for groundwater and surface water is
provided below. A more detailed explanation of EPC
estimates is provided in Sections 3.3 and 3.4 of the RA
report.
Exposure estimates for the use of groundwater were based on
on-site groundwater sampling results from selected
monitoring wells located outside the toe of the landfill.
The wells include MW-B, MW-B1, MW-C, MW-C1, WE87-4, MW90-28
(A&B), and MW90-34B. Exposure estimates for groundwater
were conservatively assumed to be present in a theoretical
supply well at these on-site measured concentrations for an
exposure period of 30 years.
Exposure estimates for contact with surface water (Upper
Simmons and Almy Reservoirs) were estimated using
contaminant loading calculations presented in Section 9.30
-------
and Appendix G of the RI Report. The two methods, described
in section 9.31 of the RI report were used to estimate the
reasonable worst-case and average exposure concentrations in
Upper Simmons Reservoir since it is the major receptor of
shallow groundwater flow from the Site. An average exposure
concentration was also estimated for Almy Reservoir using a
different but similar method as that used for Upper Simmons.
As explained above, sufficient data has not been collected
to characterize the contamination caused by past site
activities in off-site surface water, sediment, and fish,
therefore, current exposure to these media cannot be
adequately evaluated. This characterization will be
performed as part of OU2.
As presented in the RI report, Method 1 flux calculations
were based on an estimation of the size and distribution of
contaminants in the subsurface of the hot spot area. Since
the remaining mass and distribution of unknown quantities of
wastes disposed in the area are not known, the method is
somewhat speculative. The method did not incorporate
attenuation mechanisms and did not rely on the establishment
of steady state conditions. The method likely provides
upper bound estimates of the probable annual flux to the
Upper Simmons Reservoir. Estimates of concentrations
derived from this method were used to represent EPCs in the
reasonable worst-case exposure scenario.
As described in the RI report, Method 2 assumes that steady
state conditions have been established and that the
combination of biodegradation, volatilization, and dilution
processes were reducing, and would continue to reduce, the
concentrations of contaminants originating in hot spot area
and migrating with groundwater to Cedar Swamp Brook and the
toe of the landfill. Estimates derived from this method
were used to represent EPCs in the average case exposure
scenario.
Average Exposure concentrations were calculated for the Almy
Reservoir using a method similar to Method 2 described
above. No reasonable worst-case estimates were made for the
Almy Reservoir. Operable unit 2 will further evaluate the
human health risks in Upper Simmons and Almy Reservoirs and
also evaluate the ecological risks.
Excess lifetime cancer risks were determined for the
exposure pathways by multiplying the exposure level with the
chemical specific cancer factor. Cancer potency factors
have been developed by EPA from epidemiological or animal
studies to reflect a conservative "upper bound" of the risk
posed by potentially carcinogenic compounds. That is, the
true risk is unlikely to be greater than the risk predicted.
The resulting risk estimates are expressed in scientific
-------
notation as a probability (e.g. 1 x 10-6 for 1/1,000,000)
and indicate (using this example), that an average
individual is not likely to have greater than a one in one
million chance of developing 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 measure of the potential for non-carcinogenic health
effects. A hazard quotient is calculated by dividing the
exposure level by the reference dose (RfD) or other suitable
benchmark for non-carcinogenic health effects for an
individual compound. 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 epidemiological or
animal studies and incorporate uncertainty factors to help
ensure that adverse health effects will not occur. The
hazard quotient is often expressed as a single value (e.g.
0.3) indicating the ratio of the stated exposure as defined
to the reference dose value (in this example, the exposure
as characterized is approximately one third of an acceptable
exposure level for the given compound). The hazard quotient
is only considered additive for compounds that have the same
or similar toxic endpoint and the sum is referred to as the
hazard index (HI). (For example: the hazard quotient for a
compound known to produce liver damage should not be added
to a second whose toxic endpoint is kidney damage).
Table 6, Appendix B presents a summary of the carcinogenic
and non-carcinogenic risks for the contaminants of concern
in groundwater and surface water to reflect potential future
exposures corresponding to the average and the reasonable
worst case scenarios. Separate risk calculations for each
contaminant of concern are presented in Appendix C of the
risk assessment.
Carcinogenic and non-carcinogenic risk estimates were
evaluated relative to the EPA's risk management criteria.
The carcinogenic risks or ILCR (Incremental Lifetime Cancer
Risks) are compared to a risk range of 10-6 ("Point of
departure") to 10-4. Non-carcinogenic risks, or HIs (Hazard
Indices), are compared to a value of one (1), below which
adverse health effects from exposures are not anticipated.
The aggregate risk and hazard index were almost solely
attributable to risks associated with the ingestion of
groundwater. The carcinogenic risks are primarily from six
(6) of the contaminants of concern: arsenic, beryllium,
-------
bis(2-ethylhexyl) phthalate, benzene, 1,2-dichlorobenzene and
1,2-dichloroethane. A risk greater than 1X10-6 was
calculated for each of these six contaminants. The non-
carcinogenic risks are primarily from manganese, vanadium
and arsenic. A hazard index greater than 1.0 was calculated
for each of these three contaminants. The hazard quotient
for manganese contributed greater than 98% to the total
hazard index for the average case, and 99% for the
reasonable worst case.
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 public health, welfare, or the
environment. The risk assessment concluded that there is a
potential risk to human health from ingestion of groundwater
at the Site and if contaminated groundwater was allowed to
continue to migrate off-site, and off-site groundwater was
developed as a source of drinking water, then there would
remain a potential human health risk in the future due to
the ingestion of the contaminated groundwater. The 121 acre
Phase I landfill area is the source of the groundwater
contamination, therefore, the remedial action will focus on
controlling this source of groundwater contamination.
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
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. In
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
maximum 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 Congressional mandates.
Using the information gathered during the RI and RA, EPA
identified several source control response objectives to use
in developing source control alternatives to prevent or
-------
5.
6.
minimize the continued release of contaminants from the
existing 121 acre Phase I area into the environment. These
remedial action objectives were developed to mitigate
existing and future potential threats to public health and
the environment. These source control response objectives
are:
1.
Minimize the effects of landfill contaminants on
groundwater quality; specifically, reduce to a minimum
the amount of precipitation allowed to leak through the
waste column and infiltrate to the groundwater;
2.
Eliminate potential future risks to human health
through direct contact with landfill contaminants by
maintaining a physical barrier;
3.
Minimize migration of contaminants in groundwater so
that groundwater is not injurious to the aquatic
ecological system of receiving water bodies (Upper
Simmons Reservoir, Cedar Swamp Brook and Almy
Reservoir);
4.
Minimize risks to human health associated with
potential future consumption of and direct contact with
groundwater;
Comply with state and federal ARARs; and
Minimize potential impacts of implementing the selected
source control alternative on adjacent surface waters
and wetlands.
B. Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. Because many CERCLA
municipal landfill sites share similar characteristics, they
lend themselves to remediation by similar technologies. EPA
has established a number of expectations as to the types of
technologies that should be considered and alternatives that
should be developed; they are listed in the National
Contingency Plan (40 CFR 300.430(a) (1». For CERCLA
municipal landfill sites, it is expected that;
1.
The principal threats posed by a site will be treated
wherever practical, such as in the case of remediation
of a hot spot.
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2.
Engineering controls such as containment will be used
for waste that poses a relatively low long-term threat
or where treatment is impractical.
3.
A combination of methods will be used as appropriate to
achieve protection of human health and the environment.
An example of combined methods for municipal landfill
sites would be treatment of hot spot in conjunction
with containment (capping) of the landfill contents.
4.
Institutional controls such as deed restrictions will
be used to supplement engineering controls, as
appropriate, to prevent exposure to hazardous wastes.
5.
Innovative technologies will be considered when such
technologies offer the potential for superior treatment
performance or lower costs for performance similar to
that of demonstrated technologies.
6.
Groundwater will be returned to beneficial uses
whenever practical, within a reasonable time, given the
particular circumstances of the site.
In accordance with these expectations and the response
objectives previously described, a range of technologies/
processes were developed for the site to treat contamination
associated with four distinct media; landfill waste, hot
spot solids, groundwater (in refuse, soil and rock), and hot
spot groundwater.
As discussed in Chapter 5 of the Feasibility Study Report,
technologies/processes were first identified, assessed and
screened based on their short- and long-term effectiveness,
implementability, and cost. The purpose of the initial
screening was to eliminate from further consideration those
technologies/ processes which in general may be suitable at
CERCLA municipal landfills but were not considered suitable
for implementation at the Central Landfill Site. The
technologies/processes that remained after the inial
screening process were then used to develop source control
(SC) alternatives for the four distinct media previously
discussed. Chapter 6 of the Feasibility Study Report
presented the media specific Source Control (SC)
alternatives. Sitewide SC alternatives were then developed
by combining alternatives from each of the four media
specific SC alternatives. The Sitewide SC alternatives and
their detailed analyses are presented in Section 7 of the
Feasibility Study Report.
-------
In summary, twenty-two (22) media specific SC alternatives
were developed in Section 6 of the Feasibility Study Report
consisting of four alternatives for landfill wastes, six
alternatives for hot spot solids, seven alternatives for
groundwater, and five alternatives for hot spot groundwater.
From these 22 media specific SC alternatives, nine (9) Site-
wide SC alternatives were developed for detailed analysis in
Section 7 of the Feasibility Study Report.
VIII.
DESCRIPTION OF SOURCE CONTROL ALTERNATIVES
This Section provides a narrative summary of each
alternative evaluated. There are several activities which
are common to all the Sitewide source control alternatives
considered except the No Action alternative. These common
activities include:
1.
Implementing deed restrictions on groundwater use and
land development within property owned by the RISWMC.
2 .
Initiating a long-term program of sampling and analysis
of groundwater, surface water and air.
3 .
Conducting a detailed evaluation of the existing
landfill gas collection and combustion system.
4 .
Installing a chain link fence to prevent access.
Alternative OU1-1: No Action: This alternative was
evaluated in detail in the FS to serve as a baseline for
comparison with the other alternatives under consideration.
Under this alternative no treatment or containment of solid
waste or groundwater would occur and no effort would be made
to restrict potential exposure to Site contaminants. A
schematic of this alternative is shown in Figure 2, Appendix
A.
Estimated Time for Design and Construction:
Estimated Time of Operation: N/A
Estimated Capital Cost: N/A
Estimated Operations and Maintenance Costs
worth): N/A
Estimated Total Cost (net present worth):
N/A
(net present
NjA
-------
Alternative OUl-2: Cappinq of Solid Waste with a Sinqle-
Barrier Cap in Accordance with RIDEM Solid Waste Requlations
and HYdraulic Containment and Treatment of Hot Spot
Groundwater: This alternative, in addition to the
activities common to all the alternatives would require: 1)
construction of a single-barrier cap over the 121-acre Phase
I area which would meet the Rhode Island Department of
Environmental Management (RIDEM) Rules and Regulations for
Solid Waste Management closure standards and; 2) require
hydraulic containment and treatment of groundwater in the
hot spot area of the landfill. A schematic of this
alternative is shown in Figure 3, Appendix A.
The cap proposed in this alternative would be a single-
barrier cap system meeting the requirements of the RIDEM
Solid Waste Rules and Regulations. The components of the
RIDEM solid waste single barrier cap design are illustrated
in Figure 4, Appendix A.
Currently, 32 acres of the 121 acre Phase I area are capped
with a RIDEM approved single-barrier cap. The remaining 89
acres are covered with one foot of compacted granular fill.
Also, there are 33 acres of lined expansion areas designated
as Phase II and III which, when completed, will overlap
about 48.4 acres of the western portion of the Phase I area.
The proposed single-barrier cap will be placed directly over
those portions of the Phase I area that have not already
been covered with a single-barrier RIDEM cap and those
portions which will not be impacted by the Phase II and III
expansion. The existing 32 acre single-barrier RIDEM
approved cap would be integrated into the new single-barrier
cap. Once the phase II and III expansion areas reach their
capacity, the proposed single-barrier cap will be placed
directly over that portion of the expansion area which
overlies the Phase I area.
Each layer of the proposed single-barrier cap is described
below. There may be some modifications in the thickness and
composition of these layers during the design process.
1.
A 6-inch thick granular bedding layer to allow for
placement of the synthetic barrier and to establish the
landfill base grade which will be about 3:1
(horizontal:vertical), which is equivalent to a slope
of 18.4 degrees above the horizontal.
2 .
A synthetic barrier consisting of a 60 mil textured
geomembrane to prevent water from infiltrating through
the landfill.
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3.
A 12 inch thick drainage layer will be placed above the
geomembrane to allow water to drain off this synthetic
barrier and to prevent the ponding of water over this
synthetic barrier. This layer will consist of sand or
a sand and gravel mix.
5.
The top layer of the cap is a vegetative soil layer
comprised of 6 inches of subsoil and 6 inches of
topsoil. This layer allows vegetation to grow on the
cap. A filter fabric is often placed between this
layer and the drainage layer to prevent fine material
in the top layer from clogging the drainage layer.
Only short rooted species of plants resistent to
drought will be selected for planting in the topsoil.
Deep rooted plants could damage the drainage and
barrier layers.
6.
Surface water drainage controls will be constructed to
prevent erosion of the cap. Drainage controls will
include perimeter swales spaced vertically about 25
feet ringing the landfill in a terrace configuration in
the same manner currently used at the Site. The
perimeter swales will consist of bermed soil with a
crushed stone bed. The perimeter swales will drain to
downchutes (drainage channels) to channel runoff away
from the landfill.
The groundwater collection system will consist of several
deep wells (at least 200 feet into bedrock) extracting an
estimated 30,000 gallons of contaminated groundwater per day
from the hot spot area. The results of a pump test to be
conducted in the hot spot area during the design phase will
help determine the exact location and number of extraction
wells necessary to contain hot spot groundwater. The source
control remedy includes a comprehensive groundwater
monitoring program. To measure the performance of the hot
spot groundwater containment system, hydraulic flows and
groundwater contaminant concentrations will be carefully
monitored. Given the uncertainties associated with the
limits of the hot spot area, placement of the wells as
effective locations may be difficult. Therefore, the
location of the wells may require adjustments or
modifications if data collected during operation warrants
such adjustments or modifications.
The extracted groundwater will be treated on-site to remove
metals and organic compounds so that clean water may be
discharged to either on-site surface water or the Cranston
Waste Water Treatment Plant. The final discharge location
will be selected during the remedial design phase.
Groundwater treatability studies will be conducted during
-------
the design phase to determine the appropriate number and
size of treatment units and treatment techniques to optimize
the effectiveness of the treatment system.
The components of the groundwater treatment system are shown
in Figure 5, Appendix A and described below:
1.
The groundwater would first be sent to an
equalization/settling tank to allow mixing and
equalization of the flows from the various extraction
wells. Any DNAPL or solids extracted along with the
groundwater will settle out and be removed and properly
disposed of.
2.
Extracted groundwater would then be treated for the
removal of metals (primarily iron and manganese), and
other dissolved inorganics. The metals removal process
will consist of a chemical precipitation/sand
filtration process. Many of the metals dissolved in
the groundwater can be converted to corresponding
insoluble salts by direct pH adjustment with lime,
sodium hydroxide, sodium sulfide, or a combination of
these materials. Many other chemicals, including
polymers, have also been demonstrated to be effective
precipitating agents. Sand filtration, one of the most
widely used processes in water treatment, involves
passing an aqueous stream containing suspended solids
through a sand bed. Various physical and chemical
forces cause the solids to be retained within the sand
bed; and
3.
After the groundwater is treated to remove the
inorganic contaminants, the organic contaminants will
be treated using a UV/Chemical Oxidation system. This
treatment technology uses a chemical reaction
(oxidation) to convert the hazardous organic
contaminants to nonhazardous or less hazardous
compounds by introducing hydrogen peroxide, ozone or
both into the contaminated water in the presence of
ultraviolet light (UV). If the oxidation reaction is
carried to completion, the end products from the
oxidation of non-chlorinated hydrocarbons are carbon
dioxide and water. The oxidation of chlorinated
hydrocarbons may produce small amounts of hydrochloric
acid and/or inorganic chlorides which may require
additional treatment.
The cost of the alternative is summarized as follows by the
two potential discharge options evaluated, either to surface
water or to the Cranston POTW.
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Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 20,450,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,160,000
Estimated Total Cost (net present worth): $ 27,160,000
POTW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 20,450,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,760,000
Estimated Total Cost (net present worth): $ 32,590,000
Alternative OUl-3: Cappinq of Solid Waste with a Sinqle-
Barrier Cap in Accordance with RIDEM Solid Waste Requlations
and Hvdraulic Containment of Groundwater Alonq the Southern
Perimeter of the Landfill: This alternative, in addition to
the activities common to all the alternatives would require:
1) construction of a single-barrier cap over the 121-acre
Phase I area which would meet the Rhode Island Department of
Environmental Management (RIDEM) Rules and Regulations for
Solid Waste Management closure standards and; 2) require
hydraulic containment and treatment of groundwater along the
southern perimeter of the landfill. A schematic of this
alternative is shown in Figure 6, Appendix A.
This alternative would use the same capping scenario as that
described in alternative OUl-2. Instead of extracting and
treating groundwater from the hot spot area, groundwater
would be extracted from along the southern perimeter of the
landfill and treated before being discharged to either on-
site surface water or the Cranston Waste Water Treatment
Plant.
The groundwater extraction system would extend over a length
of approximately 3,600 feet and consist of an estimated
thirty-six extraction wells installed to a depth of about
230 feet. About 200,000 gallons of contaminated water per
day would be extracted from the ground.
The system used to treat the extracted groundwater would
depend on the discharge option selected. If the groundwater
is discharged to on-site surface water, the treatment system
would be identical to the system used to remove the
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inorganic and organic contaminants in groundwater extracted
from the hot spot area. This system was discussed
previously under alternative OU1-2. If the groundwater is
discharged to the Cranston Waste Water Treatment Plant
(POTW), only treatment to remove inorganic contaminants
would be needed. Removal of organic contaminants would not
be required. Therefore the UV/Oxidation process would not
be part of the treatment system if the POTW discharge option
is selected.
All the other treatment steps used for treatment of
inorganic contaminants would be the same as that described
previously under alternative OU1-2. The decision to forgo
organics treatment for the POTW discharge option was based
on available information, without pilot studies, and on the
requirements for organic contaminant loadings in discharges.
to the Cranston Waste Water Treatment Plant. The primary
requirement for organics is that the total toxic organics
(TTO) be below 2.13 parts per million (ppm). Based on the
results of groundwater analyses, the average concentration
of TTO in groundwater extracted from all of the landfill,
other than the hot spot area, is expected to be about 1 ppm.
Treatment for inorganic removal is expected to further
reduce this concentration.
Surface Water Discharge option
Estimated Time for Design and Construction: 5 years
Estimated Time of operation: 30 years
Estimated Capital Cost: $ 22,930,000
Estimated operations and Maintenance Costs (net present
worth): $ 820,000
Estimated Total Cost (net present worth): $ 27,160,000
POTW Discharge option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated capital Cost: $ 22,930,000
Estimated operations and Maintenance Costs (net present
worth): $ 1,550,000
Estimated Total Cost (net present worth): $ 32,950,000
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Alternative OUl-4: Cappinq of Solid Waste with a Sinqle-
Barrier Cap in Accordance with RIDEM Solid Waste Requlations
and Hvdraulic Containment of Groundwater Alonq the Southern
Perimeter of the Landfill and in the Hot Spot Area: This
alternative, in addition to the activities common to all the
alternatives would require: 1) construction of a cap over
the 121-acre Phase I area which would meet the Rhode Island
Department of Environmental Management (RIDEM) Rules and
Regulations for Solid Waste Management closure standards
and; 2) hydraulic containment and treatment of groundwater
extracted along the southern side of the landfill and in the
hot spot area. A schematic of this alternative is shown in
Figure 7, Appendix A.
This alternative would use the same capping scenario as that
described in alternative OU1-2. Groundwater would be
extracted from two locations: 1) along the southern
perimeter of the landfill (peak flow of 230 gpm) and; 2)
from the hot spot area (20 gpm). These groundwater
extraction systems would be identical to those described in
Alternatives OU1-2 and OU1-3.
If the Cranston POTW is selected as the discharge option,
the groundwater extracted from the two locations would be
treated separately. The treatment system for the hot spot
groundwater and southern perimeter of the landfill
downgradient groundwater were described in Alternatives OUl-
2 and OU1-3.
If on-site surface water is selected as the discharge
option, then the two treatment systems would be combined.
The combined system would consist of pre-treating the
extracted hot spot groundwater for metals removal and the
effluent of this pretreatment step would become a component
of the influent to the southern perimeter groundwater
treatment system for organics. The southern perimeter
treatment system would consist of a metals precipitation
step for the southern perimeter groundwater and an organics
treatment step (UV/oxidation) for the combined hot spot and
south side extracted groundwaters. The treatment
technologies for on-site surface water discharge were
described in Alternatives OU1-2 and OUl-3.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 25,500,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,400,000
Estimated Total Cost (net present worth): $ 34,330,000
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POTW Discharge option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 25,760,000
Estimated Operations and Maintenance Costs (net present
worth): $ 2,900,000
Estimated Total Cost (net present worth): $ 48,180,000
Alternative OUl-5: Cappinq of Solid Waste with a Multi-
Layer RCRA C Cap and HYdraulic Containment and Treatment of
Hot spot Groundwater: This alternative, in addition to the
activities common to all the alternatives would require: 1)
Constructing a multi-layer RCRA C cap over the existing 121
acre Phase I area and incorporating the existing 32 acres of
RIDEM approved cap on the side slopes; and 2) hydraulic
containment and treatment of groundwater in the hot spot
area of the landfill. A schematic of this alternative is
shown in Figure 8, Appendix A.
This alternative would use the same capping scenario as that
described in alternative OU1-2; however, the proposed cap
would be a mUlti-layer RCRA C cap instead of a single-
barrier RIDEM approved cap. As in alternatives OUl-2, 3,
and 4, the existing 32 acre single-barrier RIDEM approved
cap would be retained and integrated into the new multi-
layer cap. Additional cover over the existing 32-acre cap
area for frost protection may be required. The decision
whether or not additional cover material is needed will be
decided during the remedial design phase. There may be some
modifications in the thickness and composition of these
layers during the design process.
Each layer of the multi-layer cap is described below (from
the bottom layer contiguous to the waste, to the top
vegetative layer). A cross section of the proposed multi-
layer cap for both the top, flat area and side slopes of the
landfill is provided in Figure 9, Appendix A. There may be
some modifications in the thickness and composition of these
layers during the design process.
1.
A base layer comprised of approximately 6 inches of
fill material. This material will establish the
landfill base grade which will be about 3:1
(horizontal:vertical), which is equivalent to a slope
of 18.4 degrees above the horizontal.
2 .
A bottom low hydraulic conductivity layer to minimize
any potential leakage through the upper low hydraulic
conductivity layer located immediately above this layer
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6.
as discussed below. The bottom low hydraulic
conductivity layer is often made with clay or a
manufactured clay-like material. On the top, flat
portions of the landfill, this bottom layer may consist
of a bentonite geocomposite mat (manufactured clay
layer). However, clay and manufactured clay
substitutes can't be placed on steep slopes such as the
side slopes at Central Landfill. Therefore, at this
Site, on the side slopes, the bottom low hydraulic
conductivity layer will consist of 18 inches of a
material that is more resistent to sliding than clay,
yet has similar low hydraulic conductivity
characteristics. This material will likely be a silty
soil.
3 .
The upper low hydraulic conductivity layer will be a
synthetic barrier. This will be the main barrier for
preventing water from infiltrating through the
landfill. This synthetic barrier will be either a 40-
mil (.04 inch) VLDPE plastic membrane or a 60-mil (.06
inch) HDPE plastic membrane.
4.
A 12 inch thick drainage layer will be placed above the
synthetic barrier to allow water to drain off the
synthetic barrier and to prevent the ponding of water
over the synthetic barrier. This layer will consist of
sand or a sand and gravel mix.
5.
The top layer of the cap is a vegetative soil layer
comprised of 18 inches of subsoil and 6 inches of
topsoil. This layer adds frost protection and allows
vegetation to grow on the cap. A filter fabric is
often placed between this layer and the drainage layer
to prevent fine material in the top layer from clogging
the drainage layer. Only short rooted species of
plants resistent to drought will be selected for
planting in the topsoil. Deep rooted plants could
damage the drainage and barrier layers.
Surface water drainage controls will be constructed to
prevent erosion of the cap. Drainage controls will
include perimeter swales spaced vertically about 25
feet ringing the landfill in a terrace configuration in
the same manner currently used at the Site. The
perimeter swales will consist of bermed soil with a
crushed stone bed. The perimeter swales will drain to
downchutes (drainage channels) to channel runoff away
from the landfill.
The hot spot groundwater collection system is identical to
the system described previously under alternative OUl-2.
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The cost of the alternative is summarized below by the two
potential discharge options evaluated, to surface water or
to the Cranston POTW.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 27,260,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,160,000
Estimated Total Cost (net present worth): $ 32,110,000
PO'lW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 27,260,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,760,000
Estimated Total Cost (net present worth): $ 37,540,000
Alternative OUl-6: Cappinq of Solid Waste with a Multi-
Laver RCRA C Cap and Hvdraulic Containment of Groundwater
alonq the Southern Side of the Landfill: This alternative,
in addition to the activities common to all the
alternatives would require: 1) Construction of a multi-
layer cap over the 121 acre Phase I area and incorporates
the existing 32 acres of RIDEM approved cap; 2) hydraulic
containment and treatment of groundwater extracted along the
southern perimeter of the landfill. A schematic of this
alternative is shown in Figure 10, Appendix A.
The capping scenario and design would be identical to that
described for alternative OUl-5. The groundwater extraction
and treatment system for this alternative would be identical
to the system previously described for alternative OUl-3.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 29,750,000
Estimated Operations and Maintenance Costs (net present
worth): $ 820,000
Estimated Total Cost (net present worth): $ 32,110,000
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POTW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 30,420,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,550,000
Estimated Total Cost (net present worth): $ 37,900,000
Alternative QUl-7: Cappinq of Solid Waste with a Multi-
Laver RCRA C Cap. Hvdraulic Containment of Groundwater Along
the Southern Perimeter of the Landfill and in the Hot Spot
Area: This alternative, in addition to the activities
common to all the alternatives would require: 1)
Construction of a multi-layer cap over the 121 acre Phase I
area and incorporates the existing 32 acres of RIDEM
approved cap; 2) hydraulic containment and treatment of
groundwater which passes beneath both the hot spot and the
southern perimeter of the landfill. A schematic of this
alternative is shown in Figure 11, Appendix A.
The capping scenario and design would be identical to that
described previously for alternative, QUl-5. The
groundwater extraction and treatment system for this
alternative would be identical to the system previously
described for alternative OUl-4.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 32,280,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,400,000
Estimated Total Cost (net present worth): $ 39,280,000
POTW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 32,580,000
Estimated Operations and Maintenance Costs (net present
worth): $ 2,900,000
Estimated Total Cost (net present worth): $ 53,120,000
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Alternative OU1-a: Cappinq of Solid Waste with a Multi-
Laver RCRA C Cap. Hvdraulic Containment of Groundwater Along
the Southern Perimeter of the Landfill and in the Hot Spot
Area and Heated Vapor Extraction of Volatile Orqanics from
the Chemical Sludqes Buried in the Hot Spot Area: This
alternative, in addition to the activities common to all the
alternatives would require: 1) Construction of a multi-
layer cap over the 121 acre Phase I area; 2) hydraulic
containment and treatment of groundwater which passes
beneath both the hot spot and the southern perimeter of the
landfill; and 3) heated vapor phase extraction of organics
from the chemical sludges buried in the hot spot area. A
schematic of this alternative is shown in Figure 12,
Appendix A.
The capping scenario and design would be identical to that
described for the OUI-5. However, for this alternative, the
existing 32 acres of RIDEM approved capping would be removed
rather than incorporated and replaced with the multi-layer
cap design. The groundwater extraction and treatment system
for this alternative would be identical to the system
previously described for Alternative OUI-4.
The heated vapor extraction system would consist of an
estimated 25 vapor injection and extraction wells installed
in the hot spot area. Heated (above 150 degrees centigrade)
air would be injected and recovered from above, below and
within the chemical sludge layer. The contaminated return
air would be treated using (to be verified by testing) a
catalytic oxidation process.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 41,290,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,800,000
Estimated Total Cost (net present worth): $ 50,~20,000
PO'lW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 41,590,000
Estimated Operations and Maintenance Costs (net present
worth): $ 3,300,000
Estimated Total Cost (net present worth): $ 64,270,000
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Alternative OUl-9: Cappinq of Solid Waste with a Multi-
Layer RCRA C Cap, Hydraulic Containment of Groundwater Alonq
the Southern Perimeter of the Landfill and in the Hot spot
Area Excavation of the Chemical Sludqes Buried in the Hot
Spot Area': This alternative, in addition to the activities
common to all the alternatives would require: 1)
Construction of a mUlti-layer cap over the 121 acre Phase I
area; 2) hydraulic containment and treatment of groundwater
which passes beneath both the hot spot and the southern
perimeter of the landfill; and 3) excavation and off-site
disposal of the chemical sludge from the hot spot area. A
schematic of this alternative is shown in Figure 13,
Appendix A.
The capping scenario and design would be identical to that
described for Alternative, OUl-8. The groundwater
extraction and treatment system for this alternative would
. be identical to the system previously described for
Alternatives OUl-4.
An estimated 1,000 cubic yards of ~hemical sludge would be
removed from the hot spot area. In order to remove the
sludge it would be necessary to brace the excavation and
remove the overlying sand and gravel, municipal refuse and
septage sludge. The excavated chemical sludges would be
transported off-site for treatment in a hazardous waste
incinerator.
Surface Water Discharge option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 56,550,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,400,000
Estimated Total Cost (net present worth): $ 59,790,000
PO'IW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 56,850,000
Estimated Operations and Maintenance Costs (net present
worth): $ 2,890,000
Estimated Total Cost (net present worth): $ 73,640,000
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IX.
SUMMARY OF THE COMPARAfIVE ANALYSIS OF ALTERNATIVES
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 are summarized as
follows:
Threshold 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 of human health and 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.
2 .
compliance with applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy
will meet all of the ARARs of other Federal and State
environmental laws and/or provide grounds for invoking
a waiver.
Primary Balancinq crite~ja
The following five criter~a are utilized to compare and
evaluate the elements of one alternative to another that
meet the threshold criteria.
3.
Long-term effectiveness and 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.
Reduction of toxicity, mobility, or volume through
treatment addresses the degree to which alternatives
employ recycling or treatment that reduces toxicity,
mobility, or volume, including how treatment is used to
address the principal threats posed by the site.
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5.
Short term effectiveness 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.
6.
Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option.
7.
Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
Modifvinq Criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received
public comment on the RIfFS and Proposed Plan.
8.
9.
State acceptance addresses the State's position and key
concerns related to the preferred alternative and other
alternatives, and the State's comments on ARARs or the
proposed use of waivers.
Community acceptance addresses the pUblic's general
response to the alternatives described in the Proposed
Plan and RIfFS report.
A detailed tabular assessment of each alternative according
to the nine criteria can be found in Table 6-2lA thru 6-278
of the Feasibility Study.
Following the detailed analysis of each individual alterna-
tive, a comparative analysis, focusing on the relative
performance of each alternative against the nine criteria,
was conducted.
The section below presents the nine criteria and a.brief
narrative summary of the alternatives and the strengths and
weaknesses according to the detailed and comparative
analysis.
1.
Overall Protection of Human Health and the Environment
The preamble to the National Contingency Plan (NCP)
identifies municipal landfills as a type of site where
treatment of the waste may be impracticable because of the
size and heterogeneity of the contents. EPA generally
considers containment to be an appropriate response action
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for large municipal landfills. Because the Central Landfill
site is a large municipal landfill, the alternatives
evaluated consider containment to be the appropriate
response action for source control.
The no action alternative (OUI-l) is not protective of human
health and the environment. The no action alternative would
allow a continued release of contaminants and a possible.
spreading of contamination through the groundwater to
currently uncontaminated areas.
Alternative, OUl-2 through OUl-9 are protective of human
health and the environment however, those alternatives which
include a double-barrier RCRA C cap on the top, flat
portions of the landfill (OUI-5, 6, 7 8 and 9) provide an
added degree of protectiveness against infiltration of storm
water into the waste over those alternatives which include a
single-barrier RIDEM cap (OUI-2, 3 and 4). The RCRA C
capping alternatives do, however, pose a slightly greater
short-term impact to the community than the RIDEM cap
because it will require trucking in more off-site material
for cap construction resulting in greater short-term impacts
to local traffic.
Alternatives OUI-8 and OUl-9 have a greater potential than
all the other alternatives to impact on-site workers, nearby
residents and the environment. This impact results from
removing the existing 32 acres of RIDEM approved capping,
constructing the new RCRA C cap, and from potential
contaminant releases resulting from treating the hot spot
chemical sludges.
Alternatives which include southern perimeter or southern
perimeter plus hot spot groundwater extraction (OUl-3, 4, 6,
7, 8, and 9) may adversely impact nearby wetlands from the
water table drawdown while those with hot spot groundwater
extraction only (OUl-2 and 5) do not impact wetlands. EPA
believes that alternatives which combine hot spot
groundwater extraction and treatment and capping (OUl-2 and
OUI-5) will be effective in protecting human health and the
environment because these alternatives will 1) contain
groundwater that has contaminant concentrations exceeding
MCLs and non-zero MCLGs from migrating beyond the compliance
boundary (refer to Table 15, Appendix B of this ROD), or, in
the absence of MCLs or non-zero MCLGs, contain groundwater
that has contaminant concentrations above levels that are
protective of human health (refer to Table 16, Appendix B of
this ROD) from migrating beyond the compliance boundary and;
2) prevent the degradation of surface waters below the
identified surface water standards. EPA does not believe
those alternatives which include southern perimeter and hot
spot groundwater extraction will significantly increase
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protection of human health and the environ~ent beyond that
which will be provided by alternatives extracting
groundwater at only the hot spot. Alternatives involving
only hot.spot collection are believed to provide sufficient
long-term effectiveness since they contain groundwater
closer to the major source of groundwater contamination.
Alternatives OUl-2, OUl-3, and OUl-4 do not meet the closure
requirements for hazardous waste landfills. Alternatives
OUl-5, OUl-6, and OUl-7 will meet the closure requirements
for hazardous waste landfills on the top, flat portions of
the landfill. For the side slopes, the existing 32 acres of
RIDEM approved capping appears to meet the performance
standards for the closure of a hazardous waste landfill.
Alternatives OUl-8 and OUl-9 are in complete compliance with
all ARARs.
2. Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
The no action alternative (OUI-I) does not comply with the
ARARs identified because it would allow groundwater which
exceeds MCLs to migrate beyond the compliance boundary.
Alternatives OUl-2, 3, and 4, would not be in complete
compliance with the closure requirements for a hazardous
waste landfills. That is, the single barrier RIDEM cap does
not minimize infiltration of precipitation as effectively on .
the top, flat portion of the landfill as a double barrier
RCRA C cap. However, on the landfill side slopes, the
existing 32 acres of RIDEM approved capping appears to meet
the performance criteria for hazardous waste caps to the
extent EPA can determine at this time. That is, the
existing 32 acre cap requires minimum amount of maintenance;
promotes drainage and minimizes erosion; accommodates
settling and subsidence of the landfill; and has a
permeability less than the permeability of the natural
subsoils present. Also, the EPA has no data to suggest that
the existing 32 acre cap will not provide long-term
minimization of the infiltration of liquids through the
closed landfill. The existing 32 acre cap would be
monitored over time to ensure that it is meeting the RCRA C
performance standards for the closure of a hazardous waste
landfill. All of the other ARARs would be met.
Alternatives QUl-5, 6, and 7 will meet the closure
requirements for hazardous waste landfills on the top, flat
portions of the landfill. Again, on the landfill side
slopes, the existing 32 acres of RIDEM approved capping
appears to meet the closure requirements for. a hazardous
waste landfills as explained in the previous paragraph.
All of the other ARARs would be met.
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Alternatives OU~-8 and OUl-9 were judged to be in complete
compliance with all of the identified capping ARARs.
For alternatives OUl-2 through OUl-9 EPA has not identified
groundwater cleanup levels; rather, ARARS have been
identified to monitor the performance of these alternatives.
These ARARs include instituting groundwater monitoring
programs and identify MCLs and non-zero MCLGs and surface
water standards as a measure of performance for groundwater
containment. Each of these alternatives includes a
comprehensive groundwater monitoring program. For
groundwater containment performance, hydraulic flows and
groundwater and surface water contaminant concentrations
will be carefully monitored to determine whether or not the
remedy 1) is effective at containing groundwater that has
contaminant concentrations exceeding MCLs and non-zero MCLGs
from migrating beyond the compliance boundary (refer to
. Table 15, Appendix B of this ROD), or in the absence of MCLs
or non-zero MCLGs contaminant concentrations above levels
that are protective of human health (refer to Table 16,
Appendix B of this ROD) from migrating beyond the compliance
boundary and; 2) prevents the degradation of surface waters
below surface water standards.
3.
Long-term Effectiveness and Permanence
With the exception of the no-action alternative, QU1-I, all
of the alternatives evaluated would provide long-term
effectiveness.
Although all of the alternatives, except the no action
alternative, include capping the 121 acre Phase I area and a
groundwater containment system, alternatives OU1-5, 6, 7, 8,
and 9 have more long-term effectiveness than alternatives
OUl-2, 3, and 4 because they include a double-barrier RCRA C
cap rather than a single-barrier RIDEM cap. Alternatives
OU1-8 and 9 treat the chemical sludges in the hot spot area
in addition to capping and groundwater containment; however,
treatment of the chemical sludges will not provide any
significant additional long-term effectiveness since this
treatment does not address the DNAPLs in the fractured
bedrock underlying the hot spot area. DNAPLs have been
identified as the major source of contamination at the hot
spot area.
Those alternative which include southern perimeter
groundwater extraction and treatment in addition to hot spot
groundwater extraction and treatment (QUl-4, 7, 8 and 9) may
not provide significant additional long-term effectiveness
over those involving only hot spot groundwater extraction
and treatment (OUl-2 and 5). EPA believes that the
combination of hot spot groundwater extraction and treatment
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and capping will 1) contain groundwater that has contaminant
concentrations exceeding MCLs and non-zero MCLGs from
migrating beyond the compliance boundary or, in the absence
of MCLs or non-zero MCLGs contain groundwater that has
contaminant concentrations above levels that are protective
of human health from migrating beyond the compliance
boundary and; 2) prevent the degradation of surface waters
below surface water standards. The reason for this is 1)
hot spot groundwater extraction and treatment should prevent
the continued migration of high levels of contamination
currently existing at the hot spot; and 2) the additional
capping component should minimize infiltration of
precipitation into the landfill thereby effectively
minimizing any future migration of contaminated groundwater
caused by the existing 121 acre Phase I area. These
alternatives also provide sufficient long-term effectiveness
since they contain groundwater close to what is believed to
be the major source of groundwater contamination at the
site. Alternative QU1-5 has more long term effectiveness
than QU1-2 because it includes the double-barrier RCRA C cap
instead of the single-barrier RIDEM cap.
4. Reduction of Toxicity, Mobility, or Volume through
Treatment
The no-action alternative, QU1-1, provides neither
containment of nor treatment of contaminants and
consequently provides no reduction of toxicity, mobility or
volume of contaminants migrating from the source area.
The remaining alternatives, OU1-2 through OU1-9, include
capping (either a single-barrier RIDEM cap or a double-
barrier RCRA C cap) as a component of the alternatives and
will reduce the mobility of contaminants by minimizing the
amount of precipitation that infiltrates the waste mass.
Those alternatives that ;~~lude a double-barrier RC?~ C cap
on the top, flat portio~- ~ the landfill (QUl-5, ~. 7, 8
and 9) will be more effective in minimizing infiltration.
Those treatment technologies that do remove contaminants
from the hot spot area (either directly or through vapor or
groundwater extraction) provide the greatest reduction in
volume and toxicity of contaminants. Alternative QUl-9,
which involves excavation of hot spot chemical sludges, and
extraction and treatment of groundwater from both the hot
spot area and landfill perimeter, provides the greatest
reduction in volume and toxicity of Site contamination.
Alternative QU1-8 which also involves groundwater extraction
and treatment from both the hot spot area and the landfill
perimeter and in-situ treatment of chemical sludges provides
similar, though somewhat less, reduction in the volume and
toxicity of Site contaminants than QU1-9.
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Alternatives OUI-4 and OUI-7, involve groundwater extraction
from both the hot spot area and the southern perimeter of
the landfill but with no treatment or excavation of the hot
spot area chemical sludges, thus providing somewhat less
reduction of volume and toxicity than OUI-8 and OUI-9.
Alternatives OUl-4 and 7 may provide a slightly greater
reduction in the volume and mobility of site contaminants
than alternatives OUI-2 and 5, which involve the extraction
of groundwater at just the hot spot area. Alternatives OUl-
3 and OUI-6 which include the extraction of groundwater at
just the southern, downgradient side of the landfill provide
the least reduction in the volume and toxicity of
contaminants because extraction of groundwater at the
southern perimeter of the landfill is not as effective in
treating the hot spot area which is the major source of
groundwater contamination identified at the Site.
5.
Short-term Effectiveness
Since the no action alternative does not include
construction, there are no short-term effects.
The remaining alternatives, OUI-2 through OUI-9, include
capping (either a single-barrier RIDEM cap or a double-
barrier RCRA C cap) as a component of the alternatives.
Those alternatives that include a double-barrier RCRA C cap
on the top, flat portions of the landfill (OUI-5, 6, 7, 8
and 9) will require bringing on-site a greater amount of cap
construction material than that required for a single-
barrier RIDEM cap (OUl-2, 3 and 4) resulting in greater
short-term.local traffic impacts.
Those alternatives that include either the removal of the
hot spot chemical sludges or in-situ treatment of the hot
spot chemical sludges (OUI-8 and OUl-9) will result in the
greatest short-term risk ~= ~~-sit~ wo~~=~~ ,-~ area
residents due to poten~~a~ e~~cs~=~~ ~; . .
contaminants during these more intrusive activities. That
is, OUl-9 requires excavating an estimated 1000 cubic yards
of hot spot chemical sludges and OUl-8 requires heated vapor
extraction of the hot spot chemical sludges. Both of these
activities increase the potential for on-site workers and
area residents to be exposed to Site contaminants. Further,
these two alternatives require the removal of the existing
32 acres of single-barrier RIDEM approved capping. This
action requires bringing on-site even greater amount of cap
construction material resulting in additional short-term
local traffic impacts. .
All of the alternatives except the no-action alternative
(OU1-1) require groundwater containment systems via
extraction and treatment of groundwater. Alternatives OU1-
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3, 4, 6, 7, 8 and 9, which include extraction and treatment
of large volumes of groundwater from the southern,
downgradient perimeter of the landfill may result in a
significant lowering of the water table which could
potentially impact adjacent wetlands. Extraction of large
volumes of groundwater from the southern perimeter of the
landfill may also cause a migration of contaminants from
identified off-site source areas to the Central Landfill
site. Alternatives OUl-2 and OUl-5 which involve extraction
and treatment of groundwater from only the hot spot area
should not impact any wetlands. Therefore, the groundwater
containment system used in alternatives OUl-2 and OUl-5 is
slightly more short-term effective than the other
alternatives.
Based on the short-term risk to on-site workers, area
residents and the environment from treatment of the chemical
sludges, cap removal and construction, and from groundwater
containment as explained above, alternatives OUl-8 and 9
provide the least short-term effectiveness. Alternatives
OUl-2 and OUl-5 which involve extraction and treatment of
groundwater from only the hot spot area will not impact any
wetlands; therefore, they have more short-term effectiveness
than the groundwater containment alternatives which may
impact wetlands (OUl-3, 4, 6, 7, 8 and 9). Alternative OU1-
2 is slightly more effective than alternative OUl-5 because
less off-site material is required for construction of the
single-barrier RIDEM cap than the double-barrier RCRA C cap.
This results in less short-term local traffic impacts.
6.
Implementability
All of the alternatives evaluated are implementable. Cap
construction and groundwater extraction and treatment are
commonly used at landfill sites. Those alternatives that
involve the in-situ treatment or excavation of the hot spot
chemical sludges (OUl-8 and OUl-9) are technically more
difficult to implement than the other alternatives due to
the difficulties encountered with in-situ treatment (OUl-8)
of sludges with very low pneumatic permeabilities, such as
the hot spot chemical sludges, and the difficulties
encountered in excavation of the hot spot chemical sludges
(OUl-9) given the uncertainties of the areal extent of the
chemical sludges and the amount of overburden material which
would have to be excavated.
Alternatives which include extraction and treatment of hot
spot groundwater (OU1-2, 4, 5, and 7) would be slightly more
difficult to implement than alternatives which involve the
extraction and treatment of groundwater from only the
southern perimeter (OU1-3 and OU1-6). This is due to the
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difficulties in handling and treating the more highly
contaminated hot spot groundwater and the difficulties
involved in handling and disposing of the residual hazardous
sludges that would be generated. The treat~ent of
groundwater extracted from the southern perimeter of the
landfill with the POTW discharge option is easier to
implement because the water would be treated for metals
removal only. However, the POTW must be shown to be in
compliance with its permitting requirements before any
discharge of treated groundwater is allowed. Treatment of
southern perimeter groundwater will have to include UV
oxidation for the treatment of VOCs if the surface water
discharge option is selected. Hot spot groundwater will
have to be treated for both metals and VOCs.
7 .
Cost
Alternatives OU1-B and 9, while treating the hot spot
chemical sludges by either in-situ heated vapor extraction
or excavation, do not provide any additional treatment for
the major source problem, ONAPLS, than would alternatives
OUl-2 and OUl-5, which include only hot spot groundwater
extraction and treatment. Therefore, the added cost for in-
situ treatment or excavation of the hot spot chemical
sludges provides no significant additional benefit for the
protection of human health. Alternatives which include
solely double barrier RCRA C caps (OU1-B and 9) include the
additional cost of removing the existing 32 acres of single
barrier RIOEM capping currently in place on portions of the
side slopes. EPA believes that the existing 32 acre RIOEM
cap will meet the performance standards of a RCRA C cap on
the side slopes, therefore, the difficulties of
implementation and the additional cost of removing the
existing 32 acres of RIOEM capping is not necessary to
protect human health and the environment.
since EPA believes that the combination of capping and hot
spot groundwater extraction and treatment is sufficient to
contain groundwater exceeding MCLs/non-zero MCLGs or .health
based levels from migrating beyond the compliance boundary,
the additional cost of installing a perimeter groundwater
collection and treatment system, when compared to the
insignificant benefit gained, is not cost effective.
8 .
state Acceptance
The state's comments on the Proposed. Plan are provided in
Appendix 0, the Responsiveness Summary. In summary, the
State believes that the remedy selection as 'outlined in the'
Proposed Plan accurately defines, recognizes and complies
-------
with all environmental regulations promulgated by the
Department of Environmental Management. The State of Rhode
Island concurs with the Selected Remedy. Their letter of
concurrence, documenting the State's position on the
Selected'Remedy is provided in Appendix C of this ROD.
9.
Community Acceptance
The comments received from the community on the RIfFS and
the Proposed Plan during the public comment period and EPA's
responses to these comments are summarized in the
Responsiveness Summary in Appendix D.
Many of the comments received from the community raised
serious objections to EPA allowing RISWMC to continue
landfilling operations in the Phase II and III areas. There
. was concern that a delay in closing the Phase I area caused
by the Phase II and III operations would allow for
infiltration of precipitation through any un-capped areas of
Phase I resulting in continued leachate generation. Many
commenters felt that closing Central Landfill should have
been a component of EPA's preferred alternative. There was
also some objections to not excavating the chemical sludges
in the hot spot area and not including southern perimeter
groundwater collection and treatment in the preferred
alternative.
x.
THE SELECTED REMEDY
The selected remedy is source control alternative OUI-5.
The components of the selected source control remedy are
presented and discussed in Section VIII of this ROD. In
summary, the selected source control remedy consists of:
1.
Constructing a multi-layer RCRA C cap over the existing
121 acre Phase I area and incorporating the existing 32
acres of RIDEM approved cap on the side slopes;
2 .
Hydraulic containment and treatment of groundwater in
the hot spot area of the landfill and discharging the
treated groundwater to either on-site surface water or
the Cranston Waste Water Treatment Plant;
3.
Implementing deed restrictions on groundwater use and
land development within property owned by the RISWMC;
Initiating a long-term program of sampling and analysis
of groundwater, surface water and air;
4.
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5.
Conducting a deta~led evaluation of the existing
landfill gas collection and combustion system; and
Ins~alling a chain link fence to prevent access.
The costs of the selected remedy are summarized as follows.
6.
Surface Water Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated Capital Cost: $ 27,260,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,160,000
Estimated Total Cost (net present worth): $ 32,110,000
POTW Discharge Option
Estimated Time for Design and Construction: 5 years
Estimated Time of Operation: 30 years
Estimated capital Cost: $ 27,260,000
Estimated Operations and Maintenance Costs (net present
worth): $ 1,760,000
Estimated Total Cost (net present worth):"$ 37,540,000
The selected remedy is the first operable unit of a two
operable unit approach to remediation of the environmental
contamination caused by the Central Landfill Site. The
selected remedy as well as all the other alternatives
described in Section VIII and evaluated in Section IX of
this ROD, except the no action alternative, are source
control remedies. The purpose of the selected source
control remedy is to prevent or minimize the continued
effects of contaminatio~ .. in the 121 acre Phase I area on
groundwater quality. The second operable unit will address
any impacts to off-site areas caused by contaminants that
have already migrated from the Phase I area and beyond the
edge of the waste management area. During the second
operable unit, additional studies will be undertaken to
better characterize the extent of off-site contamination and
to develop and evaluate alternatives for remediation should
it be required.
A.
Groundwater containment
This is a source control remedy intended to prevent or
minimize the continued release of hazardous substances to
the groundwater. That is, the selected remedy is expected
to 1) prevent groundwater that has contaminant
-------
concentrations exceeding MCLs and non-zero MCLGs from
migrating beyond the compliance boundary (refer to Table 15,
Appendix B of this ROD) or; in the absence of MCLs or non-
zero MCLGs, prevent groundwater that has contaminant
concentrations above levels that are protective of human
health from migrating beyond the compliance boundary (refer
to Table 16, Appendix B of this ROD) and; 2) prevent the
degradation of surface waters below surface water standards.
The National Contingency Plan requires the compliance
boundary for groundwater containment remedies to be
established at and beyond the edge of the waste management
area. Therefore, the compliance boundary for groundwater
issues at the Central Landfill Site is the toe of the 154-
acre (Phase I, II and III) waste management area. The
selected remedy includes a comprehensive groundwater
monitoring program. To measure the performance of the
source control remedy, groundwater and surface water
contaminant concentrations will be carefully monitored.
B.
Design and Construction Issues
The time required to design and construct the selected
remedy has been estimated in the Feasibility Study Report to
be five (5) years from design start. As discussed in
Section VIII of this ROD, the Phase II and III expansion
area, when completed will overlap about 48.4 acres of the
western portion of the Phase I area. The selected remedy
requires covering, with a multi-layer cap, that portion of
the Phase II and III expansion area that overlies the Phase
I area once the Phase II and III areas reach their capacity.
If activities in the Phase II and III areas result in
extending the design and construction schedule beyond the
five (5) year estimate provided in the Feasibility Study
Report, an impermeable barrier will be designed and
installed to prevent or minimize infiltration of
precipitation and leachate through the uncapped areas of the
Phase I area. Once Phases II and III filling activities are
completed, a RCRA C cap will cover that portion of the Phase
II and III areas that overly the Phase I area as originally
planned. The design of the impermeable barrier will be
included as a component of the remedial design. None of the
other components of the selected remedy will be impacted by
the Phase II and III expansion.
Since there is some uncertainty associated with the limits
of the hot spot area groundwater, exact placement of the
extraction wells to contain the hot spot area groundwater
may be difficult. As discussed previously, through
groundwater monitoring, the effectiveness of the hot spot
groundwater extraction and treatment system will be
monitored over time. The extraction and treatment system
may require adjustments or modifications if data collected
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XI.
during its operation warrants such adjustments or
modifications.
As provided in the NCP, EPA will review the Site at least
once every five years after the initiation of remedial
action at the Site since hazardous substances, pollutants
and contaminants remain at the Site. This will ensure that
the remedial action continues to protect human health and'
the environment.
STATUTORY DETERMINATIONS
The remedial action selected for implementation at the
Central Landfill Site is consistent with CERCLA and, the
NCP. The selected remedy is protective of human health and
the environment, attains ARARs and is cost effective. The
selected remedy also satisfies the statutory preference for
treatment which permanently and significantly reduces the
mobility, toxicity or volume of hazardous substances as a
principal element. Additionally, the selected remedy
utilizes alternate treatment technologies or resource
recovery technologies to the maximum extent practicable.
A. The Selected Remedy is Protective of Human Health and
the Environment
The remedy at this site will permanently reduce the risks
posed to human health and the environment by controlling
exposures to human and environmental receptors through
treatment, engineering controls, and institutional controls.
Specifically, the risk presented by this site is the
possible exposure to and ingestion of contaminated
groundwater. The selected containment remedy uses a
combination of capping and collecting and treating
groundwater in the hot spot area to prevent or minimize the
continued release of hazardous substances from the 121 acre
Phase I area to the groundwater. Over time, the combination
of capping and containment of hot spot groundwater is
expected to 1) prevent groundwater that has contaminant
concentrations exceeding MCLs and non-zero MCLGs from
migrating beyond the compliance boundary (refer to Table 15,
Appendix B of this ROD) or; in the absence of MCLs or non-
zero MCLGs, prevent groundwater that has contaminant
concentrations above levels that are protective of human
health (refer to Table 16, Appendix B of this ROD) from
migrating beyond the compliance boundary and; 2) prevent the
degradation of surface waters below surface water standards.
The hot spot containment system should prevent the continued
migration of high levels of contamination currently existing
in the hot spot area. The capping component will prevent or
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minimize the continued infiltration of precipitation into
the landfill thereby minimizing any future migration of
contaminated groundwater caused by the 121 acre landfill
area. Under current conditions, all residences and
businesses surrounding the site have been offered public
water and almost all have accepted; therefore, there is no
current risk associated with the ingestion of contaminated
groundwater. On property owned by the RISWMC, institutional
controls will be implemented to prevent the current or
future use of contaminated groundwater.
B.
The Selected Remedy Attains ARARs
This remedy will attain all applicable or relevant and
appropriate federal and state requirements that apply to the
Site. Environmental laws from which ARARs for the selected
remedial action are derived, and the specific ARARs include:
Action-Specific
Federal Requirements
o
Safe Drinking Water Act, Maximum Contaminant Levels
(MCLs), 40 CFR, Part 141.
o
Safe Drinking Water Act; Non-zero Maximum Contaminant
Level Goals, (Non-zero MCLGs) 40 CFR, Part 141.
o
Clean Water Act (CWA)- National Pollutant Discharge
Elimination System (NPDES) Regulation, 40 CFR Parts
122, 123, and 124 November 16, 1990.
o
CWA - Federal Ambient Water Quality Criteria (FAWQC),
40 CFR 122.44.
o
Resource Conservation and Recovery Act (RCRA)- Releases
from Solid Waste Management Units, 40 CFR, Part 264,
Subpart F.
RCRA - Criteria for Municipal Solid Waste Landfflls, 40
CFR, Part 258, Subpart E.
o
o
RCRA - Interim Status; Thermal Treatment, 40 .CFR, Part
265, Subpart P.
o
RCRA - Air Emissions Standards for Process Vents, 40
CFR, Part 264, Subpart AA.
o
RCRA, Air Emissions Standards for Equipment Leaks, 40
CFR, Part 264, Subpart ss. .
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o
RCRA, Identification and Listing of Hazardous Waste, 40
CFR, Part 261.
o
RCRA, Interim Status TSDF Standards; Thermal Treatment,
40 CFR Part 265, Subpart P.
o
RCRA, Interim Status TSDF Standards; Chemical Physical
and Biological Treatment, 40 CFR Part 265, Subpart Q.
o
RCRA, Land Disposal Restrictions, 40 CFR Part 268.
o
RCRA, Closure and Post-Closure, 40 CFR Part 264,
Subpart G.
o
Clean Air Act, National Emissions Standards for
Hazardous Air Pollutants (NESHAP), 40 CFR Part 61.
State Requirements
o
Rhode Island Rules and Regulations for Groundwater
Quality, RIDEM 7/93, sections 12.02 and 12.03.
o
Rhode Island Rules and Regulations for Groundwater
Quality, RIDEM 7/93, Section 5.06.
o
Rhode Island Rules and Regulations for Hazardous Waste
Management, RIDEM 4/92, Section 9.03.
o
Rhode Island Rules and Regulations for Solid Waste
Management, RIDEM 4/92, Sections 7.08 and 15.11.
o
Rhode Island PDES Regulations (RIPDES), RIDEM, adopted
7/20/84, amended 2/9/93.
o
Air Pollution Control Regulations, Rhode Island
Department of Health, Division of Air Pollution
Control, Effective 8/2/67, amended 5/20/91, Regulation
No.1 Visible Emissions.
o
.Rhode Island Air Pollution Control Regulation No.5,
Fugitive Dust.
o
Rhode Island Air Pollution Control Regulation No.7,
Emissions Detrimental to Persons or Property.
o
Rhode Island Air Pollution Control Regulation No.9,
Approval to Construct, Install, Modify, or Operate.
o
Rhode Island Air Pollution Control Regulation No. 13,
Particulate Emissions.
-------
o
Rhode Island Air Pollution Control Regulation No. 15,
Control of Organic Solvent Emissions.
o
Rhode Island Air Pollution Control Regulation No. 17,
Odors.
o
Rhode Island Air Pollution Control Regulation No. 20,
Burning of Alternative Fuels.
o
Rhode Island Air Pollution Control Regulation No. 22,
Air Toxics.
o
Rhode Island Rules and Regulations for Solid Waste
Management, Section 8, 4/19/92.
o
Rhode Island Rules and Regulations for Solid Waste
Management, Section 9, 4/19/92.
o
Rhode Island Rules and Regulations for Solid Waste
Management, section 10, 4/19/92.
o
Rhode Island Rules and Regulations for Solid Waste
Management, Section 13, 4/19/92.
Chemical Specific
Federal Requirements
o
Safe Drinking Water Act, Maximum contaminant Levels
(MCLs), 40 CFR, Part 141. (Used as guidelines during
risk assessment.) .
o
Safe Drinking Water Act, Maximum Contaminant Level
Goals (MCLGs), 40 CFR Part 141. (Used as guidelines
during risk assessment.)
State Requirements
o
Rhode Island Water Quality Standards, effective 1/9/85,
amended 10/28/88.
o
Rhode Island Water Quality Regulations, effective
1/9/85, amended 10/28/88.
o
Rhode Island Pretreatment Regulations, June 15, 1984.
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Location-Specific
Federal Requirements
o
Protection of Wetlands, Executive Order No. 11990, 40
CFR Part 6, Appendix A.
state Requirements
o
Rules and Regulations Governing the Enforcement of the
Freshwater Wetlands Act, 8/90.
The following policies, criteria, and guidance will also be
considered (TBCs) during the implementation of the remedial
action:
Action Specific
o
RCRA, Air Emissions from Treatment, Storage and
Disposal Facilities, 40 CFR Part 264, Subpart CC
(Proposed 56 FR 33490-33598, 7/22/91)
o
Clean Air Act (CAA), Non-Methane Organic Compounds.
o
May 30, 1991 proposed rule CAA Amendments (56 FR 24468-
24528 to 40 CFR Part 60 Subpart www) .
o
Control of Air Emissions from Air Strippers at
Superfund Groundwater Sites. OSWER Directive 9355.0.28,
6/15/89.
o
USEPA Region I Memo, July 12, 1989, Louis Gitto to
Merrill Hohman regarding Air Stripper Emissions.
o
Technical Guidance for Final Covers on Hazardous Waste
Landfills and Surface Impoundments, EPA/530-SW-047,
7/89.
o
Rhode Island Guidance for Air Quality/Air Tox"ics
Substances.
Chemical Specific
o
USEPA Human Health Assessment Cancer Slope Factors.
o
USEPA Reference Doses.
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Location Specific
o
None Identified.
All the listed ARARs can be found in Tables 7 thru 14, in
Appendix B of this Record of Decision. These tables provide
a brief synopsis of the ARARs and an explanation of the
actions necessary to meet the ARARs. These tables also
indicate whether the ARARs are applicable or relevant and
appropriate to the actions to be taken at the site. In
addition to ARARs, the tables describe standards that are
To-Be-Considered (TBC) with respect to remedial actions.
The principal ARARs are also discussed below.
Principal ARARs for Groundwater Protection
The purpose of the remedy selected in this ROD is to control
the sources of contamination; therefore, no groundwater
cleanup levels are established in this ROD. Since no
cleanup levels are established, no chemical specific ARARs
for groundwater have been identified.
The action specific ARARs for groundwater include
groundwater requirements set out in the Rhode Island Rules
and Regulations for Groundwater Quality, the Rhode Island
Rules and Regulations for Hazardous Waste, 40 CFR 264
Subtitle F, and 40 CFR 258 Subtitle E. Because groundwater
cleanup levels are not established in this ROD, only those
provisions related to implementing a groundwater monitoring
program will be complied with. In addition, maximum
contaminant levels and non-zero maximum contaminant level
goals (MCLs/non-zero MCLGs) in the Safe Drinking Water Act
have been identified as action specific ARARs solely for the
purpose of measuring the performance of the source control
remedy. MCLs/non-zero MCLGs do not establish cleanup levels
for groundwater; rather, the source control remedy is
expected to contain groundwater exceeding MCLs/non-zero
MCLGs within the compliance boundary. For contaminants of
concern for which MCLs/non-zero MCLGs do not exist, health-
based levels have been established (refer to Tables 15 and
16, Appendix B of This ROD).
Principal ARARS for Surface Water Protection
Chemical and action specific ARARs address the protection of
surface water bodies (including wetlands which are addressed
separately below). Chemical specific ARARs .include Rhode
Island Pretreatment regulations for the Cranston POTW
-------
discharge option. This regulation adopts a state and local
pretreatment system for wastewater based on federal
regulations.
Action specific ARARs include the substantive requirements
of the NPDES provisions of the Clean Water Act, and those of
the RIPDES program if they are more stringent than the
federal requirements if the surface water discharge option
is selected. Additionally, the Rhode Island Water Quality
Standards and Water Quality Regulations define the water
quality antidegradation policy of the state. The Rhode
Island Water Quality Standards are based on Federal Ambient
Water Quality Criteria which set standards for surface water
quality for the protection of human health and aquatic life.
Any state standards which are more stringent than federal
standards must be complied with if the surface water
discharge option is selected.
Principal ARARs for Wetland Protection
State and Federal regulations for the protection of wetlands
are closely linked with those for the protection of surface
water bodies; however, the emphasis on wetlands are
typically location specific criteria. Generally, actions
are required to minimize or prevent the destruction,
degradation, alteration or net loss of wetlands as defined
under the State of Rhode Island Department of Environmental
Management Freshwater Wetlands Act and Federal Protection of-
Wetlands Executive Order regulations.
Principal ARARs for Air Quality Protection
Air quality protection requirements are action specific.
Federal National Ambient Air Quality Standards (NAAQS) are
not ARARs but are guidelines for specific criteria
pollutants for air emission sources. NAAQS define levels of
air quality which the EPA judges are necessary to protect
public health. The State Air Pollution Control Regulations
must contain, at a minimum, the federal air quality
requirements. Proposed federal air regulations also require
the collection, control and monitoring of Non-Methane
Organic Compounds (NMOCs) such as benzene and ethane. RCRA
requirements for air emissions from thermal units, process
vents and equipment leaks are also included as potential
ARARs.
State Air Pollution Control Regulations mandate compliance
with specific standards for such parameters as particulate
emissions, installation of air pollution control and
monitoring equipment and adherence to the Federal NAAQS.
-------
Included in the State Air Pollution Control Regulations are
the state Air Toxics Regulations. This regulation prohibits
emission of specified contaminants at rates which would
result in ground level concentrations greater than
acceptable ambient levels set in the regulation. Acceptable
ambient levels are specified as maximum contaminant
concentrations contributed by a stationary air toxic source,
at or beyond the facility property line.
Principal Hazardous Waste ARARs
Hazardous Waste Management ARARs are action specific. The
federal ARARs are derived from the Resource Conservation and
Recovery Act (RCRA). Regulations generated as a result of
this Act set specific standards and protocols for hazardous
waste management. As a RCRA authorized state, the RIDEM has
adopted the federal requirements within the recently amended
RIDEM Rules and Regulations for Hazardous Waste Management.
These regulations govern the management of hazardous waste
activities and set operational standards for hazardous waste
management facilities.
Principal Solid Waste Manaqement ARARs
The RIDEM Rules and Regulations for Solid Waste Management
Facilities are applicable requirements for capping of solid
waste landfills. These regulations specify the minimum type
of final landfill cap to be installed during closure of a
solid waste landfill in the State of Rhode Island.
Principal To Be Considered Requirements
EPA Policy on Controlling Air Emissions from Superfund Air
Strippers provides guidance on air emissions from air
strippers and distinguishes between sites located in ozone
attainment and non-attainment areas. Also identified is
EPAs Technical Guidance Document on Final Covers on
Hazardous Waste Landfills and Surface Impoundments which
provides guidance on constructing landfill caps to meet the
requirements of RCRA subtitle C.
In addition, proposed amendments are included in the
category. These amendments include RCRA subpart CC for air
emissions from treatment, storage, and disposal facilities,
the proposed amendments to the Rhode Island Rules and
Regulations for Groundwater, and the proposed amendments to
the Clean Air Act for NMOCs from landfills.
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C.
The Selected Remedial Action is Cost-Effective
In the Agency's judgment, the selected remedy is cost
effective, i.e., the remedy affords overall effectiveness
proportional to its' 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 ARARs, 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 treat-
ment; and short term effectiveness. 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 summarized in Table 2.
TABLE 2
Selected Source Control Remedy (OU1-S)
Cost Summary
Capital Costs
$27,260,000
Operation & Maintenance Costs
(net present worth)
Surface Water Discharge
POTW Discharge
$ 1,160,000
$ 1,760,000
Total Present Worth Costs
Surface Water Discharge
POTW Discharge
$32,110,000
$37,540,000
Alternatives OUI-8 and 9, while treating the hot spot
chemical sludges by either in-situ heated vapor extraction
or excavation, do not provide any additional treatment for
the major source problem, DNAPLS, than would alternatives
OUI-2 and OUI-5, which include only hot spot groundwater
extraction and treatment. Therefore, the added cost for in-
situ treatment or excavation of the hot spot chemical
sludges provides no significant additional benefit for the
protection of human health.
Alternatives which include solely double barrier RCRA C caps
(OUI-8 and 9) include the additional cost of removing the
existing 32 acres of single barrier RIDEM capping currently
-------
in place on portions of the side slopes. EPA believes that
the existing 32 acre RIDEM cap will meet the performance
standards of a RCRA C cap on the side slopes; therefore, the
difficulties of implementation and the additional cost of
removing 'the existing 32 acres of RIDEM capping is not
necessary to protect human health and the environment.
However, alternatives which include only RIDEM caps (OUl-2,
3, and 4) do not minimize infiltration of precipitation as
effectively on the top, flat portion of the landfill as
alternatives with as double barrier RCRA C cap and
therefore, the added cost of installing a RCRA C cap on the
landfill (and incorporating the existing 32 acre RIDEM cap)
is justified.
EPA believes that the combination of capping and hot spot
groundwater extraction and treatment is sufficient to 1)
prevent groundwater that has contaminant concentrations
exceeding MCLs and non-zero MCLGs from migrating beyond the
compliance boundary or; in the absence of MCLs or non-zero
MCLGs, prevent groundwater that has contaminant
concentrations above levels that are protective of human
health from migrating beyond the compliance boundary and; 2)
prevent the degradation of surface waters below surface
water standards. Therefore, the additional cost of
installing a perimeter groundwater collection and treatment
system, when compared to the insignificant benefit gained,
is not cost effective.
D. The Selected Remedy utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the Maximum Extent Practicable
Once the Agency identified those 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 technologies 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) short-term effectiveness; 4) implementability;
and 5) cost. The balancing test emphasized long-term
effectiveness and permanence and the reduction of toxicity,
mobility and volume through treatment; and considered the
preference for treatment as a principal element, the bias
against off-site land disposal of untreated waste, and
community and state acceptance. The selected remedy'
provides the best balance of trade~offs among the
alternatives.
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The no action alternative, OU1-1, is not protective of human
health and the environment. Alternatives OU1-2, 3, and 4,
which include a single-barrier RIDEM approved cap, do not
comply w~th the RCRA C capping ARAR. EPA evaluated the
remaining alternatives, OU1-5, 6, 7, 8, and 9 to determine
which one provided the best balance in terms of the criteria
presented above. Alternative OU1-5 was selected as the
remedy because of its long-term effectiveness, ability to
reduce toxicity, mobility and volume of contaminants and was
the most efficient in light of implementability and cost
concerns.
Alternatives OU1-8 and 9 treat the chemical sludges in the
hot spot area in addition to capping and groundwater
containment; however, treatment of the chemical sludges will
not provide any significant additional long-term
effectiveness since this treatment does not address the
DNAPLs in the fractured bedrock underlying the hot spot
area. DNAPLs have been identified as the major source of
contamination at the hot spot area.
Alternatives OU1-7, 8 and 9, which include southern
perimeter groundwater extraction and treatment in addition
to hot spot groundwater extraction and treatment, may not
provide significant additional long-term effectiveness over
the selected remedy, OU1-5, which requires extraction and
treatment of groundwater from only the hot spot area. EPA
believes that the combination of hot spot groundwater
extraction and treatment and capping, provided by OU1-5,
will be sufficient at 1) preventing groundwater that has
conta~inant concentrations exceeding MCLs and non-zero MCLGs
from migrating beyond the compliance boundary or, in the
absence of MCLs or non-zero MCLGs, prevent groundwater that
has contaminant concentrations above levels that are
protective of human health from migrating beyond the
compliance boundary and; 2) preventing the degradation of
surface waters below surface water standards. The reason
for this is 1) hot spot groundwater extraction and treatment
should prevent the continued migration of high levels of
contamination currently existing at the hot spot; and 2) the
additional capping component should minimize infiltration of
precipitation into the landfill thereby effectively
minimizing any future migration of contaminated groundwater
caused by the existing 121 acre Phase I area. Alternative
OU1-5 also provides sufficient long-term effectiveness since
it contains groundwater close to what is believed to be the
major source of groundwater contamination at the Site.
Those treatment technologies that remove contaminants from
the hot spot area provide the greatest reduction in volume
and toxicity of contaminants. Alternative OUl-6 does not
include treatment of the hot spot area and therefore
-------
provides the least reduction in volume and toxicity of
contaminants. Alternatives OUl-8 and 9, which involve
treatment of the hot spot chemical sludges, and extraction
and treatment of groundwater from both the hot spot area and
landfill "perimeter, provides the greatest reduction in
volume and toxicity of Site contamination. However, as
noted above, treatment of the chemical sludges does not
address the major problem, DNAPLs in the fractured bedrock
underlying the hot spot area.
Alternatives OUl-7, 8 and 9 require groundwater extraction
and treatment from both the hot spot area and the southern
perimeter of the landfill. Alternatives OUI-7, 8 and 9 may
provide a slightly greater reduction in the volume and
mobility of Site contaminants than alternative OUI-5, which
involves the extraction of groundwater at just the hot spot
area; however, as noted above, the southern perimeter
collection and treatment system may not provide any
significant additional long-term effectiveness.
Alternatives OUl-a and 9 will result in the greatest short-
term risk to ~n-site workers and area residents due to
potential exposures to released contaminants during the
treatment of the hot spot chemical sludges. Alternatives
OUI-6, 7, 8 and 9, which include extraction and treatment of
large volumes of groundwater from the southern, downgradient
perimeter of the landfill may result in a significant
lowering" of the water table.which could potentially impact
adjacent wetlands. Extraction of large volumes of
groundwater from the southern perimeter of the landfill may
also cause a migration of contaminants from identified off-
site source areas to the Central Landfill Site. Alternative
OUI-2 and OUl-5 which involve extraction and treatment of
groundwater from only the hot spot area should not impact
any wetlands. Therefore, the groundwater containment system
used in alternatives OUI-2 and OUI-5 are slightly more
short-term effective than the other alternatives.
All of the alternatives evaluated are implementable. Cap
construction and groundwater extraction and treatment are
commonly used at landfill sites. Alternatives OUl-8 and 9
which involve the in-situ treatment or excavation of the hot
spot chemical sludges are technically more difficult to
implement than the other alternatives due to the
difficulties encountered with in-situ treatment (OUI-a) of
sludges with very low pneumatic permeabilities, such as the
hot spot chemical sludges, and the difficulties encountered
in excavation of the hot spot chemical sludges (OUI-9) given
the uncertainties in the areal extent of the chemical
sludges and the amount of overburden material which would
have to be excavated.
-------
5.
6.
E. The Selected Remedy Satisfies the Preference for
Treatment which Permanently and significantly Reduces the
Toxicity, Mobility or Volume of the Hazardous Substances as
a Principal Element
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. Because many CERCLA
municipal landfill sites share similar characteristics, they
lend themselves to remediation by similar technologies. EPA
has established a number of expectations as to the types of
technologies that should be considered and alternatives that
should be developed; they are listed in the National
Contingency Plan (40 CFR 300.430(a) (1» and EPA Guidance
Document "Conducting Remedial Investigations/Feasibility
Studies for CERCLA Municipal Landfill sites" EPA/540/P-
91/001. For CERCLA municipal landfill sites, it is expected
that:
1.
The principal threats posed by a site will be treated
wherever practical, such as in the case of remediation
of a hot spot.
2 .
Engineering controls such as containment will be used
for waste that poses a relatively low long-term threat
or where treatment is impractical.
3.
A combination of methods will be used as appropriate to
achieve protection of human health and the environment.
An example of combined methods for municipal landfill
sites would be treatment of hot spot in conjunction
with containment (capping) of the landfill contents.
4.
Institutional controls such as deed restrictions will
be used to supplement engineering controls, as
appropriate, to prevent exposure to hazardous wastes.
Innovative technologies will be considered when such
technologies offer the potential for superior treatment
performance or lower costs for performance similar to
that of demonstrated technologies.
Groundwater will be returned to beneficial uses
whenever practical, within a reasonable time, given the
particular circumstances of the site.
The source control remedy selected in this operable unit
satisfies the expectations set forth in CERCLA and the NCP
for treatment of CERCLA municipal landfill sites. Potential
exposure to and ingestion of contaminated groundwater is the
principal threat posed by the Site and the hot spot area was
identified during the Remedial Investigation as the major
source of groundwater contamination at the Site. The
-------
selected remedy is a containment remedy. A component of the
selected remedy requires treatment of the hot spot area by
extracting and treating the highly contaminated groundwater
in this area using a.UV/Chemical Oxidation System. The
UV/Che~ical Oxidation System (an innovative technology) ,
uses a chemical reaction to convert the hazardous organic
contaminants to non-hazardous or less hazardous compounds.
Therefore, the hot spot groundwater extraction and treatment
component of the remedy, which addresses the principal
threat posed by the Site, satisfies the preference for
treatment which permanently and significantly reduces the
toxicity, mobility and volume of hazardous substances. OU2
will address off-site groundwater contamination.
The selected remedy also includes capping the 121 acre
landfill rather than excavating and treating the waste
material and institutional controls. The large volume and
heterogeneity of waste at the Site makes treatment
impracticable. Excavation and treatment of such a large
landfill would also involve unacceptable risk and would not
be cost effective.
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred aiternative) for
remediation of the Site in February 1994. As described in
the Proposed Plan (and previously in section X of this ROD),
the source control portion of the preferred alternative
includes, among other things, constructing a multi-layer
RCRA C cap over the existing 121 acre Phase I area and
incorporating the existing 32 acres of RIDEM approved cap on
the side slopes.
The Proposed Plan reflects the five (5) year design and
construction schedule, ~p.~inning at desigr c~'-ovided
in the Feasibility Study ~~;ort. This ROC ~ - ~larifies
the remedial steps to be taken in the event filling
activities in the Phase II and III areas which overlap
approximately 48.4 acres of the western slope and top of
Phase I area result in extending the design and construction
schedule beyond the five (5) year estimate. Should the
Phase II and III filling activities result in such a delay,
a impermeable barrier will be designed and installed to
prevent or minimize the infiltration of precipitation and
leachate through the uncapped areas of the Phase I area.
Once Phases II and III filling activities are completed, a
RCRA C cap will cover that portion of the Phase II and III
areas that overlie the Phase I area as originally planned.
-------
XIII.
As previously stated in Section X of this ROD, the design
for the impermeable barrier will be included in the design
documents for the remedy. These design documents for the
imperme~ble barrier will be included in the Administrative
Record for this Site.
In the Proposed Plan it was stated that to monitor
groundwater containment performance, hydraulic flow data and
groundwater contaminant concentration data will be collected
and carefully analyzed to determine whether or not the
remedy is containing groundwater above MCLs and non-zero
MCLGs at the compliance boundary. This ROD includes two
additional containment performance criteria 1) in the
absence of MCLs or non-zero MCLGs for contaminants of
concern, prevent groundwater that has contaminant
concentrations above levels that are protective of human
health (refer to Table 16, Appendix B of this ROD) from
migrating beyond the compliance boundary and; 2) prevent the
degradation of surface waters below surface water standards.
STATE ROLE
The Rhode Island Department of Environmental Management has
reviewed the various alternatives and has indicated its
support for the selected remedy. The State has also
reviewed the Remedial Investigation, Risk Assessment and
Feasibility Study to determine if the selected remedy is in
compliance with applicable or relevant and appropriate State
Environmental laws and regulations. The state of Rhode.
Island concurs with the selected remedy for the Central
Landfill Superfund Site. A copy of the declaration of
concurrence is attached as Appendix C.
-------
APPENDIX A
RECORD OF DECISION
CENTRAL LANDFILL SUPERFUND SITE
LIST OF FIGURES
FIGURE 1
SITE AREA MAP
fIGURE 2
SCHEMATIC ALTERNATIVE OU1-1
FIGURE 3
SCHEMATIC ALTERNATIVE OUl-2
FIGURE 4
RIDEM SINGLE-BARRIER CAP DESIGN
FIGURE 5
FLOW DIAGRAM, HOT SPOT GROUNDWATER TREATMENT
SYSTEM
FIGURE 6
SCHEMATIC ALTERNATIVE OUl-3
FIGURE 7
SCHEMATIC ALTERNATIVE OUl-4
FIGURE 8
SCHEMATIC ALTERNATIVE OUl-5
FIGURE 9"
RCRA C MULTI LAYER CAP CROSS-SECTION
FIGURE 10 SCHEMATIC ALTERNATIVE OUl-6
FIGURE 11 SCHEMATIC ALTERNATIVE OUl-7
FIGURE 12 SCHEMATIC ALTERNATIVE OUl-8
-------
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FIGURE 1:
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CENTRAL lANDFilL SITE AREA MAP - JOHNSTON, ntlODE ISLAND
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EXTRACTED
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FIGURES: FLOW DIAGRAM, HOT SPOT GROUNDWATER TREATMENT SYSTEM
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FIGURE 9:
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-------
TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE 6
TABLE 7
TABLE 8
TABLE 9
TABLE 10
TABLE 11
TABLE 12
TABLE 13
, TABLE 14
APPENDIX B
RECORD OF DECISION
CENTRAL LANDFILL SUPERFUND SITE
LIST OF TABLES
GROUNDWATER RESULTS FOR VOCS
GROUNDWATER RESULTS FOR SVOCS
GROUNDWATER RESULTS FOR PESTICIDES/PCBS AND
HERBICIDES
GROUNDWATER RESULTS FOR TOTAL AND DISOLVED METALS
QROUNDWATER RESULTS FOR WQPS AND PETROLEUM
HYDROCARBONS
SUMMARY OF CARCINIGENIC AND NON-CARCINIGENIC RISKS
FOR THE CONTAMINANTS OF CONCERN
ARARS GROUNDWATER PROTECTION - FEDERAL
ARARS GROUNDWATER PROTECTION - STATE
ARARS SURFACE WATER BODY PROTECTION - FEDERAL
ARARS SURFACE WATER BODY PROTECTION - STATE
ARARS AIR QUALITY PROTECTION - FEDERAL
ARARS AIR QUALITY PROTECTION - STATE
ARARS HAZARDOUS WASTE - FEDERAL
ARARS HAZARDOUS WASTE - STATE
TABLE 14A ARARS FOR COMPLIANCE
DRINKING WATER STANDARDS AND HEALTH ADVISORIES
TABLE 15
TABLE 16
RISK BASED PERFORMANCE STANDARDS FOR'GROUNDWATER
-------
TABLE l
Groundwater Results for VOCs
ConcentratIon (ue/l)
Range of Oetected Values A ri thmet i c'
Corrcound Name Frea Minirrun Max imun Location of Max. Mean
HSL VOCs - RIIFS I
1.1. 1-Yrichloroethane 212' 12.00 250_00 J MIoIJ 25.20
1.1-0ichloroethane '12' 1.00 J 620.00 J MIoIJ 22.43
1.1-0ichloroethene 212' 1.00 J 3.00 J IIE871B 22.03
1.2-0ichloroethane 112' 2.00 J 2.00 J IIE871S 22.05
1.2-0ichloroethene 312' '.00 J 760.00 J MIoIJ 2'.50
Methyl ethyl ketone 1/23 29.00 JB 29.00 JB IIE87HL3E 152_28
l.-Methyl-2-Pentanone 2/2' 10.00 690.00 J MIoIJ 52.13
Benzene 5124 10.00 7'.00 IIE872B 27.56
Bromoform 1/2' 2.00 J 2.00 J IIE87Hl20 22.05
Carbon disulfide 7/2' 1.00 J 39.00 IIE871. 23.86
Chlorobenzene 812' 2.00 J 67000.00 HIoIJ 1666- 10
Chloroethane 3/2' 8.00 J 100.00 J IIE872B 46.51
Chloroform 3/2' 1.00 J 2.00 J IoIE87HL5B 21.94
Ethylbenzene 612' 1.00 J 760.00 J HIoIJ 81.82
Hethylene Chloride 3/24 1. 00 JS 37_00 IIE872S 46.83
Tetrac~loroethene 2/2' 1.00 J 110_00 J MIIJ 21.09
Toluene 712' 0.90 JB 9700.00 HIoIJ 309.'2
Tric:hloroethene 4124 1.00 J 2.00 J IIE871S 21. 96
Vinyl ac:etau 1/2' 180.00 180.00 IIE872S 48.77
Vinyl chloride 312' 2.00 J 920.00 J HIoIJ 30.99
Xvlenes 3/24 7.00 1400.00 IIE8729 106.65
EPA METHOD 8010/8020 VOCs - RifFS t
1.1. 1-Yrichloroethane '/53 1.00 J 500.00 J MIoIJ 9.48
1.1-0ichloroethane 5/53 1.00 J 510.00 J HIoIJ 10.98
1.1'Oichloroethene 1/53 '.00 '.00 IIE871S ~51
1.2-0ichloroethane 2153 3.00 26.00 J HIoIJ 1,.19
1,2-0ichloropropane 1/53 1.00 J 1.00 J IoIE871B 0.78
'-Hethyl-2-Pentanone 1/5 82.00 82.00 IIE873A (, 2.l. 0
Acetone 215 20.00 290.00 M\/E 87.00
Benzene 11/53 1.00 J 70.00 MIoIJ 4.11.
Chlorobenzene 17/51 6.00 J 27000.00 J MIIJ 530.26
Chloroethane 7/53 1.00 J 39.00 IoIE 873 B 2.38
Chlorofor,,! 1/52 H.OO J '7.00 J MIIJ 21.35
Chloromethane 1/53 9.00 J 9.00 J IIE8719 0.85
Oibromoc:hloromethane 2/53 1.00 7.00 J HIoIJ 0.91
Oichlorobenzenes 8/'2 10.00 22000_00 J HIoIJ 369.19
Ethylbenzene 8/53 0.50 U 7'0.00 HIoIJ 19.22
Tetrachloroethene 1/50 2.30 J 38.00 J MWJ 3.01.
Toluene 5/35 10.00 7200.00 MIIJ 138.85
trans-1.2-0ichloroethene 9/53 1.00 J 620.00 J MWJ 13.1.7
Tric:hloroethene 211.0 16.00 J 470.00 J IoIE8712 1'.65
Trichlorofluoromethane '/53 0.50 UJ '3.00 J M\/J 1.57
Vinyl chloride 1/53 310.00 J 380.00 J MIoIJ 8.14
-------
l'AELE 1 (can tIc..)
Groundwater Results for vacs
Concentration (ug/l)
Range of Detected Values Arithmetic
C~und Name Free Minimun "'a,,;mun location of Ma". Mean
CLP vacs - RIIFS II
1,1, 1-Trichloroethane 3/54 7.00 2100.00 M\.I9026A 107.91
1,1-0ichloroethane 3/54 28.00 520_00 HII9026A 55.47
1,2-0ichloroethene {,/54 3{,.00 2800.00 H\.I9026A 135.26
Methyl ethyl ketone 5/40 6000.00 J {,6000.00 J H\.I9027AII 3018.38
4-Methyl-2-Pentanone 3/54 960.00 J 4300.00 H\.I9024811 172.69
Acetone 13/54 10.00 8 8800.00 J M\.I9026A 550.74
8enzene 11/54 3.00 J 130.00 J M\.I9026A 46.56
Chlorobenzene 18/54 8.00 3{,000.00 HIIJ 901.28
Chloroethane 3/54 5.00 J 18.00 J liE 87' 91.92
Chloroform 1/54 230.00 J 230.00 J M\.I9026A 47.27
Ethylbenzene 8/54 15.00 2700.00 MII9026A 193.70
Methylene Chloride 10/54 3.00 J 940.00 J HIIJ 54.41
Styrene 1/54 160.00 J 160.00 J MII9026A 46.44
Toluene 14/54 3.00 J 21000.00 MII9025AII 900.22
TriChloroethene 1/54 120.00 120.00 IIE8712 47.50
Vinyl chloride 2/54 1000.00 J 1800.00 J HII9027AII 122.13
Xylenes 10/5' 3.00 J 7000.00 M\.I9026A 445.36
-------
TABLE 2
Range of Detected Values Arithmetic
C oneound Name Frea Hininun Haxinun Location of Hax. Hean
HSL SVOCs - RI/FS I
1,2,I.-Trichlorobenzene 1127 25.00 J 25.00 J HWJ 13.'3
1,2-0ichlorobenzene 5127 13.00 J 3500.00 E HWJ 97.37
1,3-0ichlorobenzene 2/27 19.00 J 120.00 HWJ 15.89
'.I.'Oichlorobenzene 5127 '.00 J 1000.00 HWJ 3'.57
2,I.,6.Trichlorophenol 1/20 27.00 27.00 WE872A 17.35
2,I..oichlorophenol 2/20 10.00 J 27.00 wE872A 17.'3
2.I.-Oimethylphenol 2120 " .00 J . 27.00 wE872A 16.92
2'Chlorophenol 2/20 33.00 220.00 J HWJ 21.'0
2'Hethylnaphthalene 2/27 5.00 J 10.00 OJ HWJ 11.85
2-Hethyl phenol 1120 21.00 J 21. 00 J HWJ 15.77
I.'Chloroaniline 1127 3.00 J 3.00 J WE871B 53.63
I.'Hethyl phenol 1120 170.00 280.00 J HWJ 15.33
Anthracene 1127 19.00 J 19.00 J WE872A 13.85
Benzoic acid 2/27 26.00 J 730.00 HWJ '9.'8
Benzyl alcohol 1/27 9600.00 9600.00 HWJ 125.68
B i s<2'chl oro iso- 1120 57.00 J 57.00 J WE872A 9.85
propyl)ether
Bis(2'ethylhexyl) 1./21. 2.00 JB 31..00 DJ WE8719 15.25
phthalate
Oi-n'butyl phthalate 11./27 12.00 B 89.00 wE87HL2D 32.59
Oiethyl phthalate 3127 5.00 J 19.00 J WE872A 13.89
Fluorene 1/27 3.00 J 3.00 J HWJ 13.31
I sophorone 1/27 170.00 J 170.00 J HWJ 9.26
N-Nitrosod;phenylamines 1127 '.00 OJ 1,.00 OJ WE8719 '6.1.1.
Naphthalene 6/27 '.00 J 100.00 HWJ ".73
Phenanthrene 1/27 3.00 J 3.00 J HWJ 13.31
Phenol 1/20 120.00 120.00 MWJ 106,67
CLP SVOCs - RI/FS II
',2,I.'Tr;chlorobenzene 2/53 1,9.00 J 58.00 J MIo/9026A ".56
1,2'Oichlorobenzene 10/53 3.00 J 25000.00 HWJ 735.01
1.3-Dichlorobenzene 2/53 5.00 J 57.00 J H\I9026A 11.77
',I,-Dichlorobenzene "/53 2.00 J 820.00 J HWJ 31.95
2,I.-Dichlorophenol 1/1,0 '3.00 J 1,3.00 J HWJ 11. . 6'
2.I,-Dimethylphenol 1/1,0 38.00 J 38.00 J HW9027AII 13.89
2-Chlorophenol 2/1,0 1,0.00 J 58.00 HIlJ '5.39
2'Hethylnaphthalene '/53 3.00 J '8.00 J Hw9021,B 10.'9
2-Methyl phenol 1/'0 '9.00 J '9.00 J H\I9025AW 12.91
3,3'-Oichlorobenzidene 1/53 120.00 J 120.00 J Hw9026A 22.10
I,'Chloro'3-methylphenol 1/39 32.00 J 32.00 J Hw9027AII 13.68
I,-Hethyl phenol 6/1,0 6.00 J 660.00 HII9027AIo/ 36.90
Benzoic acid 3/'0 130.00 J 780.00 Hw9027AII 78.19
Bis(2'ethylhexyl) 22/53 12.00 B 670.00 a Hw9027AW 51.82
phthalate
Oi-n-butyl phthalate 10/53 3.00 J '2.00 J HII9027AIl 11.99
Oi-n-octyl phthalate 12153 1.00 J '3.00 J HIo/9026A 11.70
Isophorone 2153 57.00 J 130.00 H\I9027AII 12.27
Naphthalene 12/53 1,.00 J 57.00 J HII9027AIo/ 9.19
Pentachlorophenol 1/'0 60.00 J 60.00 J H\JB1 69.31
Phenol 5/1,0 35.00 J 120.00 H\I9027AII 17.81
Groundwater Results for svecs
-------
TABLE 3
Groundwater Results ~or Pesticides/PCBs and Herbicides
Concentration (ug/l)
CO/I'C)Ound Name
Frea
Range of Detected Values
Minimum Maximum
Location of Max.
Arithmetic
Mean
HSL PESTICIDES/PCBs' Rl/FS I
I.,I.'-DDT 2/26 0.01 0.11 UE872B
PCB 121.8 1/27 0.98 0.98 UE8719
PCB 1260 1/27 0.37 0.37 UE8719
CLP PESTICIDES/PCBs - Rl/FS II
1.,1.'-000 1/53 0.12 X 0.12 X MUB1
1.,1.' -OOT 2/53 0.01. J 0.37 X UE87ML2C
alplla-BHC 1/53 0.02 J 0.02 J UE87ML2B
Dieldrin 2/53 0.02 J 0.06 J UE87ML1B
Enclrin 1/53 0.02 J 0.02 J MIoI9028A
91111111-BHC 1/51 1. 10 JX 1. 10 JX 1'110190264
HeDtachlor 1/52 0.03 J 0.03 J MUD
HERB I C IDES - RI/FS I
2,I.,5-T 4/27 . <0.05 1.50 MUJ
2.I.,5-TP (Silvex) 5/27 0.09 2.1.0 MUJ
2,1.-0 16/27 <0.05 17.00 MIIJ
HERBICIDES - RI/FS II
NONE DETECTEO
0.08
0.1.0
0.71.
0.63
0.63
0.31
0.63
0.63
0.30
0.32
0.06
0.17
1.37
-------
TABLE 4
Range of Detected Values Arithmetic
Concound Name FreQ Minimum Ma~imum Location of Ma~. Mean
HSL Total Metals . RI/FS (
AIUTIinUTI (AI) 4/26 0.28 11.00 WE874 1.03
Antimony (Sb) 1/26 4.13 4.13 WE871B 0.25
Arsenic (As) 2/26 0.03 0.10 WE872B 0.01
BariUTI (8a) 3/25 0.50 2.51 WE8719 0.37
8eryll iUTI (Be) 11/26 0.007 0.02 wE87HL1D/WE87HL5C 0.01
CaaniUTI (Cd) 1/6 0.05 0.05 WE872A 0.01
CalciUTI (Ca) 4/26 4.12 229.00 WE8718 21.20
ChromiUTI (Cn 8/26 0.05 0.33 J WE871B 0.05
Cobalt (Co) 1/26 0.05 0.05 WE8719 0.03
Copper (Cu) 3/26 0.05 0.19 J WE8718 0.02
Iron (Fe) 3/25 16.20 47.20 WE872B 6.06
Lead (Pb) 4/26 0.05 J 0.33 WE8719 0.0'
MagnesiUTI (Mg) 25/26 0.15 "8.00 WE8718 19.82
,Manganese (Mn) 20/26 0.15 170.00 WE872B 22.82
Nickel (Ni) 5/26 0.06 0.35 WE871B 0.06
PotassiUTI (IC) 26/26 0.70 354.00 WE8719 21.'2
SodiUTI (Na) 26/26 3.00 1090.00 WE8719 159.87
Total Sol ids 26/26 16.00 8090.00 WE872B 1172.42
Total Suspended Solids (TSS) 22/26 0.50 '050.00 IIE8719 319.63
ThalliUTI (Tl) 1/26 0.32 0.32 IIE871B 0.2'
VanadiUTI (V) 4/26 0.29 0.52 WE8728 0.07
Zinc (Zn) 517 0.05 10.00 IIE8718 1.64
Non'HSL Total Metals' RI/FS I
Antimony (Sb) 4/27 2.10 4.00 MII8 0.'8
Arsenic (As) 6/27 0.01 0.03 liE 8738 0.01
BariUTI (8a) 2/27 0.50 0.55 J MIIC 0..33
8eryll;UTI (8e) 9/27 0.01 0.01 MIII/HIIO/IIE856A/ ~OO'
IIE85M1/WE8715/IIE8719
CaciniU11 (Cd) 8/23 0.01 0.06 WE85M' 0.01
ChromiUTI (Cr) 7/25 0.05 0.37 WE8715 0.07
Copper (Cu) 21/27 0.02 0.50 IIE8719 0.06
Iron (Fe) 1./27 18.00 60.70 IIE8715 19.02
Lead (Pb) 13/27 0.05 1.95 J IIE8719 0.13
Nickel (N;) 13/27 0.04 0.59 IIE8719 0.09
Total Sol ids 27/27 103.00 8930.00 IIE873A 2077 .00
Total Suspended Solids(TSS) 27127 33.30 4890.00 IIE8719 806.21
ThaI I I UTI (Tl) 5/27 0.12 0.27 MWB 0.22
VanadiUTI (V) 6/27 0.21 0.67 IIE873A 0.10
Zinc (Zn) 11/22 0.01. 2.51 MIIC 1.02
CLP Total Metals . RI/FS "
AIUTIinUTI (AI) '9/53 0.047 J 77.500 J M\I9026A 7.'52
Antimony (Sb) 1/53 0.048 B 0.048 8 M\I9027AII 0.022
Arsenic (As) 9/53 0 . 006 J 0.813 M\l902'8W 0.029
BariUTI (Ba) 37153 0.014 8 2.590 M\I9026A 0.22'
BerylliUTI (Be) 26/53 0.003 J 0.067 J M\I90248W 0.011
CaaniUTI (Cd) 8/53 0.005 J 0.048 J M\I9026A 0.005
CalciUTI (Ca) 53/53 0.103 2'7.00 IIE871B 16.293
ChromiUTI {Cr) '2/53 0.008 J 0.237 M\I9025AW 0.035
Cobalt (CO) 7153 0.022 8 0.073 M\I9026A 0.010
Copper (Cu) 20/53 0.017 8 1.880 M\I9026A 0.136
Cyanide (CN) 12/53 0.011 0.508 IIE8568 0.025
Iron (Fe) 53/53 0.122 J 297.000 J M\I902'B 11.937
Lead (Pb) 33/52 0.002 8 1. 000 J M\I9025AII 0.057
Magnesil.l1l (M9) '3/53 0.106 88.500 MIIBI 8.023
Manganese (Mn) 52/53 0.022 J 17'.000 J IIE871B 3.t.65
Mercury (Hg) 28/53 0.00021 0.00' M\I9026A 0.0004
Nickel (Ni) 21/53 0.02' B. 0.660 J M\I9026A 0.064
PotassiUTI (IC) '8/53 0.102 J '6.000 J MIIC 3.919
Selenil.l1l (Se) 2/35 0.007 0.057 M\I902'BII 0.012
Silver (Ag) 3/53 0.009 8 0.03' J, IIE8718 0.005
Sodil.l1l (Na) 53/53 0.156 97.500 MIlO 10.837
VanadiUTI (V) 6/53 0.026 8 0.267 M\l9026A 0.018
Zinc (Zn) 52/53 0.015 J 12.400 J M\I9026A 0.725
Groundwater Results for Total and Dissolved Metals
-------
TABLE 4
(cont'd.)
Range of Detected Values Arithmetic
C Oll'Oound Name FreQ Minimun Maximun Location of Max. Mean
HSL Dissolved Metals - RIIFS I
Arsenic (As) 212 0.20 0.20 IJE872A 0.20
Sariun (Sa) 213 0.27 1.91 IJEB719 0.81
Beryl I iun (Be) 719 0.01 0.03 IJEB71B 0.01
Caaniun (Cd) 11' 0.02 0.02 IJEB71B 0.01
Chromiun (Cn 21' 0.06 0.06 IJEB72A 0.0'
Copper (Cu) 2/3 0.02 0.25 IJEB719 0.09
lead (Pb) 11' O.OB 0.08 IJE871S 0.0'
Nickel (Ni) "5 0.19 0.25 IJE871B 0.18
Vanadiun (Vn) '" 0.32 0.71 IJE872B 0.'6
Zinc (Zn) 18/26 0.01 13.10 IJE871B 0.55
Non'HSl Oissolved Metals - RIIFS r
Antimony (Sn) 2/7 0.01 3.50 MIIB1 0.56
Arsenic (As) 2/3 0.01 0.01 IJE873A 0.01
BariL611 (Ba) "7 0.53 0.71 M\JD 0.53
BerylliUn (Be) 1/9 0.007 0.007 IJE85M1 0.003
Chromiun (Cr) '110 0.05 0.13 IJE873A 0.05
Lead (Pb) 2/13 0.06 0.11. IJE8717 0.0'
Nickel (Ni) 9/11 0,0' 0.29 WE873A 0.10
Vanadiun (Vn) 617 0.23 0.81 WE873B 0.43
Zinc (Zn) 26/26 0.02 2.24 M\lC 0.58
ClP Dissolved Metals . RIIFS "
Aluninun (AI) 27/53 0.0'7 S 7.300 J "1\190 27AII 0.233
Arsenic (As) 8/13 0.013 J 0.151 M\l902'BIJ 0.027
Bariun (Ba) 39/53 0.001 B 0.839 M\lB 0.089
Beryll iun (Be) 21/53 0.002 B 0.0388J WE87Ml1E 0.007
CaaniL611 (Cd) 12/53 0.005 0.012 J MIIP 0 :\)04
Calciun (C.) 53/53 0.105 78.400 M\l902'BIJ 19.397
Chromiun (Cr) 18/53 0.007 J 0.124 J IJE87Ml4A 0.01'
Cobalt (CO) "53 0.01' S 0.036 a M\I8, 0.008
Copper (Cu) 1/53 0.03' 0.034 IJE87', 0.009
Iron (Fe) 44/53 0.028 J 62.600 IJE874 5.102
lead (Pb) "4' 0.002 J 0.029 J IJE87Ml3E 0.007
Magnesiun (Mg) 4"53 O. '30 87.500 M\I9026A 10.951
Manganese ("In) 50/53 0.013 B 33.500 IJES7' 2.869
Mercury (Hg) 1/37 0.0002 0.0002 IJE855 0.0001
Nickel (Ni) 11/53 0.025 J 0.2B9 J M\l9027AII 0.034
Porassiun (10 '21'5 0.1'3 J 88.000 J MIIC 10.700
Silver (Ag) 6/39 0.009 J 0.0'0 IJEB71B 0.006
Sodiun (Na) 53/53 0.125 98.500 "110'0 11.027
Zinc (Zn) '0/53 0.015 B8J 7.7B08J \JE871S 0.256
Groundwater Results for Total and Diss~lved Metals
-------
TABLE 5
Croundwater Results for ~OPs and Petroleum Hydrocarbons
Concentration (mg/l)
Co~ound I/ame
Freq
Range of Oetected Values
Minimum Maximum
Location of Max.
Ari tllmetic
Mean
~OPs - RIIFS I
Anmonia (N) 51/52 0.01 1200.00 IIE873A
Chemical Oxygen Demand (COO) 33/50 4.00 3580.00 IIE873A
Chloride (CI) 51/52 2.00 1800.00 IIE873A
Nitrate (N) 37/52 0.01 4.93 IIE855
Nitrite (N) 6/52 0.01 0.09 IIE87Hl3E
Sulfate (S()i.) 32152 4.00 275.00 IIE871 B
Total Organic Carbon (TOC) 31/52 5.00 575.00 ~E873A
IIOPs - RIIFS II
Anmonia (1/) 47/53 0.10 2{,{'0.00 MII9027AW
Biological Oxygen Demand 8/9 4.40 570.00 MII9027AII
Chemical Oxygen Demand (COO) 27/53 (,.oo 2220.00 M\I9027AII
Ch lori de (CI) 53/53 0.50 1790.00 MW9027AII
Col i form, total (coI1100ml) 25/53 3.00 1600.00 MW9026A
Nitrate (N) 27/53 0.01 J 1.83 IIE855
Nitrite (N) 17/53 0.01 O.O{, IIE87{,
Toul Sol ids 53/53 (,8.80 15600.00 MII9032
Total Suspended Solids (TSS) 43/53 0.60 16700.00 J M\I9032
SuI fate (SOl.) 20/53 5.00 750.00 J IIE871B
Total Organic Carbon (TOC) 50/53 5.00 J 580.00 J MII9027AII
Petroleum Hvdrocarbons - RIIFS II
Total Petroleum Hydrocarbons 819 1.00 80.50 "W902{,BII
70.77
291.3{,
262.07
0.32
0.01
14.31
68.97
132.66
183.32
207.88
197.40
102.38
0.16
0.01
1662.60
1008.07
21..87
92.79
1{,.{,0
-------
TABLE 6
SUMMARY OF CANCER RISKS AND HAZARD INDICES
CENTRAL LANDFILL SITE
RISKS TO RFSlnFNTS
AVERAGE CASE REASONABLE WORST CASE
ME.OJA EFFECTI EFFECT'
CARCINOGENIC NONCARCINOGENIC TARGET ORGAN CARCINOGENIC NONCARCINOGENIC TARGET ORGAN
EXPOSURE PATI-iWAY RECEPTOR RISK HAZARD WITH INDEX RISK HAZARD WITH INDEX
INDEX EXCEEDING 1.0 INDEX EXCEEDING 1.0
Groundwater
Ingestion Adul~ 7.9E-04 93 CNS.91 1.4E.03 731 CNS.726
Sk.n.2.7
L'lIer.1.2
None. 1 2
Children 3.7E-04 218 CNS.213 6.8E-04 1707 CNS.1693
Skln.I.9 Sk.n.6.2
Llller.I.6 None. 2.9
Liller.2.8
Body WI. 1.2
Dermal Contact Adul~ 1.2E-Q6 0.14 2.2E.Q6 1.1 CNS.1 I
Children 4.4E-07 0.26 S.2E-07 2 CNS.2.0
Inhalation Adul~ 2.4E-07 0.057 5.8E-07 0.093
:
Children 2.2E-07 0.27 5.4E-07 0.43 ,
SubtctaJ. Adul~ 7.9E-04 93.2 1.4E.03 732
Children 3.7E.04 219 6.8E-04 1709
Surface Water METHOD I METHOD 2 I
UODM Simmon~ I
Ingestion Adul~ lolE.07 0.00060 2.4E.OS 0.0027
.
Children 3.SE-07 0.0049 7.8E.OS 0.022 I
Dermal Contac:1 Adul~ 3.5E-oa 0.0001a 7.3E.09 0.00083
Children S.2E-OS 0.0011 1.7E.OS 0.0049
Subtctal . Adults 1.6E-07 0.00078 3.1E.Oa 0.0035
Children 4.6E-07 0.0060 9.SE-OS 0.027
AII"I"Y R9~rvDir MFTHOD ,
Ingestion Adults 6.5E-09 0.000053
Children 2.6E-OS 0.00044
Derm aJ ConlaCt Adulll 2.0E.Q9 0.000012
Children 4.6E-og 0.000072
SubllltaJ . Adulll S.5E.Q9 0.000065
-------
TABLE 7
ARARs
GROUNDWATER PROTECTION - FEDERAL
',,':'Y:""..".
, ),';:,:':"""'.'"
,.
Action
Specific
1
Action
Specific
2
Safe Drinking Water Act, Maximum
Contaminant Levels (MCLs), 40
CFR, Part 141.
Relevant
&
Appropriate
Resource Conservation and Recovery
Act - Releases from Solid Waste.
Management Unlls, 40 CFR, Part 264,
Subpart F
Applicable
MCLs have been promulgated for a MCLs are not used as groundwater
number of organic and Inorganic cleanup levels; rather, they are used to
contaminants. These levels regulate measure performance of groundwater
the concentration of contaminants In containment alternatives. These
drinking water supplies. MCLs are alternatives are expected to contain
considered rolevant and appropriate groundwater exceeding MCLs within the
for groundwater because It Is compliance boundary.
federally classified as a potential
drinking water source.
Establishes requirements for solid Because this Is a source control remedy.
waste management units (SWMUs) groundwater cleanup will not be
at RCRA regulated sites. addressed and cleanup goal5 are not
Regulations Include; groundwater set; however, alternatives which Includo
protection standard requirements for a groundwater containment component I
groundwater monllorlng, detection will comply with tho portions 01 the I
monitoring and compliance. regulations which apply to Inslalilng ~.
monitoring and the corrective action groundwater monitoring. wells and :
-------
TABLE 7 (cont'd.)
ARARs
GROUNDWATER PROTECTION - FEDERAL
Action Safe Drinking Water Act; Maximum Relevant Non-enforceable health goals for MCLGs are not usod as groundwater
Specific Contaminant Level Goals, (MCLGs) 40 & public water systems. The USEPA cleanup levels; rather, they are used to
3 CFR, Part 141. Appropriate has promulgated non-zero MCLGs measure performance of groundwater
for specific contaminants. containment alternatlvos. The
alternatives are expected to contain
groundwater exceeding non-zero
MCLGs within the compliance boundary.
Action RCRA-Crlterla for Municipal Solid Relevant Establishes groundwater monitoring Because this Is a source control remedy,
Specific Waste Landfills, 40 CFR, Part 258, & requirements for municipal solid groundwater will not be addressed and
4 Subpart E. . Appropriate waste landfills. groundwater cleanup goals are not set,
however, alternatives which Include a
groundwater containment component
will comply with the groundwater
monitoring program requirements of this
subpart.
Chemical USEP A Human Health Assessment TBC CSFs are devoloped by EPA for These valuos present the most up to
Specific Cancer Slope Factors (CSFs) . health effects assessments or date cancor risk potency Information.
5 evaluation by the Human Health CSFs shall be used to compute the
Assessment Group (HHAG). Individual cancer risk resulting from
-------
.. -. . .
TAELE 7 (cont'd)
ARARs
GROUNDWATER PROTECTION - FEDERAL
ChemIcal
Specific
6
Chemical
Specific
7
ChemIcal
SpecUic
8
USEPA Reference Doses (RfDs)
TBC
Safe DrInking Water Act, Maximum
Contaminant levels (MCls), 40 CFR,
Part 141 .
Relevant
&
Appropriate
Safe Drinking Water Act, Maximum
Contaminant level Geals, (MClGs) 4
CFR, Part 141.
Relevant
&
ApproprIate
RfDs are dose levols developod by RIDs are considered the lovals unlikely
EPA for use In the characterization 01 to cause significant health affects
risks duo to non-carcinogens In associated with a threshold mechanism
varIous medIa.. of action In human exposure. . RfDs are
typically employed to characterize risks
of groundwater contaminant exposure
(for Ingestion pathways).
Establishes enforceable standards Groundwater contaminant
for specific contaminants which have concentrations were compared to MCLs
been determIned to adversely affect and were Included as a component 01
human health. These standards are the rIsk assessment.
protective of human health for
Individual chemicals and are.
developed usIng MCls, available
treatment technologies, and cost
data.
MClGs are non-enforceable health Groundwater contaminant
goals. They establish drinking water concentrations were compared 10
quality 90al5 at levels of no known or non-zero MCLGs and wero included as
anticipated health effects with an one component of the risk assessment.
-------
TABLE 8
ARARs .
GROUNDWATER PROTECTION - STATE
';fW,<:tj;1~ -""-~~:~~:::-~_~~1Vi~~!M~;;fI~~~~;
Action
Specific
t
Action
Specific
2
Action
Specific
3
Rhode Island Rules and Regulations
for Groundwater Quality, RIDEM
7/93, Sections 12.02 and 12.03.
Applicable
RI Rules and Regulations for
Groundwater Quality, RIDEM 7/93,
Section 5.06
Applicable
RI Rules and .Regulatlons for
Hazardous Waste Management,
RIDEM 4/92, Section 9.03.
Applicable
Regulations are designed to protect
and restore the quality of the State's
groundwater and Include a
groundwater monitoring program.
Regulations establish methods to
prevent Introducino pollutants Into
groundwater during monitoring well
construction and during monitoring
well and piezometer abandonment.
Regulation outlines operation
requirements for treatment, storage and
disposal faclllUes, Including a
groundwater monitoring program.
Although this Is a source control remedy
which does not address groundwater, some
alternatives have a groundwater
containment component. These
alternatives will comply with these actions
as they apply to a groundwater monitoring
program.
All permanent and non-permanent
monitoring wells (and all piezometers).
when Improper abandonment will result In
reasonable IIkllhood of groundwater
pollution, will meet the substantive
requirements of these regulations.
Although this Is source conlrol remedy
which doesn't address groundwater, some
alternatives have a groundwater
containment component. These
alternatives will comply with this secUon to
the extent It requires Installing groundwater
-------
TABLE 8 (cont'd)
ARARs
GROUNDWATER PROTECTION - STATE
.. <.!.:.::.::.;j1:'.::f::i:;::i::::'~:i~.::)~:~I~I:~:I~li:Wfl:ii~~~~~i~:.II~;~~~]: ;.~I:~i;i~'ji'j.!.i~:i:'li:i:~~:~';!:!.:i:I:!~.::i!I::1;1:.:.1.:1: :ijl:'il:~.jj.:::.I::::II:::.ii.:0,I~~ai~III:~~:;~:~~I~~i'i:::':j.:;.lj..i:iij,!,":iij':i::ji;!. :1..:I::;::1i.~:j.j!'il:'ji::.I~j'::.'i:~~~~"~~~~1h~~~i~j.i/::,::,i: . . :
.. '::.::',", ):::::}~t;~ ....
. ,'." .. .
. '/\TypciN\W/: ',"",',.,"'.
Action RI Rules and Regulations for Solid Applicable Regulations outlines operation Although this Is a source control remedy
Specific Waste Management, RID EM 4/92, requirements for Solid Waste which doesn't address groundwater. Some
4 Soction 7.08 and 1 5.1 1 . Management Facilities, Including a alternatives have a groundwater
groundwater monitoring program. containment component. These
alternatives will comply with these sections
to the extent they require a groundwater
-------
TABLE 9
ARARs
SURFACE WATER BODY PROTECTION - FEDERAL
Action
Specific
1
Action
Specific
2
. Clean Water Act - National Pollutant
Discharge Elimination System
(NPDES) Regulation, 40 CFR Parts
122, 123, and 124 November 16,
1990.
Applicable
Clean Water Act - Federal Ambient
Water Quality Criteria (FAWQC),
40 CFR 122.44.
Relevant
and
Appropriate
Regulates the point source discharge Substantive requirements of the
of water Into public surface waters. regulation will be met by any discharge
to on site surface waters.
Non-enforceable guidance which Is
used by states In conjunction with a
designated use for a stream effluent
to establish water quality standards.
WQC lovels for protection of human
health from consuming aquatic
organisms (plants and fish) and for
protection of aquatic organisms have
been developed for several
contaminants. The standards for
protection of human health from
consuming !ish and tho standards of
protection of aquatic organisms are
relevant and appropriate if there Is no
more stringent state rules for particula
contamination.
Standards for protection of human health
for consumption of fish and standards lor
protection of aquatic organisms for
Which there 15 no more stringent state
standard wllllJo mot for any discharge to
-------
TABLE 9 (cont'd)
ARARs
SURFACE WATER BODY PROTECTION - FEDERAL
. ... ,"." ',.", "',". '.".;.".".'. :;':i.:~::j)':'::.~'.~.:~:j\i~':r!'~':ij'~i&i;11~ljK~i~~~~.~~iij1~~~j~~~' ~~:~li'i:I~:j~~.[1Ijl.';~:~:~;iij~.~\:'1i!!.~;:[(i.j!.:I'r~~:: .:!:~iii~::;~:~::i.;:ii:i[~:~j~~~'~:I~:~:iill~~~~~j.i~!.i1:iil~ii!~!~!,:j:: j~I:'1~.:~j'~jJ':I[;i.i:!.,.~:~~~m:':~it~1R~i~k~:~:"i.'\;.::...;.:;:::
':::\::'::.;'!~'f~~~~':j:::~I':;,;:'".
Location Protection of Wetlands - Executive Applicable Requires federal agencies to avoid Alternatives that Involve alteration 01 a
Specific Order No. 1 1 990, 40 CFR, Part 6 Impacts associated with the wetland or that adversely Impact a
3 destruction or loss of wetlands and to wetland may not be selected unelss a
avoid support of new construction In determination Is made that no
wetlands If a practical alternative practicable alternative exists. If no
oxlsts. practlble alternative oxlsts, potontlal
-, harm must be minimized and action
taken to restore and preserve the natura
-------
TABLE 10
ARARs
SURFACE WATER BODY PROTECTION - STATE
Chemical
Specific
1
Chemical
Specific
2
Chemical
Specific
3
Rhoda Island Water Quality
Standards. RID EM. effective 1/9/85.
amended 10/28/88
Applicable
Incorporates RI Ambient Water
Quality Standards. Classifies water
use and defines water quality goals
to protect public health and welfare,
enhance the quality of state water.
and serve the purpose of the CWA.
Rhode Island Water Quality
Regulations. RIDEM. effective 119/85.
amended. 10/28/88
Applicable
To restore. preserve and enhance
the quality of the waters of the state
and to protect the waters from
pollutants.
Rhode Island Pretreatment
Regulations. RIDEM. Juno 15. 1984.
Applicable
Effluent discharged to surface waters
will meet these standards.
Effluent discharged to surface water will
not degrade high quality surface waters
or further degrade low quality surface
waters.
Covers pollutants In wastewaterS Remedial actions which Includo
which can have detrimental affects discharge to the Cranston.pOTW. will
on POTW processes. Sets specified meet all discharge limitations Imposed
limitations. pretreatment and by POTWs.
monitoring requirements for
discharges to POTWs based on
-------
TABLE 10 (cont'd)
ARARs
SURFACE WATER BODY PROTECTION - STATE"
~,: '~j'~-:::it,i!!':i::'l;;:'ij'i::.i.~:i.:i:ij:.~:':"':I:.1.~J:I~~i:'::~i~:~~!:~~il:~~:~.11~\;I.:;;'::I.:~ii:lj~:~I':!
':':':::'.0:,:,;:::,';"'..1
Location
Specific
4
Action
Specific
5
Rules nnd Regulations Governing the
Enforcoment 0' tho Froshwator
Wetlands Act, RIOEM, 8/90
Applicable
Actions required to prevent tho
undeslrealJlo drainage, excavation,
'liling, alteration, encroachment or
any other form of disturbance or
destruction to a wetland.
Rhode Island POES Rogulatlons
(RIPDES). RIDEM, adopted 7/20/84.
amended 2/9/93
Applicable
Rostore, preserve nnd enhance
quality of surface waters and protect
waters 'rom dischargers 0'
pollutants.
Alternatives Involving activitios which
affect wotlands will comply with tho
substantive provisions 0' this regulation.
On-slto discharge to sur'ace water will
meet substantive requirements that are
-------
Action
Speclllc
1
Action
Spcclllc
2
Action
Specific
3
TABLE 11
ARARs
AIR QUALITY PROTECTION - FEDERAL
Resource Conservation and Recovery
Act (RCRA) Interim Status: Thermal
Treatment, 40 CFR, Part 265,
Subpart P
RCRA, Air Emission Standards for
Process Vents, 40 CFR, Part 264,
Subpart AA
RCRA, Air Emission Standards for
Equipment leaks, 40 CFR, Part 264,
Subpart 88
".
.....
Regulations contain requirements for All remedial actions which Involve
air emissions from thermal units. thermal treatment will comply with these
regulations.
Applicable
Standards for air emissions from All remedial alternatives Involving one or
process vents associated with., mora of these technologlos will comply
distillation, fractionation, thin with the substantive portions of this
film evaportlon, column extraction or regulation If the threshold
air steam stripping operations that organic concentration Is mot.
treat RCRA substances and have
total organic concentrations of 10
ppm or oreater.
Applicable
Applicable
Standards for air emissions for
equipment that contains or contacts
RCRA wastes with organic
concentrations of at least 10% by
weight.
All remedial alternatives which Includes
such equipment will comply wilh
substantive portions of this regulation If
Ihe threshold oroanlc concentration Is
-------
TABLE 11 (co nt' d)
ARARs
AIR QUALITY PROTECTION - FEDERAL
1.:!':!"'i.:i4~ .. ,'.' .....,..,. "gi.I,:::~:,'~~;'~'~I:li!'I~~~.I'ijll~f~ltlt~'t1f~i;tfiil'1i~~~I~i !.:~i'I~~~I'~lj~:~'I\.!t~II;:I:~i:ill~!~:.t~::I::.!'.jilll: li!~.~!:~li!~i;~~.i~::~~~~~~~:ml:~;~'::~~~~:~~'~~j:'.!!'.~:Iil:'i!:.il!:!!!: :.i!.~!'~i",:~":::I.;;.~'~\j:"*!'R~~~:!~W~f=rif~~~~~;!"'::":..1;':.!: ' ... .
"
ACtiOn Clean Air Act (CAA) National Relevant Establish emission levols for certain Remedial actions shall attain NESHAP
Specific Emissions Standards for Hazardous And hazardous air pollutants.. emission limits for vinyl chloride Ihat
4 Air Pollutants (NESHAP). 40 CFR Appropriate result from treatment processes.
Part 61 .
Action RCRA, Air Emissions from Treatment, .. TBC Proposed standards for air emissions Proposed standards will be considered
Specific Storage and Disposal Facilities, from treatment, storage and disposal for all remedial alternatives if threshold
5 40 CFR, Part 264, Subpart CC : facilities with VOC concentrations VOC concentrations are met.
(Proposed 56 FR 33490-33598 equal to or greater than 500 ppm.
7/22/91)
Action CAA - Non Methane Organic TBC Regulations will require NMOC Proposed reouiation will be considered
Specific Compounds (NMOC's) specillc gas collection nnd control for NMOC emissions from 1110 landfill.
6 systems, monitoring and oas
May 30, 1991 proposed rule CAA generation estimates. The proposed
Amendments (56 FA 24468-24528.) rule would establish a performance
to 40 CFR Part 60 Subpart WWW) standard for NMOCs emission from
-------
TABLE 11 (cont'd)
ARARs
AIR QUALITY PROTECTION - FEDERAL
Acllon
Specific
7
Action
Specific
8
Conlrol of Air Emissions from
Superfund Air Strippers at Superfund
Groundwaler Sites. OSWER Olr.
9355.0.28, 6/15/89
US EPA Region I Memo, July 12,
1989, Louis GIUo to Merrill Hohman
TBC
Provldos guidance on tho control of Conlrols on air stripper will be usod as
air emissions from air slrlppers used necessary 10 nltaln Fodoral and 81al0
nt Superfund sites for groundwaler ARARs, criteria and guldanco.
Irealment and dlstlnqulshes belween
site located In aUalnment and
non-attainment areas for ozone.
TBG
Slates that superfund air strippers In
ozone non-attainment areas will
generally merit conlrols on all VaG
emlslsons.
Remedial actons Including air strippers
will Include controls to reduce VaG
emissions.
I
-------
TABLE 12
ARARs
AIR QUALITY PROTECTION - STATE
Action
Specific
1
Action
Specific
2
Action
SpecUic
3
Air Pollution Control Regulations, RI
Dept. of Health, Division of Air
Pollution Control, Effective 8/2167
amended 5/20/91 - Regulation
No.1 Visible Emissions
RI Air Pollution Control Regulation No.
5 Fugitive Dust
RI Air Pollution Control Regulation No.
7 Emissions Detrimental to
Persons or Property.
Applicable
No contaminant emissions will be
allowed for periods of more than 3
minutes In anyone hour which 15
greater or equal to 20% opacity.
Applicable
.. ..
..
. ..
...
Air emissions from remedial actions
will meet omission levols In regulations.
Reflects that reasonablo precautions On-slto remedial actions will use oood
be taken to prevent particulate Industrial practices to prevent particulate
matter from becoming airborne. matter from becoming airborne.
Applicable
Prohibits emissions of contaminants
which may be Injurious to human,
plant or animal life or cause damaoe
to propeny or which unreasonably
Intorfers with the enjoyment of life
and propeny.
;
Emissions from technologies undor I
consideration which have the potential 011
emlttlno contaminants (InCiudino '
biological, physical and chemical
treatments and thermal technologies) wll
-------
Action
Specific
4
Action
Specific
5
Action
Specific
6
Action
Specific
7
TABLE 12 (cant I d).
ARARs .
AIR QUALIlY PROTECTION - STATE
RI Air Pollution Control Regulation No.
g - Approval to Construct
Install, Modify or Operate.
RI Air Pollution Control Regulation No.
13 PartIculate Emissions
RI AIr Pollution Control RegulatIon No.
15 Control 0' OrganIc Solvent
EmIssIons
RI AIr PollutIon Control Regulation
No. 17 Odors.
'.:!i':i;"!:':;:I::!ii':\fi':~!~~~i:'!:~~:~i:,I:~~:~~~i!;!I~;i;'!:;'::."!ii:(::i\;i!!!;i':~;'I,!.:i!!j!:':!'::'~:~~~1m"~1flr~~~~:~~~: "
Applicable
Establishes guidelines for the Remedial technologies Involving
construction, Installation, construction, Installation, modification or
modification or operation of potential operation of air emission units will meet
air emission units. Establishes these requirements.
permissible emissIon rates for some
contaminants.
Applicable
Sets emissIon standards for a class
of fossil fuel fired steam or hot water
units. Prohibits use of rotary cup
burners.
Applicable
If carbon adsorption Is choson then
steam Is necessary to regenerate the
carbon beds. Hot water may be required
In other remedial technologies; all will
comply with this regulation.
Limits the amount of organIc solvent Emlslsons of organic solvents will be I
emitted to the atmosphere. controlled to ensure that the standards'
are met.
Applicable
Prohibits the rclase of objectionable Objectionable odors beyond tho facility
-------
"
TABLE 12 (con~'d)
ARARs
AIR QUALrrY PROTECTION - 5T ATE
Action
Specific
8
Action
Specific
9
Action
Specific
10
RI Air Pollution Control Regulation No.
20 Burning of Alternative Fuels.
RI Air Pollutant Control Regulation
No. 22 Air Toxlcs
Rhode Island Guidance for Air
Quality/Air Toxlcs Substances
Applicable
Dellnes standards for alternative fuel Substantive requirements of this
and establishes emission regulation will be met by components of
allowances. action which Involve burning of
alternallve fuel.
This regulation prohibits the emission The ambient air quality levels will be
of specified contaminants at rates met for all technologies which emit air
which would result In ground level contaminants.
concentrations greater than
acceptable ambient levels In the
regulation.
Applicable
TBC
Provides guidelines for models and
modeling procedures.
Guidance will be considered when
modelling emissions from the landfill gas
-------
TABLE 13
ARARs
HAZARDOUS WASTE - FEDERAL
Action
Specific
1
Action
Specific
2
Action
Specific
3
Resource Conservation and Recovery
Act (RCRA) - Identification and Listing
of Hazardous Waste, 40 CFR,
Part 261.
RCRA, Interim Status TSDF,
Standards: Thermal Treatment, 40
CFR. Part 265, Subpart P
RCRA Interim Status TSDF
Standards: Chemical, Physical and
Biological Treatment, 40 CFR, Part
265, Subpart a
Applicable
Defines those solid wastes which are Requirements define RCRA regulated
subject to regulation as hazardous wastes. Acceptable management
wastes under 40 CFR, Parts approaches for listed and characteristic
262-265. hazardous waste will be Incorporated
Into selecting remedial alternatives.
Applicable
General operating, waste analysis,
monitoring/Inspection and closure
requirements for thermal treatment
facilities (other than those using
enclosed devices with controlled
flame combustion).
Applicable
Remedial alternatlvos which Include
on-site thermal treatment will meet
these requirements.
General operating, waste analysis Remedial alternatives which Include
and trial test, Inspection and closure chemical, physical and biological
requirements for facilities which treat treatment will meet these roqulrements.
hazardous waste by chomlcal, .
physical or blolo{]lcal methods In
other than tanks, surface
impoundment: and land treatment
-------
TABLE 13 (cont'd)
ARARs
HAZARDOUS WASTE - FEDERAL
.."'.. ".,".".'.".", ",.,".",,',,".:.',. ::-i';;'i,~:~:,1~ilt:i~:~1!-~I'j;!jlll,r!~~:!~~i\t,I~~~~~'~' ;~t!i;tl~~~li':!i:~;I"!I:!:~il~~~:";:..,:':!,~',1:',:::~i:~~',!!'i '1,,:~jii,:[!I1:'il,;ii'~',I,;~!!~i:~I.~'~:~'~~'~:~~~:~'!;':',':'i,t;]:!!'!':;:!:: ::,!:i!!:ii';!'!i'I~!'!j:i!i!:I':"!'~~~ro,':~Wl~~~~~:~~,;"i',;;:-;",:::'::"::;::,
'!;;:'::::,;:;;¥~6~;t;::ii:::,..ij,
Action Hazardous Waste Management. Applicable Specific requirements for the land Remedial alternatives which include
Speci/ic RCRA, Land Disposal Restrictions disposal of RCRA hazardous waste. excavation and olf-slte disposal of
4 (LOR) 40 CFR. Part 268 Land disposal restrictions set by restricted RCRA waste will comply with
waste type and constituent LOR by meeting treatment standards
concentration or required treatment prior to disposal.
technology.
Action Technical Guidance for Final Covers TBC EPA tcchnlcal ouldance for landfill Cap construction should conform to
Specific on Hazardous Waste Landfills and covers. Presents recommended these standards.
5 Surface Impoundments. tochnlcal specifications for multllayor
EPN530-SW-047 7/89 landfill cover design.
Action RCRA. Closure and Post-Closure. 40 Applicable Details general requirements for Remedial alternatives which Include a
Specific CFR. Part 264. Subpart G. closure and post-closure of RCRA Cap shall be constructed In
6 hazardous waste facilities, Including accordance with these roquirements.
Installation 0' a groundwater
-------
Acllon
Specific
1
Action
Specific
2
Action
Specific
3
TABLE 13 (cont'd)
ARARs
HAZARDOUS WASTE - STATE
:':"i:li:;I,:::';"::':,:',j:;',:;,-:,!j'i:':i:,~::~~:;:'~I:'mll'~!ll:'!II::i:j'~ji~'~i~:;!i:!,';I~,..i;
RI Rules and Regulations for
Hazardous Waste Management,
SecUon 9, RIOEM 4/19/92
Applicable
:':,:,!"i'i:I':'il!l;i::;,:,~;!I:'~I:'~;~~~M:/'~1imo~~~~~;~,,!':!:;:::::
Outlines requirements for general All remedial actions Involving' treatment
waste analyses, security procedures, facilities and treatment processes will
inspections and safety. Sets design, comply with the substantive portions of
construction and operational this Section. Alternatives with double
requirements for containers and barrier caps will comply with closure
tanks, and closure requirements for standards.
hazardous waste facilities.
RI Rules and Regulations for
Hazardous Waste Management,
Section 8, RID EM 4/19/92.
Applicable
Outlines operational requirements for All remedial actions will comply with the
all treatment, storage, and disposal substantive requirements of this section
facilities. for treatment technologlos.
RI Rules and Regulations for
Hazardous Waste Management,
Section 10, R,OEM 4/19/92.
Relevant and
Appropriate
Outlines design, operational and
closure requirements for new
landfills.
Although this section addresses new
landfills, requirements for closure 0' CLF
will be In accordance with these
requirements for alternatives with double
-------
-~_.. .. ..
TABLE 14
ARARs
HAZARDOUS WASTE - STATE
. . ~/:;.:::::::;t:::,i::i: ':::'Ji:":'.!.:.;:!.':;;:::i:!:~]".i~.::!!i;~~:;~;t:~~!III~~!~~:~il.:1:li.~!!!:'~..j'::~i1.I:ii:
.:':::.:'::':::;i:;'!::!!ii:!::~I~!J:~I:!I:~~::~:~J!~~i:!;:!:!!I::'ii:"..:il!:~::"::..'::'!:!:!.I':i;i':.i'!!.!!'..:':.!I:'..'I~I~~!:~Wl~~!~~~~:::'(:
Action
Specific
4
Action
Specillc
5
AI Rules and Regulation for
Hazardous Waste Management,
Section 13, RID EM 4/19/92.
Applicable
Outlines design and operational
requirements for miscellaneous
units.
RI Rules and Regulations for Solid
Waste Management, RIDEM, 4/92,
Sections 9,10, & 13
Applicable
Requires minimal standards for solid
waste Ian dUll capping. SpecUles
type and depth of cap barrier layers
and engineering standards. Includes
measures to protect against odors
and dust.
Remedial alternatives which Include
miscellaneous units will meet the
substantive requirements of this Section.
Remedial alternatives which Include
RID EM Solid Waste caps will comply
-------
Pegelolll
ClF FEASIBILITY STUDY
TABIE 14A
ARAR. FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5, OU1-6, AND OU1-7
:,..:..:..'.:..; . . . ... .. d, 'C'r: . :d::< J1~~~r~~~ntsvnJ~~s:' " . :.' ""'. :Al:iIiii110 bu . ..'
... . .... ::
TvoI/,. .'.. . :.C . d
Medl. . . d . uirinemenis" Slollli!;: 'd ':'Tmiun 10 Ailal" MAns'
Goundwaler Aclion Sale ()niro Weill' Acl, Maximum Relovart MCls heve been pronllAgDlod ler a The combinDlion 01 cepping erd eXlrection and
-Fednl Specific Cortamnant Levels (MCLs), <40 & number 01 erganic and Incrganic teDlmert of 110undwDler ale.hll' Ihe hol spot er
1 CFR.PII'11<41. ApIJ'OlJ'iale cOnleminents. These levels regu!Dle Ihe sOUlhll'n pll'meler of Ihe lendf~1 er el both is
Ihe concenlrelion of corteminarts In expecled 10 contein 11000dwDlII' exceeding MCu
d'irl
-------
P.ge 2 0111
ClF FEASIBILITY STUDY
TABLE 14A (con 't)
ARAR, FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5. OU1-6. AND OU1-7
:::::/'\i::: . ".' . . ... ,..:,,:"'i' A.cllon 10 be.. ...'.
.. .' "'.'..';: ':: ':: ~e~u~iri~ine;115' . . ... '''':';'.':'.
Media'. Two/';" . 6Ialu5" .. . n'Qu'-em.nt 6yriopSl,';':' "'.::'.::':' ":'Taken'lo..Atlaln AAAfIli".. ..'
Qoundwalor Action RenA-Q~lJia fa Municipal Solid Relevant ESlablisms goundwllllJ monitairo Groundwalor COr1ainmer1 ahernBlivas wil inclwe e
-Federal Specific Was,lllldilis. 40 eFA, PErt 258. & requrements la mLflicipal solid goundwBlIJ maniairo lIogram.
4 SWpBrt E. Appop-iata wasla landf~ls.
Groundwater Chemical USEPA Human Health Assessment me eSFs are developed by EPA fa Doth capping am gaundwBlII' containment in
-Federal Spe cilic Car1:1J Slop a facias (eSFs) heahh eflects assassmer1s a conjuncdon with In!it~utiorel conrols wi. reduca the
5 evaluation by the Human Health individual cancer ri~ resul!iro Iram exposlIe 10
Assessment Group (HHAG). contaminns In 1m g ournwalll' as Ider1li ed in
the Ri~ Assossmne\.
.
o.ound_ler Chemical USEPA Relerence 00... (I10sl TBC RIO. are do.. leve'a de""loped by Bolh capping and goundwal... contalnmenlln
-Fed...al Specific EPAlor u..1n the ch...ac;t...lullon 01 conlunc1lon with 1na1ltullonel contola will reduce Ihe
e rllll. due to non-c.clnogenaln ,1111 01 de"lm,nlal health errecta "aultlng tom
varloua media. expo awe 10 contamlnanlaln Ihe goundwal... aa
Idenllfled In the Rlok Aa....menl.
o.oundwaler Chemical Sale o..1,.lng Walt.. Act. Maximum Relevant Ealablah.. enlorceable alandarda The comblnellon 01 capping and enactlon and
-Fad.a' Specific Contamlnanlle""laCMCl'I.40 CFR. & lor "Peclne conlamlnant. which have "eatmenl 01 goundwalar at either Ille hol apol or
7 P.I141 Appropriate baen del. mined 10 adver..ly .rrect Ihe lOulh...n p8'lmeler of Ihe landrll or.1 bolh I.
human health. The.e alandarda .re expeded 10 conlaln goundwal. exceeding MCla
pl'olec\lve 01 human hedh for whhln Ihe compliance boundary. A goundwa....
bldlvtdual chemlcele and ere monhorlng progam will be deelgned 10 detormlne
developed using MCla, avell.ble Ihe err.ctlvene.. ollhe containment a)'llem.
"ealmanllechnologlea. and co.t
-------
. Media
QOlrldwater
-Fednl
GOlrIdwater
-State
Groundwater
-Slat.
Groundwater
-Slala
Groundwaler
-Slata
'Type/I';
Chemical
SpecifIC
B
Acdon
Spe ciflC
1
Action
Sp.clllc
2
Action
Specific
3
Action
Speciflo
4
ClF FEASIBILITY STUDY
TABLE 14A (con't)
AnAn. FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5, OU1-6, AND OU1-7
. .
. . ""'. .
. . "'. .
}. ()':'\::';:;?n.~~ir~8h; .rits ,..
.. .
. ...
..
Stahis'
Sale [}irkiro Wahr Act. Maximum
Conlaninn level Goals. (MClGs) 40
CFR. Pllt 141.
Relavant
&
ApjJ'ojJ'iate
Rhoda Island Ruas Bnd Regulations
la Ch.....:fwBtw Quality. RIOEM
7193. S.abna 12.02 and 12.03.
Applicable
R Ruin and Regulallon. lor
Groundwaler QuaUiy. RIDEM 7193
Sactlon 5.08.
AppUcable
R Ruin and Regulallonl lor
Hazardoul W.ala Managamenl.
RDEM 4192, S.ctlon 9.03.
Applicable
R Ruin and Regulatlonl lor
Solid WII" Manag.ment,
ROEM 4192. Section 7.08 and 15.11.
Appllceble
.,","':':':'.":::":', """
.." """ .," ",.
. . . .. ... - . .. ..,. .
:".. .'.. .'. A8Q~~~~~ri(svhgDsil
. MCLGs are non-enfaceable haahh
ooals. TIley establish drirl
-------
. Medii:"):.
Suface Walll'
-Fed1l'81
Suface Walll'
-Fedll'el
S..'ace Wal.
-Federal
TyPal;::
Action
SpecifIC
1
Action
Specific
2
locallon
Specific
3
ClF FEASIBILITY STUDY
TABLE 14A (con't)
AMRa FOR COMPLIANCE
SITE WIDE ALTERNATIVES OU1-5, OU1-6,AND OU1-7
d.
d'
:.:\(}.. ",Qui-mom,nts'
..
. .
. .
. n8QU~8rrie;,t sim~ti~s:
. Slatus d:
Claan Walll' kl - Nationel Pollutant
Discharge Elimination Syslem
(NPOES) Regulalion 40
CFA Pllts 122, 123, end 124 -
Novembll' 16,1000.
ApplicelJla
Regulales the point souce dischiJ"ge
of watll inlo public wface walers.
Clean Watll' kl- Fedaral Ambient
WeIll' Qual~yQ~lI'ie (FAWQC),
40CFR 122.44.
Relovant
end
App-op-iale
Non - anfaceabla guidence which Is
used by slalas In conjunclion wilh a
dasignelad usa for a weam e!fluant
10 eSlabiish waler Quality 51 and II' ds.
wac levels fa p-oleclion 01 human
heallh from conlum/ng aquadc
orgenllml (planlund 6ahl and lor
prolectlon 0' aqualle organllma have
bean davelopad lor ...varal
contam/nanla. The lIand8lda ror
protection 01 human heafth tom
conaumlng fish and tha atand8lda 01
proieciion 01 aquallc organlsma ara
,elevanl and appropr lela H Ih...e la no
more "lngenlalale ru181 lor p.llculGr
conlamlnallon.
"'olecllon 01 Wellanda - Execullve
Order No. 11990,40 CF R, Pell 6
Applicobla
naqu~.. led« al auendello avoid
Impacb anoelaled whh Ihe
de!llrucllon Of Io.a 0' wetland I and 10
avoid IUppotl 0' new conltucllon In
wellandall a practical an«nallve
e.lalL
Paga 4 0111
.Hi. :: Acllon to be .. .
.::.:,>:: : ::TBkon'lo 'Allalri:NlMls .
Subslantive reQuremorts of the
ragulation wi. ba mal by allernativas
dischll'ging .mwnt 10 on-s~e wlace walers.
Slendords fa p'olecllon of human heallh
fa consumption of fish and slandllds fa
p'olaction 01 aquatic aganisms will be mel
by ahll'narives discharoir(j 10 on-sila
suface watll'.
Ahornotlve OUSls nolOlpacled to all« or advouely
Impact a weiland. Alternative OU6 and OUl
goundwater contaminant me..., ea may Impact
wellands. Any h..m will be minimized and Ihe
wetlanda will ba reaaed at complellon 01 the
-------
Pogo :i 01 II
ClF FEASIDILITY STUDY
TABLE 14A (con It)
ARAR. FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5, OU1-6, AND OU1-7
'. . . . '. '. n. . :"'.':'...t'tlJonlobB.... ".'
.. .. .. ... .. . . '<':;0:: . .i:, non~~8~~~~S~iJ~sI~i.::. ..
. ... - .. '. 'SllIius ". ".
..::.: Media.: ':Twi/#:: " ::::no~ortnDmenls': : ".,: > .. ::Tekinlo AUalriAAARs
..., . .
SU"lace WatlJ Chemical Rhode Island Water Qualily Applicable Inc(J'p(J'Bles RI AmbierC WBlIJ Effluent discharged 10 sU"lace wBlers
-Slale Specific Slandards. RIDEM, effective 1/9185, Quafity Sland;rds. Classlies wallJ wiM meel!hese slandards.
1 amended HV21VOO use and definos waler quaily goals
10 f)'Olecl public heakh and wellare,
onhance dIe quol~y of slole wolor,
and scrvelhe pU"pose 01 \he CWA.
SU"laco WallJ Chemical Rhode Island WBlor Ouaily Applicable Torosl(J'e,lJ"escrve and enhance EffluerC discharged 10 slllece wBler wi I
-Slale Specific Regulations, AlOHA, effeclive 1/W8S, !he quefily 0/ the wBln 01 the slele nol degrade high qua lily sU"lace weill'S
2 8I11endod 1!V21VOO and 10 1J"0lecilhe walars tom (J' IU"1h1J degrade low quality 9.IIace
pollularts. waler5.
Surlaca Wal. Chamlcal Rhodal.land "'a"aalmonl Applicable Cov... pollulanl.ln waalawal.a Romadlal actlonl which Includa
-Slalo Specific Regulallonl, RDEM. Juno 15. 1984. whlcll can havo dlllrtmanlalaftocli dlachargalo !he C)an.lon POTW. will
3 on POTW procelle.. Sall.pocrlod moalall dlacharge Umltallonllmpol8d
IImllatlon.. I"elrollmenl and by POTWI.
monllorlng roqulramenll lor
dlachargOllo POTWI buod on
loder al rogl.llaUonl.
Surlaco Wal. locallon Rulea and Rogulallonl Governing Ihe Applicable Acllonl requ~ed 10 I"ewnllhe Allernatlvo OUS II nol oxpoc.d 10 all.. or dlsl.. b or
- 51810 Specific Enlorc.emanlo' Iha Fra.hwa..r undoslroabla drainage, oxcavollon. dellroy a weiland. AII...nlllvel OU6 and OU7
4 WetlandlAct. ROEM. 8/90 liIIlng. eller ellon, enaoaehmenl or "oundwaler contamlnanl mo...... may Impact
Iny olh... lor m 01 dl.l.. banco or wollonda. Impacll wll bo mlnlmlzod In accadlnce
dor.aructlon 10 a weiland. with Ihol8 regulotlonl.
Sur loco Wal.- Acllon Rhoda hland PDES Regulallonl Applicable Oe8lore. I"e_w Ind anhanc.e On- IIIIt dllch.-gelo aurlace will.. wiD
- S18'a Speclnc (11 POES) , RlOEM. adopled 7/20/84. quollty 01 ..'oce wal.1 and fWolect meal lubltanU'Io r oqui/emenillhal .a
5 amonded 2/9/93 walen 'om dlach.g.. 01 more nlngonllhan NPOES Ao"am.
-------
.M~di~.i." ..f\.'TvD'/#.:'
Ai Quality
-Fedlral
Ai Oual iIy
-Federal
A~ Quality
-federel
A~ Quellty
-Federal
A~ Quality
- fader al
Action
Specirlc
1
Action
SpecifIC
2
Action
Speclfio
3
Adon
Speclfto
..
Action
Specltlc
5
ClF FEASIBILITY STUDY
TABLE 14A (con I t)
AHAR. FOR COMPLIANCE
SITE WIDE At TERNATIVES OUI-5, OUI-6, AND OUI-7
,::.
..,,: .:. ... ..
uirin.m.nts :::.'.\.:
nesOllC. ConslrvBlion and necovery
Acl (J1CAAJ lr1erim SIBlus; ThlrmaJ
Tr.almlr1, 40 CFA, PBlI265,
Subpart P
nCAA, Air Emisson SlandBlds fa
Process Verts, ..OCFA, Pari 264,
SOOpa/! M
nCAA, Air Emlalllon Slandardalor
Equipment leak a, 40 CFn, Part 264,
Subpart 80
Cleen A~ Act (CM) Nalbnal
Emlaalona StanderdalOl' Huardoua
A~ Pollulanla (NESHAP). 40 CfR
Perl. I.
nc RA, Ak Emlnlona tom Tlealmen~
$Iorage and DI'po181 facilldea,
40 CFR, Part 264, SlA>per I CC
(Propoaed 56 FR 33490-33598
7/22(U1)
..
, .i' :.., SI~;US: >:).'
Applicable
Applicable
Applicable
Relevanl
And
Appoplale
TOC
....:.,...::::.
.. ,::. :..",,:.:... ..:.. ...,.
. niiqu"-ltTient Svnopsls
nogulolions contein requiremenls la
air ernssions monilaing"om Ihermal Ulils.
Slendards frr air emissions" om
Jl'ocess venlS associated with
dist~lation,lraclionatiol\ thin
film evaportion, column extraclion a
nir sloom slripping OPB'Bbons thot
UBI nCnA subslan:es and have
lolal organic conoonlrallona 01 to
ppm Of ",eal..
Standardalor a~ emlllion. lor
equlpmenlll.1III contain a Of contaaa
RCRA wutea wllh organic
conoonlrallona 01alleu110% by
weight.
Ealabhh emlnbn levela IOf c«laln
hazerdoua ar pollulan".
"'opoaad alanderdalor a~ emission a
tom 'eatmenl, atorage and dlapo'"
lacllblea with VOC conoonhtlona
aquallo Of 1108IOf II,." 500 "I'm.
Page 6 011 t
:.'/< ..:.
... ::.,:...ActJonlolia :-. ..
':'Taken loAltaln.ARAns. '.:
..
Emissions 110m Ihe LFG lacilily and
healed vapor eXIrBClion will comply wilh
these regulations.
Emissions "om air slripping optrauons fa
l70undwaler taalmer1 win comply with the
subslantive pations oIlhis ragulation Ilhe
ltTest-old agaric conCOnllBlion Is mel.
All romadlal altornallvo. --
-------
Midia'
Ai Quality
-F.dll'al
Ai Quality
-F.dll'll
A~ Quailly
-Fad.a'
...: t .;pill, ::::/
Aclion
Specilic
6
Action
Specific
7
Acdon
Specific
8
CLF FEASIBILITY STUDY
TABLE 14A (con It)
ARAR, FOR COMPLIANCE
SITE WIDE ALTERNATlVES OU1-5, OUI-6, AND OU1-7
, "....:';;,;:.:w:':r:.;:~~6~~:~'~~imt8':i >
:'.:i .
....
-------
Paoa 8 01 11
ClF FEASlDlLIlY STUDY
TABLE 14A (con '~)
ARARe FOR COMPLIANCE
SITE WIDE At TEnNATIVES OUt-5, OUt-G, AND OUt-7
". .". .. SI8IU~> .: '(:'. i~O~~~~'~~nb:R~s
.. .. . ....
'. .Media '....,: ." TVDoJ' ., .... .:RiQui'mamenls . . nOQuhment Svnims/s '"
N Quolity Action III Ar PolkA ion Cortrol Rogulation No. Applicablo . Prohibits omissions 01 contaminants Emissions !rom .ochnologios which havo tho
-5tato 5pecirtc 7 Emissions Oar imenlallo which may be injU'ious 10 human, poiential of amitting comaminants (including
3 Parsons a Property. plant a enimal iro a cause damage biological, physical and chemical te8lments and
10 p'operly a which urT8asonobly l/1ermar lecmologies) will meollhese roqurements.
irtarlers whh Ihe enp~enl ollie M Ii monitaing p'0I1&m wi! be instilUled dU'ng
and p'oparty. remedialaClion.
N Qua/ily Action AI ~r Polk.1ion Cortrol Regulation No. Applicable Establishes guidelines fa Ihe Remediallechnologies involving
-Slale ~pecmc 9 - App'ovallo Constucl consruction. inslaRBlion, constuction.lnslaIBlion. modiliCalion a
4 In..IIII, Modify 01 Op.nle. modUicalion 01 opatallon 01 potenllal op....allon 01 a~ eml.slon unbs will meet
a~ .mlnlon unit.. Eatablahu Ihe... .equt emanla.
pat mlaslble emlulon ,atn 10. 80m.
contamlnanl..
A~ Quality Action R I>J. Pollullon Cont.ol Regulallon No. Applicable 5et. emlubn lIand.d.IOI a clau " carbon ad8Olplion I. chol8n Ihan
-Slat. Specific 13 Pa.llculata Emlaslon. olloasilluell\'ed .team 01 hot waler 'Ium I. necuaery to ,eoon..at. the
5 unit.. Prohibit. U88 01 ,otary cup carbon bad.. Itot walor may be .equt ed
bun.... In olh... ,.medialiechnoloo"s; aU wll
comptt wlh this .egulallon.
Ai' Quality Action A I>Jr Pollution Cont.o' Regulallon No. Applicable Umh Ih. amount of organic aolvenbl Eml,laon. of 01 oenlc aolvent. tom all hatment
-Stat. S~eclllo 15 Cont.o' 01 OIoanlo Solvent amltted 10 the almo.phe... lechnobglu and tom IhelFO lacUlty will ba
8 Emlaalon. c:onlrolled and monltor.d to .n.ue thai the
standard. .. met.
Ai' Quality Action R I>Jr PoDutlon Cont.ol Regulation Applicable Prohlbha the ,el818 01 objectionable Objectionable odor. boyond the fadUly
-Slat. Sp.clno No. 17 Odor.. odor. aao.. property IIn.... boundary will bo controlled.
-------
Paga II 01 t t
ClF FEASIDIUTY STUOY
TABLE 14A (con It)
ARAR. FOR COMPLIANCE
SITE WIOE AlTERNATIVES OU1-5. OU1-6. AND OU1-7
. .. .. . .,.. ...N:tlonluLJo. ...
' . . ... .... " :. ..."::,,..,::
. Media .'. TvDe''' ... .::'i{}i)RIQu.m.mlrlts. Sialus :. Rilqu"'umBnl SI/miosls. .):. ':Tilkenlo Attain NlAJls .:
h Oual~ Ac~on RIIW Poluion Cortrol Regularion No. Applicohle Dolines standards 10' elternative luel Subslentive reQuromerts allhis
-Slall specmc 20 Buring ci AklJnawa Fuels. and eSlablishes amission regularion wil be mel bV
B allowances. !he LfG f8ci~V monilaing prOl1em.
h Quality Acdon AI Nr PoIkAn COnD"oI AegulBlion Applic able This reguation Jl"olibils !he emission The ambiert ai' quality levels wil be
-Slaia Specme No. 22 N T oxics 01 spocilied contemlnents 81 relos mOllO' ellechnologios which emil air
9 which woud resuk In grol.lld level contaminants and an ai' monitalng Jl"ogram
concenlrarions aelller Ihan will be in~.uled. Emissions "om Ihe
acceptable a mbi er1 levels in !he LfG leci61y will also ba monircnd.
leguladon.
A" Quality Acllon Rhodel.land Guidance lor A" TDC Provide. guldelinOilor modale and Guidance will ba c:onald",ed when
-Slale Speclnc Quellty!Alr T oxlca Subllano.. modeling poced,na. modelling eml..bnalrom Ihelandfill ga.
10 combuadon lIack.
Har.doua Waale Acllon Reaowca Con_vallon and Recovery Applicable Denn.. Ihoa.. IOlld we"ea which a'i ACOllplabla menagemenl apIXoechee'or lilted
-Fed.al Spaclno Act (ReRA) -ldenllnc.llon end U.llng .ubJncI 10 ,egulallon .. har...doua and ch...adarl.tlc h81...doul waite will be
t olUar..doue W...., 40 CFR, wlllioa und... 40 CFR, p..la InCOfporalad 'nlo rlrnedlal actbn~.
P.1281. 262-265.
Har.doul Wa.le Acllon RCRA,lnl.lm Slalue TSDF. Siand..d.; Applicable Gen.al oporallng, waale aoalY1b. ThelFG lacility and heoled vapa oxtlctlon
-Fed.al Spaclfic Th.mal Trealmln~ 40 CFR, monkor Ing/lnspectlon and Clolll e wiD meel Iho18 ,equlremonla.
2 P.1265. Subp..1 P. requ~omonl.,or Ihll'malteal,oonl '.clllllo.
(olher Ihao Ihoae u.lng endo..d devlcea
-------
. .. .
'Media .,:-... 1.\< 'Typ.8/i:.:.':,..,'.i
Hazardous Wasta
-F edO' al
Halardous Waste
-Fednl
HaDldoul Waite
- Fedt...1
lIan,doul Waale
-Fed.al
Acdon
Spocirlc
:J
Acdon
Specific
..
A cllon
Spaclflc
5
Action
Spaclno
a
ClF FEASIBILITY STUDY
TABLE 14A (con It)
ARARa FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5, OU1-6, AND OU1-7
..
-- /RiI~u~,ri~;ri~iits'- ..:\:::
..
..', Slotus.
'.nB~u~8rri~~isvrio~5I5'.: .. 1-',::. ::+:'.'::TBkii~~I~~I~~::rtAfts .
..
..
RCRAlnterm Sielus TSOF
Siandards; Chemical, Ph')'sicaJ ard
Diological Treatment, 40 CFR, Pari
265. Subparl Q
Applic 0018
Gonera! operaling, waste anelysis
and rial lesl, nspection and clo9..Ja
raquremants fa lacilides which lJBal
helO'dous wase by chemical,
physical a biological methods in
olher IttJn larks, suraca
impoundment; end land Iraatmant
lacilitias.
Hazardous Westa Management.
ReAA,land Disposal Aeseictions
(Lon) 40 cm, PWI 268
Applic able
SpecifIC requremants la Ihaland
disposal 0/ ReRA hazardous wasle.
land disposal restrictions sel by
waite Iype Ind conltiluent
concenlraUon or required 'ealmenl
lechnobgy.
Technical Guidance lor Final Cove..
on Hu.doul Wasle landRlI and
S...IaC8 Impoundmenl,
EPMJO-SW-047 7/80
ToC
EPA lechnlcal guidance lor landlll
CO_I. ~eMnllrecommended
technlcel Ipeclficallons lor mulllllY"r
landfill coy. design.
RCnA, Clolure end POII-CIoI..e,
40 CFR. Perl 284. Subp.1 0
Appllcabla
Oalalll gan. al requ~ementl lor closure
and pOII- clos..e 01 hezardoul walla
lacllllle, Incluelng Inllallalbn 01 e
IJOUndwel. montOllng pogrlm.
Plga10 01 It
All chemicoJ, ph')'sico/ard biological
ruDIment will moal Ihoseroquiramerts.
Tho off-sita disposa/ 01 polemia/Iy
helwdous dowDlwed slLdga, wiD comply
with LOR by moating troatment standBlds
Jlflor 10 any off - olle dlopolel.
Thele ahernatlvel will comply whh Ihe
subllanllve requlremanls 01 this Gudanee,
excopl IOIlha e.lollng 32-eaal 01 cap which
will remaJll1n pia"" In ..,h Iitetnative
Th. double barrier cap per lion 01 each 01 Ihe..
eltetnatlval wUI be conllructod 10 malt Ihe
petlormance slandards lor capping In th...
regulallon.. A IJOUndwalor monitoring JlfolJlm
-------
Page11 of 11
ClF FEASIDILITY STUDY
TABLE 14A (con I t)
ARARa FOR COMPLIANCE
SITE WIDE AlTERNATIVES OU1-5. OU1-6. AND OU1-7
Typii/."/:' . . ... '. '. . . .. ,...'
-------
.. .
TABLE 15
LEGEND
Abbreviations column descriDtions are:
MCLG -
MQ.
RfO
DWEL -
Maximum Contaminant Level Goal. A non-enforceable
concentration of a drinking water contaminant that is prorecrive of
adverse human health effects and allows an adequate margin of
safery.
Maximum Contaminant Level. Maximum permissible level of a
contaminant in water which is deliv.ered to any user of a pt..;blic
water system.
Reference Dose. An estimate of a daily exposure to the human
population that is likely to be without appreciable risk of dele!erious
effects over a lifetime.
Drinking Water Equivalent Level. A lifetime exposure concentration
protective of adverse, non-cancer health effects, that assumes all
of the exposure to a contaminant is from a drinking water source.
(.) The codes for the Status Rea and Status HA columns are as follows:
E
D
1-
f
I
final
draft
listed for regt..;lation
proposed
tentative
.
Other codes found in the table include the following:
NA
~
IT
not applicable
performance standard 0.5 NTU - 1.0 NTU
treatment technique .
..
No more than 5 % of the samples per month may be positive. Fur
systems collecting fewer than 40 samples/month, no more t/"!an 1
sample per month may be positive.
...
guidance
Large discrepancies between Lifetime and Longer-term HA values may occur
because of the Agency's conservative policies, especially with regard to
carcinogenicity, relative source contribution, and less than lifetime
exposures in chronic toxiciry testing. These factors can result in a
cumulative UF (uncertainty factor) of 10 to 1000 when calculating a
-------
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
December 1993
Sl'JluJards "aDlth Advl.urln . ,1
;
-
Chemica" 10110 Chilli 70 IIU AII..II (Dllcur
S.o.... MClG MCl Stalus GrulIl'
Reg. Imglll Imglll ttA Lunoor- lorlUllr. RID
One'dey Teo.day lerm hlf 111 Imolkgl DWEl Lllallme mon el 10'
1111 !JIll 11II!l1II 11110111 ImulII deYI lin!)/II 11119111 Cellcar Risk
ORGANICS
Acenaphlhene . . 0.06
Acilluorlen T zero F 2 2 0.1 0.4 0.013 0.4 O. i 02
Acrylamide F zero n F 0.1 0.1 0.01 0.04 0.001 0.04 . 0001 U2
Acrylonitrile. T zero 0 . 0.006 U l'
Adipale Idir.lhylhellyll F 0.4 0.4 . 10 10 10 60 0.6 10 0.4 3 C
Alachlor F zero 0.002 F 0.1 0.1 . '0.01 0.4 0.04 U2
Ald,carlJ 0 0.001 0.001 0 0.001 0.035 0.007 U
Aldlca,lJ sullone 0 0.001 0.001 0 . 0.001 0.035 0.007 . 0
Akhc.1I1J suliolluJc 0 0.001 0.007 0 0.001 0.035 0.007 0
Aldllll . 0 0.0003 0.0003 0.0003 0.0003 0.00003 0.001 .0.0002 U2
Allletryn F 9 9 0.9 3 0.009 03 0.06 0
AII"no'"um sullamalu . f :lO 20 20 ~O 0.28 8 2 D
AIIIIII acelle IPAtJl . 0.3 .. ()
AllalJne f 0.003 0.003 f 0.1 0.1 0.05 0.2 0.035 0.2" 0.003' C
Bayoon . f 0.04 0.04 0.04 0.1 0.004 0.1 0.003 C
Ocnlalon T 0.02 f 0.3 0.3 0.3 0.9 0.0025 0.09 0.02 0
Ol:flzlalafllhraccne (pAl II P zcro 0.0001 . U:?
Oenlene f lcro 0.005 F 0.2 0.2 0.1 A
BCIIlolalpyrcllC IPAtll F Icro 0.0002 02'
Oe'llolblll,ioramhene IPAItI p 11:'0 0.0002 . . 112
UenloIO.h.ilpcrylcne IPAItI . u
Ucnzolklfluoranthene WAItI p lcro 0.0002 " . U2
hiS' 2 .ChlorOlsllpw/lyl elher F 4 4 4 13 004 I OJ 0
1.1111111"'1:,1 L r " ,. :J 9 0.13 ,. 0.U9 C
:J ... :J
III fIIIUllu:",I:nc L U
.. -.-- -- _.- ... - . -. .- -_.-. . -. - ~ - -. .--... -- - u_- - . -- .. . ---
Pagb
. Undcr rCIIII;W.
I,OIl. AIIII"...I.CIII: ...lItI U':II/III!.I.Io.'II,c'yh:IIC - '"11 """IIU~t:\J .11 '' I.I~C V.
NlI'L
-------
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
December 1993
.. age 2
SIDlld.,ds tle8llh Advl.oll..
Chemlcel. 10 IIU Chilli 70.kU Allull CINICltr
S'.'UI MClG MCL SllIlus GrOl.ll1 Ii
R.g. (rnoili Irnulll itA LOllue,. Longll'- RID .,
On8-day Ten-dllY 181m 181m ImUlllol own LlI811me moll III 10. Ii
IlIIul1l ( /II!J 111 IIII!JIII (mglll dayl ImanJ h II!J III Cancel Risk I
UlOlllOdtiOI Udt:C IOI.illllc L [)
Olomocitiolomelilane - F 50 1 1 5 0.013 0.5 0.09
O,omodiclllo,omelliaIlC ITIIMI T le,o 0.1' t 0 7 7 4 13 0.02 0.7 0.06 82
Olomolorm IflIM) T zelo 0.1' t 0 6 2 2 6 0.02 0.7 - 0.4 02
O/omomelhane T . f 0.1 0.1 0.1 0.5 0.001 0.04 0.01 0
Billyl benzyl phthalate (PAE) P le/o 0.1 - . - 0.2 6 C
Outylate f 2 2 1 4 0.05 2 0.35 [)
OulylllcOlclIC ,,- [)
ButylllclIICIIC scc. [)
Olltylbenzene It/l- - . D . ' - - .
Ca.ba.yl F 1 1 1 1 0.1 4 0.7 0
Calbolu/an F 0.04 0.04 F 0.05 0.05 0.05 0.2 0.005 0.2 0.04 E
Carbon ICllachlo.idc F IC'O 0.005 F 4 0.2 0.07 0.3 0.0007 0.03 0.03 U2
CalboxlO . F 1 1 1 4 0.1 4 0.7 [)
Chloral hyd.ale T 0.06 0 7 1.4 0.2 0.6 0.0002 6.07 0.06 C
Chlolamben . F 3 3 0.2 0.5 0.015 0.5 0.1 - 0
Chlo/dane f ICro 0.002 f 0.06 0.06 0.00006 0.002 0.003 U2
Chl%dill/ olllornc thallc (TlIM) T lC/U 0.1'1 [) 7 7 2 8 0.02 0.7 0.06 C
Chloroclhallc L 0
Chioroiolm (TIiM) T lcro O.I'.t 0 4 4 0.1 0.4 0.01 0.4 0.6 02
Chl%rnclhane L F 9 0.4 0.4 1 0.004 0.1 0.003 C
ChlO/ophcnol (2-) - . [) 0.05 0.05 0.05 0.2 0.005 0.2 0.04 U
p'ChlOfoJlhcnyl methyl
suit idc/sillt o/lc/slllinx ulc . . - U
Chl%pic,," l . . -
ChlorolhalulIIl f 0.2 0.2 0.2 0.5 0.015 0.5 0.15 U2
ChlorUlulllcllc o. L F 2 2 2 7 0.02 0.7 0.1 [)
Chillrololucllc p- L I: 2 2 'I. 7 0.02 0.7 0.1 0
ChhlfJlYlllos F 0.03 0.03 0.03 0.1 0.003 0.1 0.02 0
U\ly~"IIO: WAIII I' 11:'11 0.0002 U2
Cy.\lI.IIOI": T (} 001 0 (I 1 01 002 0.07 () 002 0.07 0 DOl C
. .- -.- - - "- - . --.. ..-... _.. 'n - .- - - -- .. .... --_..- - --.. . --- -- '_.n. -. -- .
. , ""0"'" tAt I
. , ".../ ...11""'( IIJ('uutl 0 , (m .Iff , ""'.\'
/JlIII
-------
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
December 1993
Pago 3
S IlII\cJ 81 cJs tteallh Adlllso,le.
u
Chemlcall 10110 Child 70 "U Adult ClNletll
Sialul MCLG MCL SI81us GlUull
Reg. Imgn! II11UIl) ttA LonDO'- Lonoo,- RID
Ona-doy Tan-day to,m la,m Imolllgi OWEL lIfotlme mg" 01 10.
11110/1) 1111011) 1'"011) Imgnt day) hno/l) (1110111 Cancel RI,II
Cyalloucn chlolidc L -
Cymene p- - . 0 - . - ','
2.4-0 F 0.07 0.07 F 1 0.3 0.1 0.4 0.01 0.4 0.07 ,.
D ,.
I:
DCPA IDaclhal) l - f 80 80 5 20 0.5 20 4 . D .,
DiJiapon F 0.2 0.2 F 3 3 0.3 0.9 0.026 0.9 0.2 I) .
0112 -elhylhexyljadipale F 0.4 0.4 20 20 20 60 0.6 20 0.4 3 e
Dlalinon . . F 0.02 0.02 0.005 0.02 0.00009 0.003 0.0006 E
Oibenlla.h)aoll\facellc (PAil) r lCIO 0.0003 . U2
Dlbromoacelonilrile L D 2 2 2 8 0.02 0.8 0.02 e
Dlbromochloropropane IODep) f 11:10 0.0002 f 0.2 0.05 - . 0.003 U2
Olbromomelhane l 0
Dlbulyl phlhalate IPAE) - - . - 0.1 4 . 0
Olcamba l F 0.3 0.3 0.3 1 0.03 I 0.2 D
DlCt\loroacetaldehyde l - D - - - - -
Dlchloroacclic acid T ICIII 0 ' " 4 0.04 0. 1 U2
DlchloroacetOnillile l D 1 1 0.8 3 0.008 0.3 0.006 e
Dlchlorobenlene 0- f 0.6 0.6 F 9 9 9 JO 0.09 3 0.6 D
Oichiorobellicno m. . f 0.6 0.6 F 9 .9 !) 30 0.09 3 0.6 0
Dichlorobenlene p- f 0.075 0.075 F 10 10 10 <10 0 1 4 0075 C
Dichlorodi lIuOl omelhanc L - F 40 40 !) 30 0.2 5 1 D
DIt:hlOloclhallc 11.1'1 l D
Dichluroclhallc 11,2'1 f lcro 0.005 F 0.7 0.7 0.7 2.6 0.04 U2
DIt:hlulUclhylunc (1,1.) f 0.007 0.007 F 2 1 I 4 0009 0.4 0.007 C
Oichloloclhylcne (cis" ,2.) f 0.07 0.07 F 4 3 3 11 0.01 0.4 0.01 (j
OlchlOloclhylclIC (lralls.I.2.1 f 0.1 01 f 20 2 2 6 0.02 0.6 0.1 U
1)IC"'OIIIIIICI'..ule f IUIIJ 0.005 f 10 2 0.06 2 0.5 lI2
Uu;hhllllJlhclIlIl 12,4) U O.OJ 0.03 O.OJ 0.1 0003 01 0.02 U
UILhlulOplOpanc (1,1'1 ()
UIl.hhIlUJlItJII.IIIC 11.2 I f 11:/(1 0 DO!> ' II O~ OO!J 112
1J".IlllIltIllfUII,IIIC 11.31 L 0
- -- ~--_..... . - - - - -- 'U .. . -. -_A --- --.- '-- - -- -.-- _. - -- -_. -. -.. --- - -.
-------
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
December 1993
Page 4
Siandard. ttllllih Advlsorle.
Chemical. 10 kO Child 70.kg Adull CDlICU'
5181uI MClG MCl 5'alus G,oup
Rag. hnglll' 1m gill ttA Lonuor- Lonue,- RID
One'dll)' Ten.day hum lerm 1010'" gl DWEl Ufollm. II1UIl II 10'
IlIIulll Imulll IlIIun! IlIIun! dayl ImOl1l IIIIUIll C8I1C1' Rille
()u;hlo'OIUOllilIlC 12.2., L I>
Ou;hlo,oluopene 11.1-1 l . 0 . -
Dichloropropene 11.3.' T zero f 0.03 0.03 0.03 0.09 0.0003 0.01 0.02 82
Dieldrin - - . f 0.0005 0.0005 0.0005 0.002 0.00005 0.002 . 0.0002 82
Dielhyl phlhalale IPAEI 0 0.8 30 5 0
Oielhylene glycol diniltale - . .. - - - .
-
Dlclhylhcxyl Ilhlhillale IPAEI f ,cro 0.006 D 0.02 0.7 0.3 82.
Oilsopropyl melhylphosphonalo - f 8 8 8 ~O 0.08 3 0.6 0
Olmelhun f 10 10 10 ~O 0.3 10 2 D
Ounclhyl rnclhylphosphoNIO f 2 2 2 6 0.2 7 0.1 0.7 C
U,II'cllI,1 ,.1,11",1.1'" WAll 0
I. J O.II.IlIII'C'IICIIC: f 0.04 0.04 0.04 0.14 0.0001 0.005 0.001 - 0
U....llululuc"" 12.41 l f 0.50 0.50 0.30 1 0.002 0.1
D,II.IIUluIIlCIIO 12.6'1 l f 0.40 0.40 0.40 1 0.001 0.04 . -
III 2.6 ISo 2.4 dlnllrOIOluene ... ..' 0.005 82
UIlIO:\cb f 0.007 0.007 f 0.3 0.3 0.01 0.04 0.001 0.04 0.007 0
OIOXiine p' f 4 0.4 0.-' 112
O,phcnillllld - - f 0.3 0.3 0.3 1 0.03 1 0.2 0
OiphenyliJllllrw f 1 1 0.3 1 0.03 1 0.2 I>
Diqual F 0.02 0.02 " 0.0022 0.08 0.02 0
Ui slill 0 IOn F 0.01 0.01 0.003 0.009 0.00004 0.001 00003 [
Oilhiallc 11.4.' . f 0.4 0.4 0.4 1 0.01 0.4 0.08 0
DIUlon f 1 1 0.3 0.9 0.002' 0.07 0.01 D
[rllJolhall F 0.1 0.1 f 0.6 0.8 0.2 0.2 0.02 0.7 0.1 [)
Endull f 0.002 0.002 f 0.02 0.02 0.003 0.01 0.0003 001 0.002 0
f p":/"III o/Iyllr In f ,cro H f 0.1 0.1 0.07 0.07 0.002 00-, 0.4 82
I:IhyllJcnlcnc F 0.7 07 f 30 3 1 3 0.1 3 0.7 0
I:Ihylcllt: lloh,omilic I(DUI f IC'O OOOOO!J I' 00011 0.008 0.00004 02
III'y":lIc Uly!:ul I 20 (j Ii 20 '2 40 7 f)
I III l f U.:! 03 0 I 0.4 0.00006 0.003 0.03 U2
I ,'II.IIIIIIJtll'~ , () 1)( I~I II 009 II Oil!) 002 II nOli;!!; 0 ()()~ II 0112 f)
- "" - ". ... .. - . . - --- -.. . .-..- -. . - --.- ... - - -. - ..
Ii
-------
TABLE 15 (cant 'd)
Drinking Water Standards and Health Advisories
December 1993
Page 5
- --
Standald. Iteollh Adl/llorln
Chemlcal8 10 leO Chilli 70leO Adull COIICIU
StatuI MCLG MCL Slalu. GIt.lUII
Reg. 1100111 1100/11 HA LonDoI- Lonool' RID
One day Ten-day 101m lelm 1100"'01 DWEL Ulollma moll al 10.
11110111 IlIIulll 111101\) Imglll dayl 1010111 Imglll C8lICOI Rille
f luollle lion - . f 2 2 2 5 0.013 0.4 0.09 [)
fluolene (PAIl) . 0.04 O
F Iuolotrichlolome Ihane L . . F 7 7 3 10 0.3 10 2 D
Fog Oil D
Fonolos - . F 0.02 0.02 0.02 0.07 0.002 0.07 0.01 D
Formaldehyde . D 10 5 5 70 0.15 5 1 UI
Gasoline, unleaded IlJenlencl 0 . 0.005
Glyphosale f 0.7 0.7 F 20 20 1 1 0.1 4 0.7 £
Heplachlor F lCIO 0.0004 F 0.01 0.01 0.005 0.005 0.0005 0.02 0.0008 02
".
Ih:plachlor epollide f lCIO 0-0002 F 0.01 0.0001 0.000\ 1£-5 0.0004 . 0.0004 02
ltelCachloloberuene f lelO - 0.001 F 0.05 0.05 0.05 0.2 0.0008 0.03 0.002 02
I lell achiolobul ddlcne T 0.001 F 0.3 0.3 0.1 0.4 0.002 0.07 000\ .. C ..
I Ie IC achlorocyclopenl adlfmo f 0.05 0.05 . 0.007 0.2 0 ;
,.
HelCachloloelhane L F 5 5 0.\ 0.5 0.001 0.04 0.001 C I
lielCane 11'1,1 F 10 4 4 10 . 0
ltelCalinonc F 3 3 3 9 0.033 1 0.2 0
IiMX . . F 5 5 5 70 0.05 2 0.4 0
IndcnoI1,2.3"c,dlpyrenc IPAlil P lelO 0.0004 0 U2
Isopholone L . F 15 15 15 15 0.2 7 0.1 4 C
Isopropyl melhylphosphonale . D 30 30 30 100 0.1 4.0 0.1 D
ISOI.llO/lylIJcIIlcnc D .
Llndanc f 0.0002 0.0002 F 1 1 003 0.1 0.0003 0.0\ 00002 C
Malalhion . - f 0.2 0.2 0.2 0.8 0.02 0.6 0.2 /)
M.lh:l!: hydliuillc f 10 10 ,- 20 0.5 20 .. ()
:J
MCI'A I' 0.1 0.1 0.\ 0.4 0.0015 O.O~ 00\ I:
MClholilyl L f OJ 0.3 03 0.3 0025 O~ 0.2 n
Mo" h... ~. h',., , 0 (I~ (I(H , 0 ()!. 005 u 05 02 0005 0.2 U 04 /)
'.A. ...)1 ,-II'f' "t 1,,1'4" f .
t.,. 'I." I I. II .11." " , (II 0 I (0) 0 \ () 00025 0 OO~ 0002 ()
.- -- - .. --._-- -. -
-------
December 1993
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
PaOt! 6
Slend.,d, Heallh Adl/llo,l..
Chemlcel. 10.I&U Child 10.1&0 Adull C OIlC III
5'01ul MCLG MCL 510lu. G,OUII
Rog. (mOll) (mglll itA Lonoe,- Lonuo,- RID
Ono.d~y T en-doy 101m lelll\ (molkgl DWEL lIIoII",. mgll 01 10"
(mon! Imo'" IIIIUIl) (mon! doy) 111\0111 ImOIl) C IIOC8' RII II
Mclhyl lerl bulyl elher L D 3 3 0.5 2 0.005 0.2 0.04 0
Melolachlor L - - f .2 2 2 5 0.15 5 0.1 C
MClllbulin L F 5 5 0.3 0.9 0.025 0.9 0.2 D
Monoehloroaeelic acid L . D - - " -
Monochlorobenlcne F 0.1 0.1 F 2 2 2 1 0.02 0.1 0.1 D
Naphlhalene - F 0.5 0.5 0.4 1 0.004 0.1 0.02 - D
Nltroccllulose Inoll'Io)(icl F
Nilloguanidine f 10 10 10 ~O 0.1 4 0.7 D
Nillophcnol p- . F 0.8 0.8 0.8 3 0.008 0.3 0.06 0
O)(arnyl IVydalel f 0.2 0.2 F 0.2 0.2 0.2 0.9 0.025 0.9 0.2 E
Pilrallual F 0.1 0.1 0.05 0.2 0.0045 0.2 0.03 E
PCIII ill: Illor IIC IhilllC () -
Pcntachiorophcllol F zcro 0.001 F 1 0.3 0.3 1 0.03 1 . 0.03 02
Phellanthrene (PAUl - - . - -
Phcllol D 6 6 6 20 0.6 20 4 D
P,eloram f 0.5 0.5 F 20 20 0.1 2 0.01 2 0.5 0
PlllychlulIIl.llcll blphcllyls II'Cllsl F 11:111 0 Dom, f' 0 ()O()~) 112
f'romclOn L - F 0.2 0.2 0.2 0.5 0.015" 0 I'. 0.1. ()
.:J
PlUnarnide F 0.8 0.8 0.8 3 0.015 3 0.05 C
PlOpachlor . - f 0.5 0.5 0.1 0.5 0.013 0.5 0.09 D
ProJliJlillC F 1 1 0.5 2 0.02 0.1 0.01 C
ProJlhaHl . F 5 I) 5 ~O 0.02 0.6 0.1 ()
PWllylhclIlCIIC 11- D
Pylcrll: (PAIII 0.03 ()
IIOX F 0.1 0.1 0.1 0.4 0,003 0.1 0,002 0.03 C
S.lIIiJ/IIIC F 0.004 0004 I' O,OJ 0.07 007 0,07 0005 02 0.004 C
SIY'CflC F 0 I 0 I F 20 2 2 J 02 7 0 I C
2.4.bT L I 011 OtJ Oil 1 001 U 35 0 OJ f)
1.:1.7.1\ TCO[.) l()nullIl f ,t:IO .11 1111 I II 06 It 07 Il (JIJ 4[ 011 1I,0~ 41011 :n UII U2
-....--.- ..--. -_.. .-.. -_. -- -- -- -- --- . - - ---. .. ..... . -.. . .-. ---- -'. - - _.. -.- ~-._- - - - - - -
. UII,h~' h:v.CW
-------
TABLE 15 (cant 'd)
Drinking Water Standards and Health Advisories
December 1993
SlondDfda I' Health Advlso.l..
Chellllcbla 10 1<0 Child 70 I 002 U OO:.! 01 C
V,"yl LIIIIIIII.lC F IC'U U 002 f J :J () 0 I OO!) U UO)!> A
Xy"""", f 10 10 I. 4U 40 40 100 2 liO 10 II
. . - ... .. . --- - --- .-. .- _. --- - - . .- - h - ------. ..-.. n ---.. -.. . .. --~- ..
. .
Page 7
.. f\ IIA w,1I1II11 III: 110:\11:111111:.1 ,I",: III III~IIIIII 11'.11 11,11.1..1 1),11.,11,1:.0: r1.:l" "'III y ""1"111
-------
TABLE 15 (cant 'd)
Drinking Water Standards and Health Advisories
December 1993
Page 8
Slondeu" tlellllh Advlso,l..
Chemicals 10 kO ChillI 70.kU Adlill CIllICIlI
Stelul MClG MCl Slatus GIOUp
R80. 1m On! ImOll1 tlA lonuer- lon!Jor. RID
One.day Ten.dey IUlm lor/ll IlnU/kli1 DWEl life lime moll el 10'
(ln9111 (1119111 1111 !J II I (1110/11 deyl IIIIU/II 11110111 Cence' Rlak
INORGANICS
Aluminum l 0
Ammonia - 0 . - 30 0
Anlimony F 0.006 0.006 F 0.07 0.01 0.07 0.0\5 0.0004 0.07 0.003 D
Arsenic . 0.05 0 - 0.002 A
AsbeSlos Ifibersll > 1 OJlrn F 7 MFl 1 MFl 700 Mfl A
lenOlhl
Oariurn F 2 2 F 0.07 2 2 0
Oe=rylhum F 0.004 0.004 0 30 30 4 20 0.005 0.2 0.0008 U2
Doron l 0 4 0.9 0.9 3 0.09 3 0.6 " 0
C adllllurn F 0.005 0.005 F 0.04 0.04 0.005 0.02 0.0005 0.02 0.005 ! ()
Chloramine T 4 0 \ \ \ 1 0.1 3.3 2.6 -
Chlorale l 0
Chlollnc T 4 . 0 - 0.08 " - 0
Chlollne diOltide T 0.08 0 0.003 0.\ 0.08 0
Chlorllc l 0 - - 0
Chromium 11010111 f 0.1 0.1 F 1 \. 0.2 0.8 0.005 0.2 0.\ 0
COllper F 1.) 1-. " . . 0
Cyanidc P 0.2 0.2 F 0.2 0.2 0.2 0.8 0.022 0.8 0.2 U
Fluoride. F 4 4 - 0.12
Hypochlorilc T 4 - -
IIYIIOt:hlolous ill;itl T 4
lead 1011 lapl F zero n". U2
Malloancse l 0 0.\41
0.005
MerclllY 11110111.11111:1 F 0.002 0.002 r 0.002 0.0003 0.0\ 0.002 0
MulyLlllellulII l D 000 001 0.05 0.005 0.2 0.04 ()
N,!.""I f 0.1 0 1 f \ I ()!j 1.7 0.02 Oli 0.1 0
N.II.llc I.I~ NI f IU 10 t- \0' Ui '
.. - .. - - -- --- - _.
. 111111<:1 ,.:"",\1\1
.. CIII'I":'
-------
December 1993
TABLE 15 (cont'd)
Drinking Water Standards and Health Advisories
Pago 9
Siandards Health At.lvlso,iel
ChemlclIl. 10110 Chilt.l 70110 At.lult C alleu,
StatuI MCLG MCL Sletus G,oup
Rig. 1m 11111 Imllll) HA longal- looua,. RID
One.day Ten-day lelm la,m Imglkgl OWEl LIlellme mll/l 81 10"
Imglll 1m oM 1010/11 Imgn) day) Imgll) Imglll Cance, Rllk
NII,ilc 1.ls Nt F 1 1 f 1. O.Hi. .
Nillille + Nitrile Ibolh as N) F 10 10 f " . '
Selenium F 0.05 0.05 0.005
Silver . . - D 0.2 0.2 0.2 0.2 0.005 0.2 0.1 . D
Sotlium D 20...
SIIOl\lillm l D 25 26 26 :>0 0.6 90 17 . 0
Sulfale p . . . .
Thallium F 0.0005 0.002 F 0.007 0.007 0.007 0.02 0.00007 0.002 0.0004 .
Vanat.llum l D 0
WIllIe pho~J.lholOuS F 0.00002 0.0005 0.0001 0
I,,,. l f 6 6 3 t2 0.3 11 2 D
III,,, ("I "lode Imc".ulc..J .~ l,'\(;1 L F 6 6 J 12 0.3 11 2 .' 0
RADIONUClIDES
Uti. parhclc ilnd pholon
aChv.ly lIormc,ly
man.mat.le rat.llofluclit.lcs) p zero 4mrem . ' . - . 4 mrernlv A
Gross alpha pallicle aClivily P zcro 15 pCi/l 1 5 pCl/l A
nadlum 226 P zcro 20 pCi/l ' . 20 "Cl/l A
Aildium 228 P ICIO 20 "Cl/l 20 pC,/l. A
nation p Icro 300 IICl/l . 0 I 50 "CI/L A
Ur amum P lero 20 pg/L - 0.003 70 PUll A
. Undcr rcview.
.. Delcrrcd.
-------
TABLE 16
RISK BASED PERFORMANCE STANDARDS FOR GROUNDWATER CONTAINMENT
contaminant of Concern
containment Level
(uq / 1 )
1,1 - Dichloroethane
810
Methyl Ethyl Ketone
22,000
2,4 - Dichlorophenol
110
Naphthalene
1,500
lead.
15
Vanadium
-------
APPENDIX C
RECORD OF DECISION
CENTRAL LANDF!LL SITE
-------
... 0 .. ... ,. _0.
;~~~;'"
I D-E-M I
I
. . . .:~~:~~ih~: :.
, ;. .
...1-,. .
State of Rhode Island and Providence Plantations
Department of Environmental Management
Office of the Director
9 Hayes Street
Providence, RI 02908
John De Villars, Regional Administrator
United States Environmental Protection Agency, Region I
John F. Kennedy Federal Building
Bos~on,~ 02203-2211
Dear ~illars:
This is to advise you that the State of Rhode Island concurs with the selected source control
remedy detailed in the June 1994 Record of Decision for the Remedial Action of the Central
Landfill Superfund site. This concurrence is based upon all aspects of the abovementioned
Record of Decision being adequately addressed and implemented during design, construction
and operation of the remedy.
15 June 1994
The Department wishes to specifically emphasize that the remedy, as proposed and
implemented, must ensure compliance with all applicable or relevant and appropriate State
and Federal statutes, regulations and policies.
Furthermore, both agencies must continue to progress on the second operable unit for this site,
involving the investigation and analysis of off-site contaminant migration both from the
Central Landfill itself and any neighboring sites which have been identified.
Finally, I urge EP A to make every effort to assure that the remedy will be implemented in
a timely and efficient manner and that it be implemented, over time, in a coordinated manner
with the licensed disposal activities ongoing at this property.
Thank you for providing us with an opportunity to review and concur with this important
R.ecord'~Of~DeCiSion.
Smc e
---
V .
Mich 1 Annarummo, Director
Dep . ent of Environmental Management
cc:
James Fester, Associate Director, DEM
):rank Ciavattieri, Acting Director, EPA Region I Waste Management Division
Dennis Huebner, Chief, EP A Region I, NH & RI Waste Management Branch
Terrence Gray, Chief, DEM Division of Site Remediation
Telephone 401-277-2771, TDD 277-6800, FAX 274-7337
-------
APPENDIX D
RECORD OF DECISION
CENTRAL LANDFILL SITE
-------
RESPONSIVENESS SUMMARY
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
OPERABLE UNIT 1
CENTRAL LANDFILL SUPERFUND SITE
JOHNSTON, RHODE ISLAND
-------
TABLE OF CONTENTS
RESPONSIVENESS SUMMARY
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
OPERABLE UNIT 1
CENTRAL LANDFILL SUPERFUND SITE
SECTION
PAGE
PREFACE
..............
.......
1
I.
OVERVIEW (Site history, FS objectives, .
alternatives evaluated)
. . . . . .
2
A.
B.
FS Alternatives. . . . . . . . . . . . . . . .
General Reaction to the Preferred Alternative.
3
6
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS. .
6
III. COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA RESPONSES
. . . .
7
ATTACHMENTS
A. COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT
LANDFILL SUPERFUND SITE IN JOHNSTON, RHODE ISLAND
THE
CENTRAL
B.
TRANSCRIPT OF THE FEBRUARY 1994 INFORMAL PUBLIC HEARING
C. COPIES OF WRITTEN COMMENTS MADE DURING THE PUBLIC COMMENT
PERIOD
-------
PREFACE
The u. S. Environmental Protection Agency (EPA) held a 30-day
public comment period, from February 13, 1994 to March 14, 1993, to
provide an opportunity for interested parties to comment on EPA's
Preferred Alternative for a source control remedy at the Central
Landfill Superfund site in Johnston, Rhode Island. The Preferred
Alternative was selected after completion of a Feasibility Study
that evaluated various options for addressing the source of
contamination at the Landfill. EPA identified its preliminary
recommendation of a Preferred Alternative for source control in a
Proposed Plan, issued in February 1994, at the start of the public
comment period. On the evening of February 22, 1994, EPA conducted
a public meeting to discuss the Preferred Alternative and Proposed
Plan. On February 28, 1994, EPA held an informal public hearing at
which eight commenters spoke. Eleven commenters responded during
the-public comment period, three of whom responded both in writing
and at the public hearing.
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised during the public
comment period. EPA considered all of the comments summarized in
this document before selecting a remedial action to address the
source of contamination at the central Landfill Site.
The Responsiveness Summary is divided into the following sections:
section I. Overview. This section discusses the Site history,
outlines the objectives of the Feasibility Study, identifies the
treatment al ternati yes evaluated in the FS, and identif ies and
summarizes general. reaction to EPA's Preferred Alternative.
Section II. Backqround on Community Involvement and Concerns..
This section contains a summary of the history of community
interest and concerns regarding the Central Landfill Site.
section III. Summary of Maior Comments Received Durinq the Pubic
Comment Period and EPA's Response to those Comments. Each written
and oral comment from the public and interested parties on the FS
and the Proposed Plan are summarized and responded to directly.
ATTACHMENT A - This attachment provides a list of the community
relations activities that EPA has conducted for the Central
Landfill Superfund Site.
ATTACHMENT B - This attachment is the transcript of the February
28, 1994, informal public hearing held in Johnston, Rhode Island.
ATTACHMENT C This attachment includes
received during the public comment period.
the written
comments
-------
I.
OVERVIEW
The Central Landfill site is an active landfill site located on
Shun Pike in Johnston, Rhode Island. Since the early 1950s the
site has been used as a combination sand and gravel/quarry stone
operation, a refuse burning dump, and a solid waste disposal area.
In 1986, the Central Landfill Site was added to the National
Priorities List. Field work for the Remedial Investigation
commenced in 1987, after the owner signed an. agreement with the EPA
to study the nature and extent of contamination at the site.
The landfill, has been owned and operated by the RISWMC since 1980,
and currently receives approximately 85 percent of Rhode Island's
municipal solid waste. A total of 154 acres of the site have been
licensed for landfilling by the State of Rhode Island. The 121
acre Phase I landfill area and a 33 acre (Phase II and III)
expansion area make up the 154 acres. within the Phase I area is
an approximately 0.5 acre area where large volumes of liquid
industrial waste were disposed of in bedrock trenches in the mid to
late 1970s by the previous owner.
The 121 acre Phase I area reached its capacity in April 1993 and no
longer accepts solid waste. Thirty-two acres (13 acres at the
. north end of the site and 19 acres at the southern end of the site)
of the Phase I landfill area are currently capped with a Rhode
Island Department of Environment Management (RIDEM) approved single
barrier cap design. The remaining 89 acres of the Phase I area are
covered with a.temporary soil cap. RISWMC is currently utilizing
12 acres of the 33 acre Phase II and Phase III expansion areas for
nonhazardous municipal solid waste disposal.
The remedial response objectives identified in the FS are to:
1.
Minimize the effects of landfill contaminants on
groundwater quality; specifically, reduce to a minimum
the amount of precipitation allowed to leak through the
waste column and infiltrate to the groundwater;
2.
Eliminate potential future risks to human health through
direct contact with landfill contaminants by maintaining
a physical barrier; . .
3.
Minimize migration of contaminants in groundwater so that
groundwater is not injurious to the aquatic ecological
system of receiving water bodies (Upper Simmons
Reservoir, Cedar Swamp Brook and Almy Reservoir);
4.
Minimize risks to human health associated with potential
future consumption of and direct contact with
groundwater;
-------
5.
Comply with state and federal Applicable or Relevant and
Appropriate Requirements (ARARs); and
6.
Minimize potential impacts of implementing the selected
source control alternative on adjacent surface waters and
wetlands.
Based on these objectives, EPA developed and evaluated alternatives
to address the source of contamination. The alternatives that were
evaluated in the FS report are described briefly below.
A.
Feasibility study Alternatives
Based on the results of, the FS, EPA' s Preferred Al ternati ve
includes the following components as the most effective for
addressing the source of the contamination in and on the Central
Landfill Superfund Site:
.
constructing a multi-layer RCRA C cap over the 89 acres
of the 121 acre Phase I landfill that are not currently
capped. The remaining 32 acres of the 121 acre Phase I
area are currently capped with a Rhode Island Department
of Environmental Management (RIDEM) approved cap. The 32
acre RIDEM cap will be retained and incorporated into the
new 89 acre RCRA C cap.
.
Extracting contaminated groundwater from the hot spot
area and pre-treating it before it is discharged to
either on-site surface water or the Cranston, Rhode
Island wastewater treatment plant;
.
Implementing deed restrictions on groundwater use and
land development within property owned by the Rhode
Island Solid Waste Management Corporation (RISWMC);
.
Long-term sampling and ana~ysis of groundwater, surface
water and air;
.
Evaluating in detail the existing landfill gas collection
and combustion system.
.
Installing a chain-link fence to prevent access.
EPA evaluated nine alternatives in detail in the FS. Several
activities were common to all the alternatives considered except
the no action alternative. These common activities include: 1)
institutional controls; 2) environmental monitoring; 3) evaluation
of the existing landfill gas collection and combustion system; and
4) fencing.
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Alternative OU1-l:
No' Action
Alternative OUl-2: capping of Waste with a Single Barrier Cap in
Accordance with RIDEM Solid Waste Regulations and Hydraulic
containment and Treatment of Hot spot Groundwater
Alternative OUl-3: Capping of Waste with a Single
Accordance with RIDEM Solid Waste Regulations
containment and treatment of Groundwater Along
Perimeter of the Landfill
Barrier Cap in
and Hydraulic
the Southern
Alternative OUl-4: capping of Waste with a Single Barrier Cap in
Accordance with RIDEM Solid Waste Regulations and Hydraulic
containment and Treatment Hot spot Groundwater and Groundwater
Along the Southern Perimeter of the Landfill.
Alternative OUl-5: Capping of Waste with a Multi-Layer RCRA C Cap
and Hydraulic Containment and Treatment of Hot spot Groundwater
Alternative OUl-6: capping of Waste with a Multi-Layer RCRA C Cap
and Hydraulic Containment of Groundwater along the Southern
Perimeter of the Landfill
Alternative OUl-7: Capping of Waste with a Multi-Layer RCRA C Cap,
Hydraulic containment of Groundwater Along the Southern Side of the
Landfill and in the Hot spot Area
Alternative OUl-8: Capping of Waste with a Multi-Layer RCRA C Cap,
Hydraulic containment of Groundwater Along the Southern Side of the
Landfill and in the Hot spot Area and Heated Vapor Extraction of
Volatile Organics from the Chemical Sludges Buried in the Hot spot
Area
Alternative OUl-9: Capping of Waste with a Multi-Layer RCRA C Cap,
Hydraulic containment of Groundwater Along the Southern Side of the
Landfill and in the Hot spot Area Excavation of the Chemical
Sludges Buried in the Hot spot Area
EPA has selected Alternative QUl-5. The primary goal is to
minimize the continued effects of the landfill contamination on
groundwater. quality, thereby reducing the risks to human health
associated with the potential future consumption of and direct
contact with groundwater. Off-site groundwater and an ecological
risk assessment are the subject of studies currently being
conducted under EPA oversight by the Rhode Island Solid Waste
Management Corporation pursuant to an EPA enforcement order. A
second Remedial Investigation/Feasibility Study concerning the
nature and extent of off-site groundwater contamination, the
results of an ecological risk assessment, and a range of
alternatives to address any contamination will be issued after the
studies are completed.
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Except for the no action al ternati ve, all of the al ternati ves
evaluated in the FS would provide overall protection of human
health and the environment. However, alternatives OUl-2, 3, and 4
were not acceptable because they would not be in complete
compliance with the RCRA C closure requirements for hazardous waste
landfills, specifically, the single barrier RIDEM cap design used
in these three alternatives does not minimize the infiltration of
precipitation into the top, flat portions of the landfill.
Of the remaining alternatives, those which include southern
perimeter groundwater extraction and treatment in addition to hot
spot groundwater extraction and treatment (OUl-7, 8 and 9) may
provide a slightly greater reduction in the volume and mobility of
site contaminants than those alternatives that involve only hot
spot groundwater extraction and treatment (OUl-5), however, the
additional southern perimeter collection system may not provide any
significant additional long-term effectiveness or benefit to
protecting human health over that provided by hot spot groundwater
collection and treatment alone.
EPA believes that the combination of hot spot groundwater
extraction and treatment and capping willI) prevent groundwater
that has contaminant concentrations exceeding MCLs and non-zero
MCLGs from migrating beyond the compliance boundary or, in the
absence of MCLs or non-zero MCLGs, prevent groundwater that has
contaminant concentrations above levels that are protective of
human health from migrating beyond the compliance boundary and; 2)
prevent the d-egradation of surface waters below surface water
standards. Hot spot groundwater extraction and treatment should
prevent the continued migration of high levels of contamination
currently existing at the hot spot. The additional capping
component will minimize infiltration of precipitation into the
landfill; thereby, effectively minimizing any future migration of
contaminated groundwater caused by the existing 121 acre Phase I
area. Based on these reasons, EPA does not believe the additional
cost of installing a southern perimeter collection system is
warranted.
In summary, Alternative OUl-5 will achieve the best balance among
the criteria used by EPA to evaluate the alternatives~ The
selected alternative will provide short- and long-term
protectiveness of human health and the environment, will attain all
federal and state applicable, relevant and appropriate requirements
-(ARARs) identified, will reduce the mobility and toxicity of site
contamination and utilize permanent solutions to the-maximum extent
practicable. In addition, the Alternative OUl-5 is the most cost
effective of the alternatives evaluated.
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B.
General Reaction to the Preferred Alternative
The comments received from the community on the RI/FS and the
Proposed Plan during the public comment period and EPA's responses
to these comments are summarized in this Respons~veness Summary.
Only one comment, from the DEP, voiced full support for the
preferred alternative. Many of the comments received from the
community raised serious objections to EPA allowing RISWMC to
continue landf illing operations in the Phase II and III areas.
There was concern that a delay in closing the Phase I area caused
by the Phase II and III operations would allow for infiltration of
precipitation through any uncapped areas of Phase I resulting in
continued leachate generation. Many commenters felt that closing
Central Landfill should have been a component of EPA's preferred
alternative. There was also some objections to not excavating the
chemical sludges in the hot spot area and not including southern
perimeter groundwater collection and treatment in the preferred
alternative.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Throughout the Site's history, community concern and involvement
has been high. EPA has kept the community and' other interested
parties apprised of the Site activities through informational
meetings, fact sheets, press releases and public meetings.
In February, 1994, EPA made the administrative record available for
public review at EPA's offices in Boston and at the Marion J. Mohr
Library in Johnston, Rhode Island. EPA published a notice and
brief analysis of the Proposed Plan in Providence Journal on
February 8, 1994 and made the plan available to the public at the
Marion J. Mohr Library.
In September 1993 EPA issued a fact sheet which summarized the
results of the Remedial Investigation. On February 22, 1994, EPA
held an informational meeting t.o discuss the results of the
Remedial Investigation and the cleanup alternatives presented in
the Feasibility Study Report and to present the Agency's Proposed
Plan. Also during this meeting, the Agency answered questions from
the public. From February 13 to March 14, 1994, the Agency held a
30 day 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 February 28,
1994, the Agency held a informal public hearing to again discuss
the Proposed Plan and to accept any oral comments. A transcript of
this hearing with the comments received and the Agency's response
to comments are included in this responsiveness summary.
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III.
COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
EPA'S RESPONSE TO THOSE COMMENTS
Eight people testified at the public hearing. A copy of the
transcript of the hearing is attached as Appendix B. Copies of
written comments are attached in Appendix C.
Comments from Ms. Sandra Dennehy
Resident, Johnston RI
Comment 1: Is there no possible way you can cap the existing
portion of the landfill prior to Phase II and Phase III being
filled to capacity by the Rhode Island Solid Waste Agency?
EPA Response: EPA's selected remedy does not allow for delaying
the capping of the existing 121 acre Phase I landfill until the
Phase II and III expansion areas reach their capacity. Currently,
32 acres of the 121 acre Phase I area are capped with a RIDEM
approved single-barrier cap. The RIDEM cap is effectively
minimizing the inf il tration of rain through these areas of the
Phase I area. The 33 acre Phase II and III expansion areas will
not impact the entire 121 acre Phase I area. The Phase II and III
areas, when filled to capacity, will overlap about 48.4 acres of
the western portion of the Phase I area. As the Phase II area is
filled, a impermeable barrier, termed the Leachate Diversion System
(LDS), is being placed between the Phase I and II area as a means
of diverting leachate away from the Phase I landfill. The LDS is
to be installed over each lift of solid waste placed in Phase II
prior to the successive lift being placed. The Rhode Island
Department of Environmental Management (RIDEM) has reviewed the LDS
and approved its use at the Central Landfill.
EPAs selected remedy requires placing a multi-layer cap directly
over those portions of the 121 acre Phase I area that have not
already been covered with the RIDEM cap and those portions which
will not be impacted by the Phase II and III landfilling
activities. This area amounts to about 40.6 acres. Capping of
this area can start as soon as the design is completed. The
selected remedy also requires covering, with a multi-layer cap,
that portion of the Phase II and III expansion area that overlies
the western 48.4 acres of the Phase I area. The design and
construction of the entire remedy, including all capping, has been
estimated in the Feasibility Study Report to be completed within
five years from the time design begins. If activities in the Phase
II and III areas result in extending the design and construction
schedule beyond the five year estimate, then EPA will require that
RISWMC construct a liner directly over any part of the 48.4 Phase
I acres not impacted at that time by the Phase II and III area.
The liner will prevent rain from infiltrating through these parts
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of the Phase I landfill. After the liner is completed, filling
over the Phase I area can resume. After the Phase II and III area
reaches capacity, the multi-layer cap will be constructed over the
portion of the Phase II and III area that overlies the Phase I
area. The design of the liner will be included as part of the
remedial design for the remedy and all the design documents will be
made available for public review in the site File at the Marion J.
Mohr Library in Johnston, Rhode Island. None of the other
components of the selected remedy will be impacted by the Phase II
and III activities. .
comment 2: Does your agency have any solutions to deal with the
increasing problem of seagulls in and around the landfill?
EPA Response: EPA has not investigated the seagulls in and around
the landfill. The seagulls are attracted to the landfill by the
disposal of municipal solid waste. Regulation of solid waste
activities at the landfill are not within the scope of the
comprehensive Environmental Response, compensation and Liability
Act (CERCLA). However, EPA has forwarded this comment to the Rhode
Island Department of Environmental Management. The Rhode Island
Department of Environmental Management is currently investigating
this issue to determine the magnitude of the problem and to
determine what if any actions need to be taken to deal with the
situation.
Comments from Ms. Mary Cerra
Vice President, Johnston Town Council
comment 1: Does the clean-up plan that is being proposed fit into
the state Master Plan approved by state wide planning?'
EPA Response: The state Master Plan is not a Applicable Relevant
and/or Appropriate Requirement (ARAR). The source control remedy
selected by EPA ("clean-up plan") is independent of the state
Master Plan. This comment was forwarded to the Rhode Island
Department of Environmental Management for their review.
Comment 2:
How safe is the plan?
EPA Response: EPA believes that all of the source control
alternatives evaluated, except the no action alternative, are
protective of human health and the environment. EPA believes that
of all the alternatives evaluated, the selected remedy achieves the
best balance when considering long- and short-term effectiveness,
reduction of toxicity, mobility and volume of contamination,
implementability and cost.
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Comment 3a:
How long will it take to complete?
EPA Response: The Feasibility study Report has estimated that the
construction of the remedy will be completed 5 years from the start
of design. See also EPA's response to Ms. Sandra Dennehy's comment
regarding capping of the existing landfill prior to Phase II and
Phase III being filled to capacity.
Comment 3b:
How effective will it be?
EPA Response: The primary goal for all of the alternatives
evaluated is to prevent groundwater that is contaminated above
drinking water standards from migrating beyond the perimeter of the
154 acre licensed landfill area. EPA believes that the selected
remedy will effectively achieve this goal.
Comment 4: During this process, what will happen to the trenches
and/or pools of liquid, etc.?
EPA Response: The Remedial Investigation identified a relatively
small area near the northeastern perimeter of the landfill where
large volumes of liquid industrial hazardous waste were disposed of
prior to 1980 by the previous owner in several trenches that were
excavated into the bedrock. This area was referred to as the "hot
spot" in the Proposed Plan. Pools of liquid no longer exist in
these trenches. The liquids have long since penetrated into the
underlying fractured bedrock leaving behind an approximately one
foot thick layer of a rubber like chemical sludge. Presently, the
trenches and chemical sludge are covered with about thirteen (13)
feet of septage sludge and additional fifteen (15) feet of landfill
debris and daily soil cover.
The capping component of the selected remedy covers the hot spot
area. The cap will prevent or minimize the infiltration of
precipitation through the hot spot area. The hot spot groundwater
extraction and treatment component of the selected remedy will
prevent the highly contaminated' groundwater in this area from
migrating beyond the landfill area.
Comment 5:
Are lined landfills leak-proof?
EPA Response: The existing 121 acre Phase I landfill area is not
lined. The 33 acre Phase II and III expansion will include a
bottom liner and a leachate diversion system between the Phase II
and Phase I areas. See also EPA' s response the Ms. Sandra
Dennehy's comment regarding capping of the existing landfill prior
to Phase II and Phase III being filled to capacity for more
information on the leachate diversion system. The liner for the
Phase II and III areas will be designed and constructed to meet the
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State and Federal performance criteria for municipal solid waste
liners.
Comment 6: Since the Town does not own the landfill, who will have
the foot the clean-up bills?
EPA Response: EPA and the current owner, RISWMC, are currently
discussing RISWMC's performance of the remedy. If the RISWMC does
not perform the work, EPA could use federal Superfund money to do
the work and/or search for other parties potentially responsible
for the environmental contamination.
Comments from Ms. Jennifer A. Champagne Martelli
state Representative - District 56
Comment 1: The preferred alternative OUl-5 does not include
removing the RIDEM cap on the existing 32 acres and replacing it
with the RCRA C cap. What short and long-term affects would occur
if the RCRA C cap is not used on the 32 acres?
EPA Response: Short-term effects refers to the likelihood of
adverse impacts on human health or the environment that may be
. posed during the construction and implementation of an alternative
until the specified goals are achieved. Long-term effectiveness
refers to the ability of an alternative to maintain reliable
protection of human health and the environment over time once the
remedial activities have been completed. EPA does not believe that
there would be any short-term benefits to removing the RIDEM cap
nor any significant long-term benefits.
Removing the existing 32 acres of RIDEM approved capping on the
side slopes and replacing it with the RCRA C cap proposed by EPA
for the side slopes will require bringing on-site a greater amount
of cap construction material, resulting in greater short-term
impacts on local traffic as well as greater increase in dust,
fugitive emissions, risk to workers, etc. for minimal benefit.
Based on information EPA has to date, we believe the existing 32
acres of RIDEM approved capping on the side slopes of the existing
landfill meets the performance criteria for hazardous waste caps
(RCRA C). That is, the existing 32 acre cap requires minimum
amount of maintenance; promotes drainage and minimizes erosion;
accommodates settling and subsidence of the landfill; and has a
permeability less than the permeability of the natural subsoils
present. Also, the EPA has no data to suggest that the existing 32
acre cap will not provide long-term minimization of the
infiltration of liquids through the closed landfill.
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comment 2: What short and long-term effects if OUl-8 and OUl-9 are
not completed?
EPA Response: The differences between EPAs selected remedy and
alternatives OUl-8 and 9 are that alternative OUl-8 and 9 would
require removing the 32 acres of RIDEM capping and replacing it
with EPA's selected cap design for the side slopes and treating the
chemical sludges in the hot spot area of the Site. EPA's selected
remedy, alternative OUl-5, will retain the 32 acres of RIDEM
capping and will not treat the chemical sludges in the hot spot
area. As discussed above, EPA does not believe that there would be
any short-term or significant long-term benefits to removing the
RIDEM cap. Although alternatives OUl-8 and 9 treat the chemical
sludges, EPA does not believe that this treatment will provide any
significant additional long-term effectiveness since this treatment
does nothing to address the major source of contamination at the
site, which is in the groundwater in fractured bedrock below the
chemical sludges. EPA believes that the capping provided by the
selected remedy, which covers the hot spot area will prevent or
minimize the infiltration of precipitation through this area. The
hot spot groundwater extraction and treatment component of the
selected remedy will prevent the highly contaminated groundwater in
this area from migrating beyond the landfill area.
Comment 3: If the RIDEM cap were replaced and/or the off-site
disposal of the hot spot chemical sludges were removed, your report
suggests that a tremendous amount of off-site trucking would occur.
What compensation do you suggest to the (Town of Johnston) host
community or the area residents for their exposure to the increase
trucking?
EPA Response: EPAs selected remedy results in less traffic impacts
than alternatives OUl-8 and 9 since it involves retaining the 32 .
acre cap and does not involve excavation of the chemical sludges.
The statute governing cleaning up Superfund sites, the
Comprehensive Envirommental Response, Copensation and Liability Act
(CERCLA) 40 CFR 6901, et. seq. does not require EPA to provide for
any compensation to the Town of Johnston or area residents for
increased traffic impacts during performance of the remedy.
Comment 4: What would the impact be on wetlands if you went
forward with the treatment of the groundwater in the southern area?
EPA Response: Extraction of large volumes of groundwater along the
southern perimeter of the landfill may significantly lower the
groundwater table in nearby wetlands. A significant lowering of
the water table in nearby wetland areas will adversely effect the
wetland vegetation and associated fauna which has become
established in these areas.
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Comment
treated?
5:
What effect short/ long
term
if
this area
is not
EPA Response: Extracting and treating groundwater from the
southern perimeter of the landfill in addition to extracting and
treating groundwater from the hot spot area may not provide any
significant additional long-term effectiveness. EPA believes that
the combination of hot spot groundwater extraction and treatment
and capping, provided by the selected remedy, will achieve the goal
of preventing groundwater with contaminant concentrations exceeding
drinking water standards from migrating beyond the boundary of the
licensed landfill. The reason for this is 1) hot spot groundwater
extraction and treatment should prevent the continued migration of
high levels of contamination currently existing at the hot spot;
and 2) the additional capping component will minimize infiltration
of precipitation into the landfill thereby effectively minimizing
any future migr~tion of contaminated groundwater caused by the
existing 121 acre landfill. The selected remedy also provides
long-term effectiveness since it contains groundwater close to what
is believed to be the major source of groundwater contamination at
the site.
Institutional controls on the use of groundwater in this area and
the availability of public water to surrounding residents will
prevent any likelihood of adverse impacts on human health until the
specified containment goals are achieved.
Comment 6: What proof can EPA provide that the new so-called state
of the art landfill, Phase II and III, will not produce the same or
similar chemical sludge that we are not cleaning up?
EPA Response: The disposal of liquid industrial wastes in trenches
excavated into bedrock in the hot spot area of the site prior to
1980 was the acti vi ty responsible for producing the existing
chemical sludges in that area. Existing Rhode Island solid waste
regulations prohibit this type of activity from taking place in any
of the phases at Central Landfill.
Comment 7: All nine Source Control Alternatives were examined and
are proposed by the EPA, I would like to know why is not one of the
alternatives to cease all landfill operations considering it' s
close proximity to the Reservoir?
EPA Response: As stated on page 8 of the February 1994 Proposed
Plan, the results of studies undertaken during the remedial
investigation found no evidence to suggest that contaminated
groundwater underneath the site is migr~ting to the scituate
Reservoir located about 2.5 miles west of the 121 acre landfill.
The studies did conclude that the Upper Simmons Reservoir, located.
about 1,200 feet southeast of the landfill, is the major receptor
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of groundwater which passes beneath the Central Landfill. The
studies also indicate that a small portion of the flow beneath the
landfill migrates to the Almy Reservoir, located about 2,400 feet
northeast of the landfill. The basic goal of the source control
remedy selected in this first operable unit is to prevent any
further effects from the 121 acre landfill to off-site areas,
including Upper Simmons and Almy Reservoirs.
Comment 8: I request a legal opinion as to what authority the EPA
posses to recommend the closure of the State Landfill operations in
the Town of Johnston. Further, in EPA's legal opinion, what body
is vested with the power; what body possesses the responsibility,
to recommend complete cessation of landfill operations in the Town
of Johnston.
EPA Response: Sections 7002 and 7003 of the Resource Conservation
and Recovery Act (RCRA), 42 U.S.C. ~~ 6972 and 6973, provide for
civil action in the event that a hazardous or solid waste facility
poses an imminent and substantial threat to the environment.
section 7003 provides for EPA to take action against the violator;
section 7002 provides for a citizens' suit. Based on the results
of the RIfFS performed for the first operable unit at this Site,
EPA believes that the Phase I area is the source of groundwater
contamination and has issued a Proposed Plan for remediating the
source including closing the Phase I area. At this time, EPA has
no evidence on which we could base a determination that Phases II
and III meet the criteria for issuing a Section 7003 order to close
these areas. Any citizen may of course pursue a section 7002
action.
In addition, all municipal solid waste landfills are subject to 40
CFR Part 258 regulations which govern construction, operation and
closure of municipal landfills. Phases II and III are subject to
Part 258 regulations. section 4005 of RCRA requires each state to
create a state permitting program to implement the Part 258
regulations. The State of Rhode Island has created a permitting
program and has applied for EPA approval of its program. Unless
and until EPA deems the State program inadequate, EPA has no
mechanism to enforce these regulations. If a state permitting
program is deemed inadequate by EPA, EPA has enforcement authority
to enforce the federal criteria. Further, EPA always retains its
authority under Section 7003 should an imminent and substantial
endangerment situation arise. Citizens may also seek enforcement
of the federal criteria, independent of any state enforcement
program through Section 7002 authority. The State is also able to
enforce its own permitting program in state court for violation of
the state criteria.
The Phase I area. of Central Landfill has been identified as a
Superfund hazardous waste landfill and was listed on the National
Priorities List in 1986. As such, activities in the Phase I area
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are governed by the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), 42 U.S.C. S 9601 et. sea.
Under CERCLA, Section 104(e) (3), EPA has the authority to enter any
site to determine the need for response action or the appropriate
response or to effectuate a response action. This Record of
Decision reflects EPA's site investigation and the remedial action
necessary at Central Landfill to protect human health, welfare and
the environment. As part of the remedial action, RCRA regulations
including closure of a hazardous waste landfill and groundwater
monitoring requirements are identified. These regulations must be
complied with when the remedy for the Phase I area is implemented.
Under CERCLA and the National Contingency Plan (NCP) 40 CFR Part
300 et. sea., its implementing regulations, EPA also has authority
to prohibit activities which interfere with its performance of a
response action, including the performance of studies, design,
construction and operation of a remedy. As of this date, EPA has
no reason to believe that the landfilling activities in Phases II
and III will interfere with the remedial action set out in this
Record of Decision.
Comments from Mr. Louis A. Perrotta, Town Council President
Town of Johnston, RI
Comment 1: If hazardous waste has and is flowing and polluting
wells, what is going to stop it from continuing and if the Cedar
swamp Brook, which flows to the Bay, is contaminated, what effects
does this have on the Bay?
EPA Response: The selected remedy is the first operable unit of a
two operable unit approach to remediation of the environmental
contamination caused by the Central Landfill site. The selected
remedy is a source control remedy. The purpose of the selected
source control remedy is to prevent or minimize the continued
effects of contamination within the 121 acre Phase I area on
groundwater quality. The second operable unit will address any
impacts to off-site areas, including Cedar Swamp Brook, caused by
contaminants that have already migrated from the Phase I area and
beyond the edge of the waste management area. During the second
operable unit, additional studies will be undertaken to better
characterize the extent of off-site contamination and to develop
and evaluate alternatives for remediation should it be required.
At this time, EPA has determined that Cedar Swamp Brook and Upper
Simmons Reservoir have received contamination from the site. What
effect, if any, on the Bay is not known at.this time. The studies
of Cedar swamp Brook and Upper Simmons Reservoir that will be
conducted during the second operable unit will provide additional
data to help EPA determine if there is an adverse impact to other
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bodies of water.
Comment 2: Would your program guarantee that wells further away
from the Cedar Swamp Brook and the Upper Simmons Reservoir be
protected?
EPA Response: The source control remedy selected in operable unit
one is intended to prevent or minimize the continued release of
contamination from the 121 acre Phase 1 area. Operable unit two
will investigate to what extent contaminated groundwater has
migrated from the site. As discussed in the RI and FS there are
many other potential sources of groundwater contamination in the
vicinity of the Central Landfill site. These other source areas
are being investigated by the RIDEM.
Comment 3:
Does EPA have the power to close the landfill?
EPA Response: See EPA's response number
Jennifer A. Champagne Martelli's comments.
8
to
Representative
Comments from Mr. Paul santilli
Resident, Johnston, RI
Comment 1: Why doesn't EPA do all the testing/sampling at the
landfill and have all the samples analyzed out of the State of
Rhode Island instead of splitting ten percent of the samples
collected by the RISWMC?
EPA Response: EPA has no reason to believe that the environmental
monitoring data reported by the RISWMC during the Remedial
Investigation was inaccurate or tampered with. As the commenter
indicated, EPA has split approximately 10% of the samples collected
by the RISWMC and ha~ the samples sent to laboratories selected by
the EPA. EPA compared the laboratory results of the split samples
with the results that the RISWMC obtained from their laboratory.
The comparison showed good correlation between the samples analyzed
by EPA and the samples analyzed by the laboratories selected by the
RISWMC.
Comment 2: Why doesn't EPA get involved with the Town in shutting
down the landfill?
EPA Response: See EPA's response number
Jennifer A. Champagne Martelli's comments:
8
to
Representative
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Comments from Mr. Kevin J. McNichols
Resident, Johnston, RI
Comment 1: What is the criteria for EPA assuming jurisdiction of
the landfill and if EPA doesn't have direct operational control,
what do we do to give you the direct operational control?
EPA Response: See EPA's response number
Jennifer A. Champagne Martelli's comments.
8
to
Representative
Comments from Mr. J Darrot Lynott,
Weston & sampson Engineers
P.E.
At the request and the authorization of the Mayor of Johnston, RI,
Mr. Ralph R. aRusso, a review of the Proposed Plan was completed by
Weston and Sampson Engineers. The following comments were received
in a letter to EPA dated March 9, 1994.
Comment 1: It is our understanding that the EPA has proposed, in
the Source Control Plan for the Central Landfill Superfund Site, to
cap 89-Acres of the landfill and extend the cap over that portion
of the 33 acre expansion that "piggy backs" the" existing unlined
landfill. If it is the intention of the EPA to delay closure of 89
acres of the landfill until the 33 acres expansion is capped the
flow of leachate through the so called "hot spots" will continue
unabated until such time as the expansion area is closed. It is
anticipated that phase II and III will continue operation until
2023. We recommend that the EPA complete a construction schedule
for the 89 acre closure and prepare an analysis of groundwater
contamination due to delayed closure.
EPA Response: Filling in the Phase II area started in March 1993.
The remaining capacity of the combined Phase II a~-: III areas is a
function of the filling rate. Based upon the April 1993 to April
1994 records, 597,000 tons were received, or and average filling
rate of 2,100 tons per day, 5 1/2 days per week. The estimated
capacity, based on the April 1993 to April 1994 data is 7.45 years
or a completion date of October 2000. This completion date was
estimated as follows:
Estimated Solid Waste Received
597,000 tons/year
1,100 lbs/yd3
Assumed Density
Volume of Solid Waste
1,085,454 yd3/year
272,500 yd3/year
Volume of Cover Material
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Total Volumetric Filling Rate
1,357,954 yd3/year
7,620,000 yd3
2,500,000 yd3
Phase II Volume Remaining
Phase III Volume
Total Volume of Phase II & III
10,120,000 yd3
Filling start Date of Phase II
April 1993
Total Life of Phases II and III
7.45 years
Estimated completion Date
October 2000
If the filling rate were to increase to an average of 3,000 tons
per day, the life expectancy would decrease to 5.2 years (i.e. June
1998).. If the filling rate decreased to an average of 1,200 tons
per day, the life expectancy would increase to 13 years (i.e. April
2006) .
Currently, 32 acres of the 121 acre Phase I area are capped with a
RIDEM approved single-barrier cap. The RIDEM cap is effectively
minimizing the infiltration of rain through these areas of the
Phase I area. The 33 acre Phase II and III expansion areas will
not impact the entire 121 acre Phase I area. The Phase II and III
areas, when filled to capacity, will overlap about 48.4 acres of
the western portion of the Phase I area. As the Phase II area is
filled, a impermeable barrier, termed the Leachate Diversion System
(LDS), is being placed between the Phase I and II area as a means
of diverting leachate away from the Phase I landfill. The LDS is
to be installed over each lift of solid waste placed in Phase II
prior to the successive lift being placed. The Rhode Island
Department of Environmental Management (RIDEM) has reviewed the LDS
and approved its use at the Central Landfill.
EPAs selected remedy requires placing a multi-layer cap directly
over those portions of the 121 acre Phase I area that have not
already been covered with the RIDEM cap and those portions which
will not be impacted by the Phase 11 and III landfilling activity.
This area a~ounts to about 40.6 acres. Capping of this area, which
includes the hot spot area, can start as soon as the design is
completed. The selected remedy also requires covering, with a
multi-layer cap, that portion of the Phase II and III expansion
area that overlies the western 48.4 acres of the Phase I area. The
design and construction schedule for the entire remedy, including
all capping, has been estimated in the Feasibility study Report to
be 5 years. If the Phase II and III area does not reach its design
capacity in time to allow completing construction of the cap over
that portion of the Phase II and III area overlying the western
48.4 acres of the Phase I area by the time estimated in the FS
Report, then EPA will require that RISWMC construct a liner
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directly over any part of the 48.4 Phase I acres not impacted at
that time by the Phase II and III area. The liner will prevent
rain from infiltrating through these parts of the Phase I landfill.
After the liner is completed, filling over the Phase I area can
resume. After the Phase I I and I I I area reaches capac i ty , the
multi-layer cap will be constructed over the portion of the Phase
II and III area that overlies the Phase I area. The design of the
liner will be included as part of the remedial design for the
remedy and all the design documents will be made available for
public review in the Site File at the Marion J. Mohr Library in
Johnston, Rhode Island. None of the other components of the
selected remedy will be impacted by the Phase II and III
activities.
Comment 2: By moving forward with an expansion which "piggy-backs"
on the existing unlined landfill the potential exists for a)
differential settlement on top of the existing landfill and b)
gross deformation of the liner on the side slope of the existing
landfill.
Differential Settlement is due to void spaces within the existing
landfill. Areas settle and consolidate at different rates causing
pipes laid at minimum slope for leachate collection to settle and
possibly break. The net effect is a buildup of leachate within the
landfill which will eventually flow through the existing unlined
landfill and potentially through "hot spots" identified by the EPA.
Deformation is due to settlement of the existing unlined landfill
and the weight of the new trash placed on the side slopes. Gross
deformation of the liner or clay can lead to rupture of the liner.
If this occurs, leachate may f low through the existing unlined'
landfill and potentially through "hot spots" identified by the EPA.
It is our request that the EPA provide documentation in support of
their proposed closure design and in particular on the. effects of
differential settlement and gross deformation of the lined
expansion.
EPA Response: EPA agrees that a potential exists for differential
settlement on top of the existing landfill and will need to be
considered during the detailed design of the cap. However, the
concern over possibly breaking leachate collection pipes in the cap'
is not valid since, as illustrated in Figure 4 of the Proposed
Plan, the proposed cap will employ a 12 inch thick drainage layer
consisting of a sand or sand/gravel mix instead of drainage pipes.
The cornmenter also raised "a concern over gross deformation of a
liner on the side slopes of the existing landfill and that the
gross deformation could lead to rupture of the liner, resulting in
the flow of leachate through the unlined landfill and potentially
through the "hot spot". A liner has not been constructed on the
side slopes as originally planned. The Rhode Island Department of
Environmental Management (RIDEM) approved the use of a Leachate
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Diversion System (LDS), instead of a liner, in January 1992. The
construction drawings for the LDS are dated January 1993. As
discussed previously, the LDS will be placed between the Phase I
and II area as a means of diverting leachate away from the Phase I
landfill. The LDS is to be installed over each lift of solid waste
placed in Phase II prior to the successive lift being placed. EPA
recommends that the commenter review the drawings for the LDS.
These drawings area available at EPA's office at 90 Canal Street in
Boston, MA. A copy should also be available at the RIDEM office at
291 Promenade Street, in Providence, RI.
Comments from Mr. Blake A. Martin
Groundwater Associates, Inc.
At the request and the authorization of the Mayor of Johnston, RI,
Mr. Ralph R. aRusso, a review of the Proposed Plan was completed by
Ground Water Associates, Inc. The following comments were received
in a letter to EPA dated March 11, 1994.
Comment 1: We understand that closure and capping of the Phase I
landfill will be delayed until the Phase II area is completed. Any
delays in the capping/closure program will undoubtedly leave open
faces at the existing landfill. Such open' areas will allow
rainfall infiltration and greatly enhance opportunities for
leachate generation. Our report of March, 1993 indicated that both
leachate generation and contaminant migration from the "hot spot"
had already caused significant impacts to ground water quality both
on-site and off-site. Also, additional leachate generation would
hinder efforts to monitor the effectiveness of any collection at
the hot spot. changes in groundwater quality due to leachate
generation versus changes caused by the collection system would be
difficult to discern.
EPA Response: The statement that closure and capping of the Phase
I landfill will be delayed until the Phase II area is completed is
not correct. EPAs selected remedy requires placing a multi-layer
cap directly over those portions of the 121 acre Phase I area that
have not already been covered with the RIDEM cap and those portions
which will not be impacted by the Phase II and III landfilling
activity. This area amounts to about 40.6 acres. Capping of this
area, which includes the hot spot area, can start as soon as the
design is completed. The selected remedy also requires covering,
with a multi-layer cap, that portion of the Phase II and III
expansion area that overlies the western 48.4 acres of the Phase I
area. The design and construction schedule for the entire remedy,
including all capping, has been estimated in the Feasibility study
Report to be 5 years from the start of design. If the Phase II and
III area does not reach its design capacity in time to allow
completing construction of the cap over that portion of the Phase
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II and III area overlying the western 48.4 acres of the Phase I
area by the time estimated in the FS Report, then EPA will require
that RISWMC construct a liner directly over any part of the 48.4
Phase I acres not impacted at that time by the Phase II and III
area. The liner will prevent rain from infiltrating through these
parts of the Phase I landfill. After the liner is completed,
filling over the Phase I area can resume. After the Phase II and
III area reaches capacity, the multi-layer cap will be constructed"
over the portion of the Phase II and III area that overlies the
Phase I area. The design of the liner will be included as part of
the remedial design for the remedy and all the design documents
will be made available for public review in the Site File at the
Marion J. Mohr Library in Johnston, Rhode Island. None of the
other components of the selected remedy will be impacted by the
Phase II and III activities.
EPA agrees that any delays in the capping/closure program will
leave "open" (un-capped) faces at the existing (Phase I) landfill
and that these open faces will allow rainfall infiltration and
leachate generation to continue. EPA also agrees that additional
leachate generation would hinder efforts to monitor the
effectiveness of collection or containment at the hot spot. The
changes or impacts to groundwater quality due to leachate
generation versus changes caused by the containment system would be
difficult to discern. These are the major reasons EPA will require
that the RISWMC construct the liner as discussed above if the Phase
II and III landfilling activities are not completed in time to
allow completing the cap construction by the time estimated in the
FS Report.
Comment 2: The second concern is related to capture and
containment of both the hot spot contamination, and contaminant
movement along the southern boundary of the landfill. Although the
EPA summary indicates that no risk reduction benefits can be gained
by capturing contaminated ground water beyond the hot spot area,
concentrations of VOC's and metals significantly exceeding state
and federal standards are found beyond the extent of the Phase I
landfill. In Ground Water Associates report of March, 1993, data
is presented showing the presence of dissolved thallium (54-457
ppb) and chlorobenzene (300-474 ppb) at elevated levels to the
south and southeast of the landfill (see GWA, 1993, pages 40-43).
without capture and containment of these contaminants of concern,
an elevated continued risk to human health and the environment can
be expected. Only options OUl-6, OUl-7, OUl-8, and OUl-9 address
this issue--not OUl-5.
options 7 through 9 are discounted due to their impacts on
wetlands. However, discharge of treated water on-site is a
possible alternative. Thus, the Source Control Plan should
consider the ability to maintain wetlands by on-site recharge.
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EPA Response: EPA is aware of the VOCs and metals contamination
(including chlorobenzene and thallium) in the groundwater beyond
the extent of the Phase I area. Most of the data refereed to in
Groundwater Associates March 1993 Report was collected as part of
the Operable Unit One Remedial Investigation performed by the
RISWMC under EPA direction and oversight. An analysis of this data
was part of EPA's remedy selection process. Many of the VOCs and
metals identified in the groundwater beyond the extent of the Phase
I area were identified as contaminants of concern in EPA's Risk
Assessment Report.
The commenter stated that, "without capture and containment of
these contaminants of concern, an elevated continued risk to human
health and the environment can be expected. Only options OU1-6,
OUl-7, OUl-8 and OUl-9 address this issue--not OUl-5." EPA agrees
that capture and containment of these contaminants of concern is
necessary to protect human health and the environment. However,
EPA does not agree that only options or alternatives OU1-6, 7, 8,
and 9 will be protective of human health and the environment. EPA
believes that of the nine alternatives evaluated in detail in the
Feasibility study Report, all of them, except the no action
alternative (OU1-1), are protective of human health and the
environment. Source control alternative OU1-5 was selected as the
remedy because EPA believes it provides the best balance in terms
of the nine evaluation criteria used by EPA. These criteria and a
summary of the evaluations were presented on pages 27 through 34 of
the Proposed Plan. In summary, EPA selected alternative OU1-5
because of its long-term effectiveness, ability to reduce toxicity,
mobility and volume of contaminants and was the most efficient in
light of implementability and cost concerns. EPA believes that the
combination of hot. spot groundwater extraction and treatment and.
capping provided by OU1-5 will be sufficient at containing
groundwater exceeding MCLs and non-zero MCLGs from migrating beyond
the compliance boundary, which in the case of Central Landfill is
the perimeter of the licensed landfill area. The reason for this
is 1) hot spot groundwater extraction and treatment should prevent
the continued migration of high levels of contamination currently
existing at the hot spot; and 2) the additional capping component
should minimize infiltration of precipitation into the landfill
thereby effectively minimizing any future migration of contaminated
groundwater caused by the existing 121 acre Phase I area.
The commenter also stated that options 7 through 9 were discounted
due to their impacts on wetlands. Although it is true that these
alternatives may impact nearby wetlands, and this was one of the
reasons for not selecting them, it was not the main reason for not
selecting them. Alternatives OU1-7, 8 and 9, which include
southern perimeter groundwater extraction and treatment in addition
to hot spot groundwater extraction and treatment, may not provide
any significant additional long-term effectiveness over the
selected remedy, OUl-5, which requires extraction and treatment of
groundwater from only the hot spot area. As stated previously, EPA
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believes that the combination of hot spot groundwater extraction
and treatment and capping provided by the selected remedy will be
sufficient at containing groundwater exceeding MCLs and non-zero
MCLGs from migrating beyond the compliance boundary. Alternatives
OU1-8 and 9 treat the chemical sludges in the hot spot area in
addition to capping and groundwater containment; however, treatment
of the chemical sludges will not provide any significant additional
long-term effectiveness since this treatment does not address the
DNAPLs in the fractured bedrock underlying the hot spot area.
DNAPLs have been identified as the major source of contamination at
the hot spot area. .
Comments from Mr. Ralph Perotta, special Counsel
to the Town of Johnston
Comment 1: The Source Control Study is deficient because it
to consider or even address or acknowledge that there will be
II and III landfills piggybacked on top of the Phase I site,
you're allegedly closing.
fails
Phase
which
EPA Response: . Mr. Perotta felt that the Proposed Plan was
def icient because it did not considered or even addressed or
acknowledged that the Phase II and III expansion will piggyback on
top of the Phase I area. EPA is very much aware that the Phase II
and III expan~ion piggybacks on the Phase I area. On page 13,
first full paragraph, of the Proposed Plan it states, "There are 33
acres of lined expansion areas designated as Phase II and III
which, when completed, will overlay the west slope of the Phase I
area. The proposed multi-layer cap will extend over that portion
of the expansion area that directly overlies the 121-acre Phase I
area." EPA agrees that this is an important issue and the Proposed
Plan may not have provided enough of a discussion on this issue.
EPA's proposed plans are only intended to provide a brief
description of the preferred alternative and the other alternatives
evaluated in the Feasibility Study Report. The issue is discussed
in more detail in the Record of Decision and in EPA's responses to
the remainder of the issues raised by Mr. Perotta.
Comment 2: Mr. Perotta presented a summary of the technical review
of the Proposed Plan performed by Weston & Sampson Engineers, Inc.
and Ground Water Associates, Inc. Mr. Perotta is concerned that:
1) Phase I would not be capped until Phase II is completed; 2)
differential settlement between the phase I and II areas and gross
deformation of the liner placed between the Phase I and II areas;
3) continued leachate generation in the Phase I area if capping is
not performed until the Phase II area is completed; and 4) the
proposed plan (OU1-S) will not prevent contamination from migrating.
beyond the southern landfill boundary.
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EPA Response: The concerns raised by Mr. Perotta are addressed in
EPA's responses to the comments rece i ved from Weston & Sampson
Engineers, Inc. and Ground Water Associates, Inc.
Comments from Ms. Eugenia Marks, Director for Issues
Audubon society of Rhode Island
Comment 1: I would like to emphasize Audubon's position that the
chemical sludge be removed from the hot spot in order to prevent
future groundwater contamination after the remedial treatment has
been completed. Because groundwater will be formed as
precipitation infiltrates land outside the capped landfill
footprint, groundwater will continue to come into contact with the
sludges dumped during the Silvestri Brothers operation of the area.
According to U. S. G. S. surficial geology maps there are glacial
deposits in the area which transmit groundwater easily. These area
the deposits which the Silvestri Brothers sold in their sand and
gravel operation. We also understand that the sludges were dumped
into open pits cut into the bedrock and fissures in the bedrock may
also serve in the transport of groundwater. General patterns of
groundwater movement would indicate that the groundwater moving
over and around the hot spot would eventually recharge the surface
water in Cedar Swamp Brook which flows into Simmonsville Reservoir.
We believe that the long-term health of the groundwater quality and
the surface water it recharges will be best served by removing the
hot spot sludges.
EPA Response: Th~ commenter believes that the chemical sludges
should be removed from the hot spot area in order to prevent future
groundwater contamination. During the mid to late 1970s large
volumes of liquid industrial wastes were disposed of in several
trenches which were excavated into bedrock in a small area (about
0.5 acres) of the Site, near the eastern perimeter of the existing
landfill. This area has been identified as the hot spot area. The
liquids disposed of have long since penetrated into the underlying
fractured bedrock leaving behind a chemical sludge. Results of
studies conducted during the Remedial Investigation in the hot spot
area indicates that the chemical sludges are of very low
permeabili ty, rubber like in consistency, located close to but
above the water table and are currently covered with about thirteen
(13) feet of septage sludge and an additional fifteen (15) feet of
landfill debris and daily soil cover. EPA believes that the major
source of contamination to the groundwater from the hot spot area
is not the residual chemical sludge but the liquids that have
penetrated into and remain in the underlying fractured bedrock,
below the water table. During the Remedial Investigation, Dense
Non-Aqueous Phase Liquids (DNAPLs) were found in the fractured
bedrock beneath the chemical" sludges.
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Alternative OUl-8 evaluated the in-situ treatment of the chemical
sludges in the hot spot area and alternative OUl-~ evaluated the
excavation and off-site disposal of the chemical sludges from the
hot spot area. Although alternatives OUl-8 and 9 would treat the
chemical sludg~s, EPA does not believe that this would provide any
significant gains in long-term effectiveness since this treatment
would do nothing to address the real source problem, which is below
the chemical sludges. EPA believes that the capping provided by
the selected remedy, which covers the hot spot area, will prevent
precipitation from contacting the chemical sludges and as stated
previously, the chemical sludges are above the groundwater table.
EPA believes that the hot spot groundwater extraction and treatment
component of the remedy will prevent the highly contaminated
groundwater in this area from migrating beyond the landfill and
that this containment provides the best available approach to
protecting groundwater quality and the surface water it recharges
to.
Comment 2: We ask that the proposed plan consider the long-term
possibilities for contamination of the Upper Simmonsville
Reservoir. We are concerned that erosion is occurring on the
existing grassed southeastern face of the landfill, contributing
not only to sedimentation of Cedar Swamp Brook and ultimately the
Upper Simmonsville Reservoir, but also contributing some
contaminants. Of particular concern would be the heavy metals
cadmiumj chromium, and mercury which may leach as organic acids
form in the refuse or acidified precipitation continues at current
pH levels if erosion compromises the RI OEM single cap barrier.
Our concern is for the health of f ish and any persons who may
consume them. Although the risk is low on a population scale, we
believe that this toxilogical pathway should be addressed. We .
understand that there are off-site studies continuing which will
provide data on which to base decisions. Nonetheless, the
treatment of the cap and the extraction of groundwater in the
proposed plan on which we comment have an impact on water quality
and fish health in the Upper Simmonsville and Almy Reservoirs.
EPA Response: The commenter raised a concern that erosion of the
RIDEM single barrier cap may occur and contribute to the
sedimentation of Cedar Swamp Brook and ultimately the Upper Simmons
Reservoir. The commenter was also concerned that if erosion
compromised the RIDEM cap, infiltration of precipitation through
the cap may leach heavy metals in the form of organic acids from
the refuse. EPA is aware that erosion of uncapped areas of the
landfill is occurring and that erosion of other areas of the 610
acre parcel owned by the RISWMC may also be eroding and
contributing to the sedimentation problem in the. Upper Simmons
Reservoir. However, erosion of the areas capped with the RIOEM
single barrier cap have been effectively controlled. A component
of EPA's remedy will cap the remainder of the Phase I area which
will control the erosion of these areas as well. EPA believes that
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the capping component of its remedy, which incorporates the
existing 32 acres of RIDEM single barrier capping, will provide for
long-term minimization of the infiltration of precipitation through
the landfill. The cap will be monitored and maintenance activities
will be performed as needed to ensure that the cap continues to
perform satisfactory over the years. One of the performance
criteria is to prevent erosion.
Comment 3: We ask that the possibility of extracting groundwater
from the southern landfill boundary be held as a contingency should
off-site studies indicate levels of concern.
EPA Response: The commenter requested that extracting groundwater
from the southern landfill boundary be held as a contingency should
off-site studies indicate levels of concern. The selected remedy,
OUl-5, is the first operable unit of at least a two operable unit
approach to remediation of the environmental contamination caused
by the Central Landfill Site. The selected remedy is a source
control remedy. The basic purpose of the selected source control
remedy is to prevent or minimize the continued effects of the 121
acre Phase I area, including the hot spot, on groundwater and
surface water quality. A monitoring program is included as part of
the remedy to. assure that the source control remedy performs as
required. The remedy may need adjustments or modifications if data
collected as part of the monitoring program warrants such
adjustments or modifications. Also, EPA will review the site at
least once every five years after the initiation of the remedy to
assure that the remedy continues to protect human health and the
environment.
The second operable unit will address any impacts to off-site areas
caused by contaminants that have already migrated from the Phase I
area and beyond the RISWMC property boundary. During the second
operable unit, additional studies will be undertaken to better
characterize the extent of off-site contamination and to develop
and evaluate alternatives for remediation should it be required.
Comment 4: We ask that consumption of fish be considered under
recreational fishing. Although I understand that standards for
metals and organics in f ish tissue are not set federally, some
states area creating their own standards.
EPA Response: The commenter requested that consumption of fish be
considered under recreational fishing. EPA currently plans on
evaluating this route of exposure during the operable unit two
studies.
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Comment 5: As an alternative, we suggest that additional
geomembrane be installed over the existing DEM cap 'on the
northeastern face of the landfill as well as assuring sufficient
coverage in the cove around the hot spot. Although water will not
collect and percolate through the slope in the volume that it does
on the cap because of erosion and the concentration of contaminants
in the hot spot area, we ask that the protection of an additional
layer be considered.
EPA Response: The multi-layer capping component of EPA's selected
source control alternative will meet the performance criteria for
capping hazardous waste landfills (RCRA C). Based on information
EPA has to date, we believe the existing 32 acres of RIDEM approved
capping, which will be integrated into the multi-layer cap, is
meeting the performance criteria for capping hazardous waste
landfills. That is, the existing 32 acre cap requires minimum
amount of maintenance; promotes drainage and minimizes erosion;
accommodates settling and subsidence of the landfill; and has a
permeability less than the permeability of the natural subsoils
present.. Also, the EPA has no data to suggest that the existing 32
acre cap will not provide long-term minimization of the
infiltration of liquids through the closed landfill. The existing
32 acre cap, as well as the new capping to be constructed, will be
monitored over time to ensure that it continues to meet the RCRA C
performance standards for the closure of a hazardous waste
landfill.
Comment 6:
treatment.
To what degree will the contaminants be removed during
EPA Response: The degree of treatment required for the groundwater
extracted from the hot spot area depends on the discharge option
selected. Two discharge options will be evaluated in detail during
the remedy design phase; 1.) on-site surface waters, and 2.) the
Cranston Waste Water Treatment Plant.
If discharge to on-site surface waters is the option selected, the
effluent of the on-site treatment system will meet the NPDES
provisions of the Clean Water Act, and those of the RIPDES program
if they are more stringent than the federal requirements.
Additionally, the Rhode Island Water Quality Standards and Water
Quality Regulations define the water quality antidegradation policy
of the state. The Rhode Island Water Quality standards are based
on Federal Ambient Water Quality criteria which set standards for
surface water quality for the protection of human health aquatic
life. Any state standards which are more stringent than federal
standards must be complied with if the surface water discharge
option is selected. If discharge to the Cranston Waste Water
Treatment Plant is the option selected, the effluent of the on-
. site treatment system will meet the Rhode Island Pretreatment
regulations for the Cranston POTW. This regulation adopts a state
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and local pretreatment
regulations.
system for wastewater
based on federal
Comments from Mr. Al Russo, state Representative
Town of Johnston
Comment 1: What if anything is going to be done to clean up the
upper and lower Simmons Reservoir? Is EPA going to dredge the
solids on the bottom of the pond and return the reservoirs to their
pristine state?
EPA Response: The selected remedy is the first operable unit of a
two operable unit approach to remediation of the environmental
contamination caused by the Central Landfill Superfund site. The
first operable unit will control the sources of contamination at
the site. Source control remedies prevent or minimize the
continued release of hazardous substances to the environment.
Source control alternatives rely on the prevention of exposure for
the protection of human health and the environment. The second
operable unit, currently underway, will address impacts to off-site
areas, including Upper and Lower Simmons Reservoir, caused by
contaminants that have already migrated from the site. During the
second operable unit, additional studies will be undertaken to
characterize the extent of off-site contamination and to develop
and evaluate alternatives for remediation should it be required.
As of this date, it is not known if EPA will require any remedial
action in Upper or Lower Simmons Reservoir. However, the RISWMC
has been ordered by the RIDEM to take corrective actions to restore
wetlands altered by the landfill operations. Dredging of the Upper
Simmons Reservoir is one of the planned activities under this State
Order.
Comment 2: Will the groundwater flowing from the landfill in a
southeasterly direction be monitored since it possesses a potential
risk to the health of the residents?
EPA Response: A component of the selected remedy requires long-
term monitoring of groundwater which will include monitoring of the
groundwater flowing from the landfill in a southeasterly direction.
Comment 3: What are the estimated contaminant concentrations that
groundwater would have flowing into the Upper Simmons Reservoir?
EPA Response: Estimates of the contaminant concentrations in
groundwater discharging to the Upper Simmons Reservoir were
presented in Volume I, section 9.60 and Volume II Table 9-5 of the
OUl RI Report. The estimates were based on current site
-------
conditions, i.e, the concentrations calculated did not account for
the effects of EPA's source control remedy. The data collected in
Upper Simmons Reservoir during the OU2 studies will allow EPA to
better evaluate the contaminant concentrations in the Upper Simmons
Reservoir.
Comment 4: What are the deed restrictions on the groundwater use
and land development on the property owned by the RISWMC?
EPA Response: Institutional controls shall ensure the long-term
integri ty of all the components of this source control remedy.
Deed restrictions and/or other controls shall prohibit any activity
at the site which would interfere with or compromise the landfill
cap, its related systems, the hot spot containment and treatment
system, or any other component of this source control remedy. Such
controls will also provide for EPA and RIDEM approval prior to the
commencement of any future activities at the site which may impact
the landfill cap, its related systems, or any other component of
this source control remedy. The institutional controls will also
prohibit the use of on-site groundwater as a drinking water source.
Comment 5: As to the long-term program of sampling and analysis of
groundwater, surface water and air, how often are you going to
test, how long will this testing continue and will the tests be on-
site or off-site?
EPA Response: Initially EPA will require that the sampling be
performed quarterly. The exact sampling locations have not been
determined yet. It is likely that sampling will be performed in
off-site areas as well as on-site areas. Sampling will continue
until it can be demonstrated that the source control remedy has
adequately performed for three consecutive years. .
Comment 6: What will become of the residue from the groundwater
treatment system?
EPA Response: Any residues generated from the treatment of
groundwater extracted from the hot spot area will be tested to
determine if it is hazardous or non-hazardous. If any residue is
hazardous, it will be disposed of at an approved off-site hazardous
waste facility. If it is non-hazardous, on-site disposal may be an
option.
Comment 7: Why was the preferred plan
alternative OUl-9?
(OUl-5)
selected over
EPA Response: Alternative OUl-9 evaluated the excavation and off-
site disposal of the chemical sludges from the hot spot area.
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Although alternatives OUl-9 would remove the chemical sludges, EPA
does not believe that this would provide any significant gains in
protection of human health and long-term effectiveness since the
excavation of the chemical sludges would do nothing to address the
real source problem, which is below the chemical sludges. EPA
believes that the capping provided. by the selected remedy, which
covers the hot spot area, will prevent precipitation from
contacting the chemical sludges. EPA believes that the hot spot
groundwater extraction and treatment component of the remedy will
prevent the highly contaminated groundwater in this area from
migrating beyond the landfill and that this containment provides
the best available approach to protecting groundwater quality and
the surface water it recharges to. See also EPA's response number
1 to comments submitted by Ms. Eugina Marks, Director of issues,
Audubon Society of Rhode Island.
Comments from Mr. Rocco Mariorenzi, President
Rotary Drive Association, Town of Johnston
Comment 1: Mr. Mariorenzi is concerned about the bacterial level
in surface water in the vicinity of Rotary Drive which has been
found to be as high as 230,000 over 230,000. Mr, Mariorenzi
believes that the bacterial contamination may be coming from the
Central Landfill. Mr. Mariorenzi requests an explanation of the
significance of the bacteria count. What kind of bacteria is it,
where is it corning from and what can EPA do about it?
EPA Response:
Department of
, response.
EPA has forwarded this comment to the Rhode Island
Environmental Management for their review and
Comments from Ms. Karen Torti
Resident, Johnston, RI
Comment 1: What type of fill will be used in the preferred plan,
where will the fill be purchased, will the fill be utilized from
RISWMC property, if so, what portion of the property will this fill
be utilized from?
EPA Response: If any fill is needed the design will specify the
requirements for the fill. Material from RISWMC property may be
used if it meets the design requirements.
-------
Comment 2: Ms. Torti expressed concern over the impacts of the
Phase II and III areas and the potential that another problem like
the hot spot is being created. Ms. Torti also stated that the
liner system for the Phase II and II areas according to Hazardous
Newsletter, only lasts approximately 13 days and the leachate
collection system will only last up to 2 years.
EPA Response: See EPA's response to comment number 6 submitted by
State Representative Jennifer A. Champagne Martelli.
Comment 3: If a problem ever existed at the scituate Reservoir,
what would EPA's reaction be and what type of process would you use
to remediate that problem? Who will accept the liability if a
liability does occur?
EPA Response: The primary goal of the selected source control
remedy is to prevent or minimize the continued effects of
contamination from the site on groundwater quality. As the
commenter indicated, results of the studies undertaken during the
Remedial Investigation found no evidence to suggest that
contaminated groundwater from the Site is migrating to the scituate
Reservoir. A component of the selected remedy requires long-term
monitoring of groundwater. If data collected during the monitoring
program, or other evidence obtained by EPA in the future, were to
indicate that contaminated groundwater from the Central Landfill
superfund site was migrating to the Scituate Reservoir, the goal of
the source control remedy is not being met and EPA would require
that the RISWMC take measures to stop the migration from the site.
Comment 4: Has the preferred process (UVjoxidation) been used in
any Superfund site? How long has the life of the process been?
Will the process have an odor? will the process have any air
emissions, if so, will the air quality of the residents in the area
be affected?
EPA Response: EPA, New England Division, is currently planning on
using the UV jOxidation system at eight Superfund sites and is
currently using the system at three Superfund sites. At one of
these sites the system has been successfully operating for about
1.5 years. EPA does not anticipate any odor or emissions problems
associated with the UV/Oxidation system. A UV/Oxidation pilot
study will be performed at the Site be fore full scale operations
begin to ensure that air emissions and odor are not a problem.
-------
APPENDIX E
RECORD OF DECISION
CENTRAL LANDFILL
-------
Central Landfill
NPL Site Administrative Record
Index
Compiled: February 4, 1994
Prepared for
Region I
Waste Management Division
-------
Introduction
This document is the Index to the Initial Administrative Record
for the Central Landfill National priorities List (NPL) .site.
Section I of the Index cites site-specific documents and Section
II cites guidance documents used by EPA staff in selecting a
response action at the site.
The Administrative Record is available for public review at the
EPA Region I's Records Center, 90 Canal st., Boston, Massachusetts
(617-573-5729), and at Marion J. Mohr Memorial Library, 1 Memorial
Avenue, Johnston, Rhode Island 02929. Questions concerning the
Administrative Record should be addressed to the EPA Region I site
manager. Additional/Supplemental volumes may be added to this
Administrative Record.
This index contains Confidential documents that are available only
for judicial review.
The Administrative Record is required by the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA),
as amended by the Superfund Amendments and Reauthorization Act
(SARA) .
-------
Volume I
Central Landfill NPL site
Administrative Record
Table of Contents
1.0
Pre-Remedial
1.2
3.0
Remedial Investigation (RI)
Preliminary Assessment
3.1
3.2
Volume II
3.4
3.6
volume III
3.6
Volume IV
3.6
Volume V
3.7
Volume VI
3.7
Volume VII
3.9
3.10
Correspondence
sampling and Analysis Data
Interim Deliverables
Remedial Investigation (RI) Reports
Remedial Investigation (RI) Reports (cont'd.)
Remedial Investigation (RI) Reports (cont'd.)
Work Plans and Progress Reports
Work Plans and Progress Reports (cont'd.)
Health Assessments
Endangerment Assessments
4.0
Feasibility study (FS)
4.2
4.4
4.6
Sampling and Analysis Data
Interim Deliverables
Feasibility Study (FS) Reports
-------
central Landfill NPL site
Administrative Record
Table of Contents
Volume VIII
4.6
4.9
Feasibility Study (FS) Reports (cont'd.)
Proposed Plans for Selected Remedial Action
-5.0
Record of Decision (ROD)
5.2
Applicable or Relevant and Appropriate
Requirements (ARARS)
9.0
State Coordination
9.1
Correspondence
10.0 Enforcement
10.3
10.7
State and Local Enforcement Records
EPA Administrative Orders
Volume IX
13.0 Community Relations
13.1
13.5
Correspondence
Fact Sheets
16.0 Natural Resource Trustee
16.1 Correspondence
17.0 site Management Records
17.7
17.8
Reference Documents
state and Local Technical Records
Administrative Record Index
-------
Section I
-------
1.0
3.0
ADMINISTRATIVE RECORD INDEX
for the
Central Landfill NPL site
Pre-Remedial
1.2
Preliminary Assessment
1.
"Potential Hazardous Waste site Identification and
Preliminary Assessment," EPA Region I
(April 15, 1982).
Remedial Investigation (RI)
3.1
Correspondence
1.
Letter from John P. Hartley, Goldberg-Zoino &
Associates, Inc. to Kenneth Wenger, EPA Region I
(April 6,1987). Concerning comments and questions
relating to review of residential well data.
Attachments cited in entry number 2 may be viewed by
appointment only, at the EPA Region I Records Center,
Boston, Massachusetts.
2.
. Letter from Jeffrey Girard, Rhode Island Solid
Waste Management corporation to John Quinn, state
of Rhode Island Division of Land Resources
(May 20, 1987). Concerning the attached:
A. Project Location Plan.
B. Well Location Plan.
C. Well Detail (Drawing No. 833419.3).
D. Slotted PVC Pipe Detail (Drawing No.
833419.4) .
3.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management corporation to Ronald Lee,
State of Rhode Island Depattment of Health {August
11, 1987). concerning a request for information
associated with residential well sampling data.
4.
Memorandum from Julie A. Serowik, Rhode Island
Solid Waste Management corporation to Ronald
Gagnon, State of Rhode Island Department of
Environmental Management, Richard C. Boynton, EPA
Region I, Town of Johnston (February 15, 1991).
Concerning notification of .sampling rounds.
-------
9.
10.
11.
5.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Ronald Gagnon,
State of Rhode Island Department of Environmental
Management (March 18, 1991). Concerning
explanation of the attached "Table of Locations,
Elevations, and Current Status of Wells and
Borings."
6.
Letter from Richard C. Boynton, EPA Region I to
Thomas E. Wright, Rhode Island Solid Waste
Management Corporation (April 24, 1991).
Concerning notification that James M. Brown will be
the EPA Remedial Project Manager for the site.
7.
Letter from Dennis P. aRusso, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (May 3, 1991). Concerning decommissioning
of well WE87-1. With attached:
A. Procedures for decommissioning monitoring
wells.
B.
Site Plan.
8.
Letter from Judith S. McCabe, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (May 7, 1991). Concerning
results of the April 30, 1991 meeting on the Phase
II Expansion Area.
Letter from John P. Hartley, GZA GeoEnvironmental,
Inc. to'James M. Brown, EPA Region I
(May 14, 1991). Concerning explanation of the
attached preliminary sampling schedule.
Letter from James H. Doorley III, Rhode Island
Solid Waste Management Corporation to James M.
Brown, EPA Region I (May 22, 1991). Concerning
plans to landfill Interim Area 3.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (May 30, 1991). Concerning notification
that deep-well drilling will commence qn
June 10, 1991.
-------
12.
13.
14.
15.
16.
17.
18.
19.
Letter "from Judith S. McCabe, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (June 3, 1991). Concerning
explanation of the attached Memorandum Dated"
October 3, 1988 from Susan B. Kiernan and Sofia
Bobiak, State of Rhode Island Department of
Environmental Management to Robert L. Bendick,
State of Rhode Island Department of Environmental
Management.
Letter from James M. Brown, EPA Region I to Julie
A. Jaglowski, Rhode Island Solid Waste Management
Corporation (June 6, 1991). Concerning proposed
casing and well grout for deep wells in HWDA-2.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (June 14, 1991). Concerning
decommissioning of Monitoring Well WE87-1 a & b.
Trip Report on a Visit to the Central Landfill
site, James M. Brown, EPA Region I, Dennis P.
aRusso and Julie A. Jaglowski, Rhode Island Solid
Waste Management corporation (June 18, 1991).
Concerning drilling of well ML6.
Letter from Julie A. Jaglowski, Rhode
Waste Management Corporation to James
Region I (June 18, 1991). Concerning
schedule for deep-well drilling.
Island Solid
M. Brown, EPA
the revised
Letter from James M. Brown, EPA Region I to Jeff
Newman, State of Rhode Island Office of the Speaker
(July 1, 1991). concerning transmittal of the
attached "RIfFS Status Report -- June 1991. II
Letter from James M. Brown, EPA Region I to
Joseph Ignazio, u.S. Army Corps of Engineers
(July 8, 1991). concerning a response to the
attached June 13, 1991 letter regarding site
activities.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA.
Region I (July 18, 1991). concerning the attached
list of documents pertaining to the RIfFS.
-------
24.
25.
26.
27.
20.
Letter from Julie A. Jaglowski Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (July 23, 1991). Concerning confirmation
of the July 29, 1991 RWS meeting.
21.
Letter from James M. Brown, EPA Region I to Jeffrey
Girard, Rhode Island Solid Waste Management
Corporation (July 30, 1991). Concerning rock
excavation in Phase II and III of the site and the
attached Letter Dated November 24, 1987 from
Kenneth Wenger, EPA Region I to Jeffrey Girard,
Rhode Island Solid Waste Management Corporation.
22.
Letter from James M. Brown, EPA Region I to-Julie
A. Jaglowski, Rhode Island Solid Waste Management
Corporation (August 2, 1991). Concerning summary
of the July 29, 1991 meeting.
23.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to Ronald Gagnon,
State of Rhode Island Department of Environmental
Management (August 6, 1991). Concerning requests
for new sampling wells. with attached:
A.
Proposed Location Plan.
B.
Location Plan and Boring Logs for B-1
and WE 87-13.
Letter from James M. Brown, EPA Region I to Dennis
P. aRusso, Rhode Island Solid Waste Management
Corporation (August 16, 1991). Concerning a
revised schedule for completion of the RIfFS.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (September 5, 199 1). Concerning
agreement with the revised schedule for completion
of RIfFS documents.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (September 23, 1991). Concerning
transmittal of the attached field summary for the
decommissioning of MW-D and the GZ88 series wells.
Letter from Julie A. Jaglowski,
Waste Management Corporation to
Region I (September 25, 1991).
confirmation of the October 15,
Rhode Island Solid
James M. Brown, EPA
Concerning
1991 meeting.
-------
28.
29.
30.
31.
32.
33.
34.
35.
Letter from Richard C. Boynton, EPA Region I to
Dennis P. aRusso, Rhode Island Solid Waste
Management Corporation (October 10, 1991).
Concerning the revised schedule for the primary
RIfFS deliverables.
Letter from Dennis P. aRusso, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (October 18, 1991). Concerning a request
for EPA to release water quality results from the
attached list of residential wells that Rhode
Island Solid Waste Management corporation now has
title to.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (December 3, 1991). Concerning meeting
scheduled for December 17, 1991.
Letter Report from Thomas E. Billups, David R.
Carchedi, and Michael A. Powers, GZA
GeoEnvironmental, Inc. to Michael E. Lavallee,
Rhode Island Solid Waste Management Corporation
(December 30, 1991). Concerning final report of
blast monitoring activities.
Letter from Michael E. Lavallee, Rhode Island Solid
Waste Management corporation to James M. Brown, EPA
Region I (January 3, 1992). Concerning transmittal
of the Blast Monitoring Final Report, GZA
GeoEnvironmental, Inc. for comment.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (February 4, 1992). concerning
construction of a Wests ide Leachate Collection
System and the request that EPA provide opinion on
whether Resources Conservation and Recovery Act
(RCRA) will apply.
Letter from Russell J. Morgan and Michael A.
Powers, GZA GeoEnvironmental, Inc. to James M.
Brown, EPA Region I (February 11, 1992). concerning
deliverable schedules and RIfFS timeline.
Letter from Richard C. Boynton, EPA Region I to
Terrence Gray," State of Rhode Island Department of
Environmental Management (March 18, 1992).
Concerning proposed dredging of Cedar Swamp Brook
and Upper Simmons Reservoir.
-------
3.2
39.
40.
36.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (April 14, 1992). Concerning blast
monitoring at the site.
37.
Letter Report from Steven J. Simpson, Thomas E.
Billups, and Michael A. Powers, GZA
GeoEnvironmental, Inc. to Julie A. Jaglowski, Rhode
Island Solid Waste Management Corporation
(June 29, 1992). Concerning final report of blast
monitoring activities.
38.
Letter from Edward A. Summerly and Michael A.
Powers, GZA GeoEnvironmental, Inc. to James M.
Brown, EPA Region I (January 29, 1993). Concerning
a request for an extension of submittal of the
final Remedial Investigation Report.
Letter from Dennis P. aRusso, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (February 16, 1993). Concerning a request
for an extension of submittal of the final Remedial
Investigation Report and the Feasibility Study
Report.
Letter from Dennis P. aRusso, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (May 4, 1993). Concerning the release of
information in the March 1993 Remedial
Investigation Report.
sampling and Analysis Data
The Work Plan referenced in entry number 1 has been
amended by subsequent_Progress Reports cited in 3.7 Work
Plans and Progress Reports.
1.
2.
3.
Cross-Reference: "Revised Proposal for Sampling,
Analysis, Monitoring and Reporting of Conditions at
the Central Landfill," Rhode Island Solid Waste
Management Corporation (February 1985) [Filed and
cited as attachment A to entry number 1 in 10.7 EPA
Administrative Orders].
"Project Operations Plan for Residential Well
Sampling, Camp Dresser & McKee Inc. (May 1985).
Letter from John Drake, Camp Dresser & McKee to
Kenneth Wenger, EPA Region I (June 3, 1987).
Concerning the attached:
-------
4.
A.
Residential Well Findings from July 23-25,
1985 sampling.
B.
Location Map.
C.
Hazardous Substance List and Detection Limits
for Water.
D.
Residential Well Sampling Cross Reference List
Residential Well sampling Cross Reference List
is withheld as CONFIDENTIAL.
Letter from James E. Bedell, Geo Tech Environmental
Services Inc. to Kenneth Wenger, EPA Region I
(July 22, 1987). Concerning comments on monitoring
well installations.
Maps associated with entry number 5 are reproduced in
the March 1993 Remedial Investigation Reports filed as
entries 1 through 7 in 3.6 Remedial Investigation (RI)
Reports.
5.
"Fracture Trace/Geophysical Investigation of
Central Landfill Site, Johnston, Rhode Island,
"University of Rhode Island and Geotech Enterprises
Inc. for Goldberg-Zoino & Associates, Inc.
(August 1987).
6.
Letter from James E. Bedell, Geo Tech Environmental
Services Inc. to David Del sesto, We Are The
Endangered Residents (August 28, 1987). Concerning'
review of data sets from June 9, 1987 sampling.
The sampling plans cited in number 7 may be.reviewed, by
appointment only, at the EPA Region I Records Center,
Boston, Massachusetts.
7.
Memorandum from Julie A. Jaglowski, Rhode Island
Solid Waste Management corporation to Ronald
Gagnon, state of Rhode Island Department of
Environmental Management (November 19, 1991).
Concerning transmittal of the May 1990 Sampling
Round Report and the second Sampling Round Report.
8.
"community Health Services Office of Health
Engineering Summary of Private Wells - Beryllium -
Town of Johnston, "Rhode Island Department of
Health.
9.
"Community Health Services Office of Health
Engineering Geology Ground Water - Town of
Johnston, "Rhode Island Department of Health.
-------
3.4
3.6
Interim Deliverables
1.
"Central Landfill Health and Safety Plan,"
Goldberg-Zoino & Associates, Inc. (June 1987).
2 .
Letter Report from Thomas E. Billups, et al, GZA
GeoEnvironmental, Inc. to Michael Lavallee, Rhode
Island Solid Waste Management Corporation (December
30, 1991). Concerning results of GZA's blast
monitoring program for rock excavation in the Phase
II and III expansion areas.
Remedial Investigation (RI) Reports
Reports
1.
"Remedial Investigation Report - Operable Unit I -
Volume I of VII," GZA GeoEnvironmental, Inc.
(March 1993).
The oversize drawings associated with number 2 may be
reviewed, by appointment only, at the EPA Region I
Records Center, Boston, Massachusetts.
3 .
4.
5.
6.
7.
2.
"Remedial Investigation Report - Operable Unit I -
Volume II of VII, "GZA GeoEnvironmental, Inc.
(March 1993).
"Remedial Investigation Report - Operable Unit I -
Volume III of VII, "GZA GeoEnvironmental, Inc.
(March 1993).
"Remedial Investigation Report - Operable Unit I -
Volume IV of VII," GZA GeoEnvironmental, Inc.
(March 1993).
"Remedial Investigation Report - Operable Unit I -
Volume V of VII, "GZA GeoEnvironmental, Inc.
(March 1993).
"Remedial Investigation Report - Operable Unit I -
Volume VI of VII, "GZA GeoEnvironmental, Inc.
(March 1993).
"Remedial Investigation Report - Operable unit I -
Volume VII of VII, "GZA GeoEnvironmental, Inc.
(March 1993).
-------
Comments
3.7
8.
Letter from Judith S. Graham, state of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (May 27, 1993). Concerning
approval of the March 1993 "Remedial Investigation
Report - Operable unit I, "GZA GeoEnvironmental,
Inc.
9 .
Letter from Richard C. Boynton, EPA Region I to
Thomas E. Wright, Rhode Island Solid Waste
Management Corporation (June 8, 1993). concerning
approval of the March 1993 "Remedial Investigation
Report Operable unit I, "GZA GeoEnvironmental, Inc.
Work Plans and Progress Reports
Progress Reports
1.
Letter Report from David D. Dorocz, Rhode Island
Solid Waste Management Corporation to Kenneth
Wenger, EPA Region I (May 9, 1987). Concerning the
May 10, 1987 progress report.
2 .
Letter from David D. Dorocz, Rhode Island Solid
Waste Management corporation to Kenneth Wenger,
EPA Region I (June 10, 1987) with attached Progress
Report 1, Goldberg-Zoino & Associates, Inc.
3.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management corporation to Kenneth Wenger, EPA
Region I (July 14, 1987) with attached Progress
Report 2, Goldberg-zoino & Associates, Inc.
4.
Letter from John P. Hartley, GOldberg-zoino &
Associates, Inc. to David D. Dorocz, Rhode Island
Solid Waste Management corporation (August 13,
1987). concerning Progress Report 3.
5.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger, EPA
Region I (September 16, 1987) with attached
Progress Report 4, GOldberg-Zoino & Associates,
Inc.
6.
Letter from John P. Hartley, Goldberg-Zoino &
Associates, Inc. to David D. Dorocz, Rhode
Island Solid Waste Management corporation
(October 15, 1987). Concerning Progress Report 5.
-------
7.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger, EPA
Region I (November 17, 1987) with attached Progress
Report 6, Goldberg-Zoino & Associates, Inc.
8.
Letter from John P. Hartley, Goldberg-Zoino &
Associates, Inc. to David D. Dorocz, Rhode Island
Solid Waste Manage~ent Corporation (December 21,
1987). Concerning Progress Report 7.
The oversize drawing associated with number 9 may be
reviewed, by appointment only, at the EPA Region I
Records Center, Boston, Massachusetts.
9.
10.
11.
12.
13.
14.
15.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger, EPA
Region I (January 22, 1988) with attached Progress
Report 8, Goldberg-Zoino & Associates, Inc.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger, EPA
Region I (February 12, 1988) with attached Progress
Report 9, Goldberg-Zoino & Associates, Inc.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger,
EPA Region I (March 15, 1988) with attached
Progress Report 10, Goldberg-Zoino & Associates,
Inc.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Kenneth Wenger, EPA
Region I (April 19, 1988) with attached
"Environmental Sampling Program, II Goldberg-Zoino &
Associates, Inc. (March 1988). Concerning Progress
Report 11.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management corporation to Wayne RObinson, EPA
Region I (May 19, 1988) with attached Progress
Report 12, Goldberg-Zoino & Associates, Inc.
Letter from John P. Hartley and Edward A. Summerly,
GOldberg-Zoino & Associates, Inc. to David D.
Dorocz, Rhode Island Solid Waste Management
Corporation (June 7, 1988). Concerning Progress
Report 13.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (July 14, 1988) with attached Progress
Report 14, Goldberg-Zoino & Associates, Inc.
-------
16.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (August 10, 1988) with attached Progress
Report 15, Goldberg-Zoino & Associates, Inc.
17.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (September 19, 1988) with attached
Progress Report 16, Goldberg-Zoino & Associates,
Inc.
18.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Wayne RObinson, EPA
Region I (October 14, 1988) with attached Progress
Report 17, Goldberg-Zoino & Associates, Inc.
19.
Letter from David D. Dorocz, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (December 1, 1988) with attached Progress
Report 18, Goldberg-Zoino & Associates, Inc. .
20.
Letter from Ronald T. DelFino, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (December 22, 1988) with attached Progress
Report 19, Goldberg-Zoino & Associates, Inc.
21.
Letter from John P. Hartley and. Edward A. Summerly,
. Goldberg-Zoino & Associates, Inc. to David D.
Dorocz, Rhode Island Solid Waste Management
Corporation (January 13, 1989). Concerning
Progress Report 20.
22.
Letter from Julie A. serowik, Rhode Island Solid
Waste Management corporation to Wayne Robinson, EPA
Region I (February 10, 1989) with attached Progress
Report 21, GOldberg-Zoino & Associates, Inc.
23.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (March 15, 1989) with attached Progress
Report 22, Goldberg-Zoino & Associates, Inc.
24.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management corporation to Wayne Robinson, EPA
Region I (April 17, 1989) with attached Progress
Report 23, Goldberg-Zoino & Associates, Inc.
25.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management corporation to Wayne Robinson, EPA
Region I (May 12, 1989) with attached Progress
Report 24, Goldberg-Zoino & Associates1 Inc.
-------
34.
35.
26.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (June 20, 1989) with attached Progress
Report 25, GOldberg-Zoino & Associates, Inc.
27.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (July 13, 1989) with attached Progress.
Report 26, Goldberg-Zoino & Associates, Inc.
28.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (August 28, 1989) with attached Progress
Report 27, Goldberg-Zoino & Associates, Inc.
29.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (September 20, 1989) with attached
Progress Report 28, GOldberg-Zoino & Associates,
Inc.
30.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (October 17, 1989) with attached Progress
Report 29, GOldberg-Zoino & Associates, Inc.
31.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (November 17, 1989) with attached Progress
Report 30, GOldberg-Zoino & Associates, Inc.
32.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
. Region I (December 29, 1989) with attached Progress
Report 31, Goldberg-Zoino & Associates, Inc.
33.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to Wayne Robinson, EPA
Region I (January 26, 1990) with attached Progress
Report 32, Goldberg-Zoino & Associates, Inc.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management corporation to Wayne Robinson, EPA
Region I (March 30, 1990) with attached Progress
Report 33, Goldberg-Zoino & Associates, Inc.
"Central Landfill RIfFS Progress Report No. 34,"
Goldberg-Zoino & Associates, Inc. for Rhode Island
Solid Waste Management Corporation (August 1990).
-------
36.
37.
38.
39.
40.
41.
42.
43.
"Progress Report No. 35, Central Landfill RIfFS,"
Goldberg-Zoino & Associates, Inc. for Rhode Island
Solid Waste Management corporation (October 1990).
Response dated February 5, 1991 from Edward A.
Summerly, John P. Hartley, and Frank W. Clark for
Michael A. Powers to the January 7, 1991 Comments
from EPA Region I.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management corporation to Richard C. Boynton,
EPA Region I (February 18, 1991). Concerning
transmittal of responses to comments on Progress
Report No. 35.
Letter from John P. Hartley, GZA GeoEnvironmental,
Inc. to Julie A. Serowik, Rhode Island Solid Waste
Management Corporation (March 14, 199 1).
Concerning Progress Report 36.
Letter from Julie A. Serowik, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (May 1, 1991) with attached Progress
Report 37, GZA GeoEnvironmental, Inc.
"Central Landfill RIfFS Progress Report No. 38," GZA
GeoEnvironmental, Inc. for Rhode Island Solid Waste
Management corporation (July 1991).
"Central Landfill RIfFS Progress Report No. 39," GZA
GeoEnvironmental, Inc. for Rhode Island Solid Waste
Management Corporation (August 1991).
"Central Landfill RIfFS Progress Report No. 40,
"GZA GeoEnvironmental, Inc. for Rhode Island Solid
Waste Management corporation (November 1991).
Work Plans
44. "Technical Specifications for drilling at the
Central Landfill," GOldberg-Zoino & Associates,
Inc. for Rhode Island Solid Waste Management
corporation (June 1987).
45.
46.
"Tank Removal Project Work Plan," Goldberg-Zoino &
Associates, Inc. for Rhode Island Solid Waste
Management Corporation (August 1988).
"Project Work Plan Abandoned Drum
Characterization," Goldberg-Zoino
Inc. for Rhode Island Solid Waste
Corporation (September 1988).
& Associates,
Management
-------
3.9
50.
47.
"Project Work Plan Multi-Level Well Sampling,"
GOldberg-Zoino & Associates, Inc. for Rhode Island
Solid Waste Management Corporation (September
1988) ."
48.
Letter Report from Thomas E. Billups, David R.
Carchedi, and Cheryl Marfuo for Edward A. Summerly,
GZA GeoEnvironmental, Inc. to Michael E. Lavallee,
Rhode Island Solid Waste Management Corporation
(September 11, 1991). Concerning the Blast
Monitoring Work Plan. .
49.
Letter from Michael E. Lavallee, Rhode Island Solid
Waste Management Corporation to James M. Brown, EPA
Region I (October 3, 1991). Concerning transmittal
of the Blast Monitoring Work Plan - Revision 1,
GZA GeoEnvironmental, Inc. for comment.
Letter Report from Thomas E. Billups, David R.
Carchedi, and Edward A. Summerly, GZA
GeoEnvironmental, Inc. to Michael E. Lavallee,
Rhode Island Solid Waste Management Corporation
(February 4, 1992). Concerning the Blast
.Monitoring Work Plan.
51.
Comments on Work Plans
52.
.Comments Dated September 27,1991 from James M.
Brown, EPA Region I on the September 11, 1991 Letter
Report from Thomas E. Billups, David R. Carchedi,
and Cheryl Marfuo for Edward A. Summerly, GZA
GeoEnvironmental, Inc. to Michael E. Lavallee, Rhode
Island Solid Waste Management Corporation.
Comments Dated October 9, 1991 from James M. Brown,
EPA Region I on the Blast Monitoring Work Plan
Revision 1.
Health Assessments
1.
Letter from Louise A. House, Department of Health
and Human Services Agency for Toxic Substances and
Disease Registry to James NC Brown, EPA Region I
(September 3, 1992). Concerning transmittal of the
following attachments:
A.
"ATSDR's Evaluation of Childhood Brain Cancer
Cases in Providence" (August 1992).
-------
4.0
B.
Memorandum from Don Gibeaut and Laura Barr,
Department of Health and Human Services Agency
for Toxic Substances and Disease Registry to
Louise A. House, Department of Health and Human
Services Agency for Toxic Substances and
Disease Registry (August 7, 1992).
C.
Memorandum from Ahmed Gomaa, Department of
Heal th and Human Services Agency for Toxic
Substances and Disease Registry to Louise A.
House, Department of Health and Human Services
Agency for Toxic Substances and Disease
Registry (July 23, 1992).
D.
Memorandum from Louise A. House, Department of
Heal th and Human Services Agency for Toxic
Substances and Disease Registry to James M.
Brown, EPA Region I (July 19, 1991).
2.
"Lead Initiative Summary Report," Department of
Health and Human Services Agency for Toxic
Substances and Disease Registry (September 24,
1992). Attached to letter dated September 29,
1992 from Louise A. House, Agency for Toxic
Substances and Disease Registry to James M. Brown,
EPA Region I.
3.10 Endangerment Assessments
1. "Baseline Risk Assessment," COM
corporation (FPC) {November 23, 1993).
Federal
Programs
Feasibility study (FS)
4.1
Correspondence
1.
Cross Reference: Letter from Richard C. Boynton, EPA
Region I to Thomas E. Wright, Rhode Island Solid
Waste Management Corporation (January 25, 1994).
Concerning preliminary approval of the December 1993
"Final Feasibility Study Operable Unit OUI
Volume 1-3," GZA GeoEnvironmental, Inc. for Rhode
Island Solid Waste Management Corporation [Filed as
part of entry number 1 in 4.6 Feasibility Study (FS)
Reports] .
-------
4.2
4.4
3.
Sampling and Analysis Data
1 .
Letter from Russell J. Morgan, GZA GeoEnvironmental,
Inc. to James M. Brown, EPA Region I (June 2, 1992).
Concerning the attached groundwater quality criteria
for use during the Feasibility study.
Interim Deliverables
Reports
1.
"Feasibili ty Study Technical Memorandum
Identif ication of Remedial Technologies, " GZA
GeoEnvironmental, Inc. (December 1991).
2.
"Feasibility Study Technical Memorandum - Remedial
Response Objectives and Response Actions," GZA
GeoEnvironmental, Inc. for Rhode Island Solid Waste
Management Corporation (February 1992).
"Draft Report Initial Screenings of Remedial
Alternatives, "GZA GeoEnvironmental, Inc. for Rhode
Island Solid Waste Management Corporation (March
1992) .
4.
Comments
" ,
5.
6.
Comments Dated November 5, 1991 from James M. Brown,
EPA Region I on the October 1991 "Preliminary
Remedial Response Objectives and Response Actions -
Technical Memorandum," GZA GeoEnvironmental, Inc.
Comments Dated December 13, 1991 from Judith S.
McCabe, State of Rhode Island Department of
Environmental Management on the December 1991
"Feasibility Study Technical Memorandum
Identif ication of Remedial Technologies, "GZA
GeoEnvironmental, Inc.
Comments Dated January 15, 1992 from James M. Brown,
EPA Region I on the December 1991 "Feasibility Study
- Technical Memorandum - Identification of Remedial
Technologies," GZA GeoEnvironmental, Inc.
7.
Responses to Comments
Response Dated February 24, 1992 from Russell J.
Morgan and Michael A. Powers, GZA GeoEnvironmental,
Inc. to the Comments Dated January 15, 1992 from
James M. Brown, EPA Region I.
-------
Feasibility study (FS) Reports
4.6
Feasibility study Operable Unit OUl
I," GZA GeoEnvironmental, Inc. for Rhode
Solid Waste Management Corporation (December
"Final
Volume
Island
1993) .
1.
Feasibility Study Operable Unit OU1
II, "GZA GeoEnvironmental, Inc. for Rhode
Solid Waste Management corporation (December
"Final
Volume
Island
1993) .
2.
Feasibility Study Operable Unit OU1
III," GZA GeoEnvironmental, Inc. for Rhode
Solid Waste Management corporation (December
"Final
Volume
Island
1993) .
3.
Proposed Plan for Selected Remedial Action
4.9
"EPA Proposes Source Control Plan for the Central
Landfill Superfund Site, "EPA Region I (February
1994).
1.
Record of Decision (ROD)
5.0
Requirements
Appropriate
Applicable
(ARARS)
Relevant
and
5.2
or
Cross-Reference: "A Summary of Groundwater
Cla.ssif ication Draft, "state of Rhode Island
Department of Environmental Management (January
1990) and "Chapter 13.1 Groundwater Protection,
"State of Rhode Island Department of Environmental
Management [Filed and cited as Attachments A and B
of entry number 4 in 9.1 Correspondence].
1.
Letter from Judith S. McCabe, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (February 10, 1992). Concerning
the attached preliminary list of Applicable or
Relevant and Appropriate Requirements (ARARs).
2 .
state coordination
9.0
correspondence
9.1
Memorandum from Richard C. Boynton, EPA Region I to
File (July 3, 1991). concerning telephone call with
Terrence Gray, State of Rhode Island Department of.
Environmental Management regarding an amended
1.
-------
10.0 Enforcement
Consent Order for wetlands remediation.
2.
"Solid Waste Management Facility License Conditions
for the Rhode Island Solid Waste Management
Corporation Central Landfill, "State of Rhode Island
Department of Environmental Management
(July 24, 1991).
3.
Letter from Judith S. McCabe, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (September 24, 1991). Concerning
the following attachments:
A.
"A Summary of Groundwater Classification
Draft, "State of Rhode Island Department of
Environmental Management (January 1990).
B.
"Cnapter 13.1 Groundwater Protection, "Rules
and Regulations for Groundwater Quality, State
of Rhode Island Department of Environmental
Management.
4.
Letter from Judith Graham, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (April 14, 1993). Concerning
transmittal of the attached February 11, 1993 "State
of Rhode Island Senate Resolution Respectfully
Requesting the Solid Waste Management Corporation,
the Department of Environmental Management and the
u.S. Environmental Protection Agency to Complete the
Cleanup of the Johnston Landfill."
1.
10.3 state and Local Enforcement Records
Letter from Ronald T. DelFino, Rhode Island Solid
Waste Management Corporation to Thomas E. Wright,
Rhode Island Solid Waste Management Corporation
(September 14, 1981). Concerning attached Consent
Order revising the schedule for closure of the
hazardous waste disposal area.
-------
10.7 EPA Administrative Orders
The Work Plan included in entry number 1 has been amended
by subsequent Progress Reports ci ted in 3.7 Work Plans and
Progress Reports.
1.
Administrative Order by Consent, In the Matter of
Central Landfill, u.s. EPA Docket No. 1-87-1016
(April 3, 1987), with attachments:
A.
"Revised Proposal for Sampling, Analysis,
Monitoring and Reporting of Conditions at the
Central Landfill," Rhode Island Solid Waste
Management corporation (February 1985)
B.
Changes and/or additional testing elements pe@g
to the Remedial Investigation
C.
Schedule of activities and deliverables-
13.0 community Relations
13.1 correspondence
1.
Letter from David Del Sesto, We Are The Endangered
Residents to Kenneth Wenger, EPA Region I (January
15, 1987) . Concerning the new SARA grant
legislation.
2 .
Letter from James E. Bedell, Geo Tech Environmental
Services to We Are The Endangered Residents
(February 10, 1987). Concerning brief description
of the geologic and hydrologic reasons for concern.
3.
Letter from Thomas E. Wright, Rhode Island Solid
Waste Management Corporation to Robert Finke, WPRI -
TV 12 (August 2, 1991). Concerning the television
series titled, "Don't Drink the Water."
4.
Letter from Julie A. Jaglowski, Rhode Island Solid
Waste Management Corporation to Sharon Abbott, Booz,
Allen & Hamilton (August 23, 1991). Concerning
transmittal of documents to be used in the Community
Relations Plan.
5.
Letter from Judith S. McCabe, State of Rhode Island
Department of Environmental Management to James M.
Brown, EPA Region I (September 13, 1991).
Concerning desire for the state to play an active
role in the development of the Community Relation
Plan.
-------
8.
9.
13.5 Fact
1.
6.
Letter from James M. Brown, EPA Region
O'Connell (October 7, 1991).
clarification of EPA's position on the
closure plan.
I to Stephen
Concerning
site
7.
Letter from Ralph J. Perrotta to Paul G. Keough, EPA
Region I (April 22, 1993). Concerning questions
regarding EPA's position on the cleanup at the site
and with the following attachments:
A.
Letter from Linda M. Murphy for Merrill S.
Hohman, EPA Region I to Thomas E. Wright, Rhode
Island Solid Waste Management Corporation
(September 25, 1990).
B.
"FY93 Budget Narrative."
C.
"Figure 10 - Off-site Sources of Contamination
in Central Landfill Vicinity".
D.
"Figure 4 Map Showing Existing Landfill,
Previously Mapped Surficial Deposits, and
Borrow Pit Area".
E.
Letter from Richard C. Boynton, EPA Region I to
Thomas E. Wright, Rhode' Island Solid Waste
Management Corporation (July 1, 1992).
F.
Letter from James M. Brown, EPA
Dennis P. arusso, Rhode Island
Management Corporation
(August 16, 1991).
Region I to
Solid Waste
Letter from Paul G. Keough, EPA Region I to Ralph J.
Perrotta (June 2, 1993). Concerning responses to
questions raised in the April 22, 1,993 letter.
Technical Report - "Critical Evaluation Of Central
Landfill With Regard To Future Expansion And/Or
Siting Of a Free-Standing Landfill". Prepared for
the Town of Johnston by Groundwater Associates,Inc.,
March 29, 1993.
Sheets
"Central Landfill Fact Sheet
-------
16.0 Natural Resource Trustee
16.1 Correspondence
17.0
1.
Letter from Merrill S. Hohman, EPA Region I to
Sharon Christopherson, National Oceanic and
Atmospheric Administration. Concerning notification
of potential natural resource damages with attached
trustee notification package.
2.
Letter from Merrill S. Hohman, EPA Region I to
William Patterson, U.s. Fish and wildlife Service.
Concerning notification of potential natural
resource damages with attached trustee notification
package.
17.7 Reference Documents
site Management Records
1.
Letter from J. Joseph Garrahy, Governor of the State
of Rhode Island to Herbert Johnston, U.S. Geological
Survey (September 29, 1983). concerning inquiry
into effects of the Central state Landfill on the
Scituate River.
2.
. Letter from Herbert Johnston, U.S. Geological Survey
to J. Joseph Garrahy, Governor of the State of Rhode
Island (October 12, 1983). Concerning response to
inquiry into effects of the Central state Landfill
on the scituate River.
3.
"Wastewater Investigation,"
Engineers (May 1992).
of
U.S.
Army
Corps
4 .
Cross Reference: Memorandum from Don Gibeaut and
Laura Barr, Department of Health and Human Services
Agency for Toxic Substances and Disease Registry to
Louise A. House, Department of Health and Human
Services Agency for Toxic Substances and' Disease
Registry (August 7, 1992) [Filed and cited as
attachment B of entry number 1 in 3.9 Health
Assessments).
5.
"Evaluation of the Central Landfill and its
Potential Impacts on the Scituate Reservoir, "CH2M
Hill for the Providence Water Supply Board (October
1988).
-------
17.8 state and Local Technical Records
1.
Letter from Herbert E. Johnston, U. S. Geological
Survey to Tom Quigley, Goldberg-Zoino & Associates,
Inc. (August 28, 1984). Concerning direction of
ground water flow in the vicinity of the Central
State Landfill with attached letters of explanation~
2 .
"Study Plan - Cyanide Waste Disposal Assessment,"
Goldberg-Zoino & Associates, Inc. for Rhode Island
Solid Waste Management Corporation (February 1987).
3.
"Cyanide Waste Disposal Assessment (Final Report),"
Goldberg-Zoino & Associates, Inc. for Rhode Island
Solid Waste Management Corporation (May 1987).
-------
section II
Guidance Documents
EPA guidance documents may be reviewed at the Region I Records
Center in Boston, MA.
General EPA Guidance Documents
1. "Final and Proposed Amendments to the National Oil and
Hazardous Substances Pollution Contingency Plan," Code of
Federal Requlations (Title 40, Part 300), September 8, 1983.
2. "National oil and Hazardous Substances Pollution
contingency Plan," Code of Federal Requlations (Title 40,
Part 300), 1985.
3. "National oil and Hazardous Substances Pollution
contingency Plan - Final Rule, "Federal Reqister (Vol. 55,
No. 46), March 8, 1990..
4. U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Community Relations in
Superfund:A Handbook (Interim Version) (EPAjHW-6), September.
1983.
5. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Guidance on Remedial
Investiqation under CERCLA (Comprehensive Environmental
Response, Compensation, and Liabilitv Act) (EPA/540/G-
85/002),
June 1985.
6. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Guidance on Feasibility Studies
under CERCLA (Comprehensive Environmental Response,
Compensation. and Liabilitv Act) (EPA/540/G-85/003), June
1985.
7. U.S. Environmental Protection Agency. Environmental
Monitoring Systems Laboratory. Sediment Samplinq Ouality
Assurance User's Guide (EPA/600/4-85/048), July 1985.
8. U.S. Environmental Protection Agency. Hazardous Waste
Engineering Research Laboratory and Office of Emergency and
Remedial Response. Covers for Uncontrolled Hazardous Waste
sites (EPA 540/2-85/002), September 1985.
9. U.S. Department of Health and Human Services. National
Institute for occupational Safety and Health, and
Occupational Safety and Health Administration. Occupational
-------
Safety and Health Guidance Manual for Hazardous Waste Site
Activities, October 1985.
10. U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Guidance on Remedial Actions
for contaminated Groundwater at Superfund Sites (OSWER
Directive 9283.1-2), December 1988.
11. U.S. Environmental Protection Agency. Comprehensive
Environmental Response. Compensation and Liability Act of
1980, as amended October 17, 1986. .
12. U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Superfund Public Health
Evaluation Manual (EPA/540/1-86/060, OSWER Directive 9285.4-
1), October 1986.
13. U.S. Environmental Protection Agency. Office of Ground-
Water Protection. Guidelines for Ground-Water Classification
under the EPA Ground-Water Protection Strateqy. December
1986.
14. U.S. Environmental Protectior. Agency. Quality Assurance
Management Staff. Guidelines and Specifications for Preparinq
Quality Assurance Proqram Documentation, June 1987.
15. U.S. Environmental Protection Agency. Center for
Environmental Research Information. A Compendium of
Technoloqies Used in the Treatment of Hazardous Waste
(EPA/625/8-87/014), September 1987.
16. U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. A Compendium of Superfund
Field Operations Methods (OSWER Directive 9355.0-14),
December 1987.
17. U.S. Environmental Protection Agency. Office of
Emergency and Remedial Response. Draft Guidance on
. Conductinq Remedial Investiqation and Feasibility Studies
under CERCLA (Comprehensive Environmental ResDonse.
Compensation and Liability Act). March 1988.
18. 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), April 1988.
19. U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Superfund EXDosure Assessment Manual
(EPA/540/1-88/001, OSWER Directive 9285.5-1), April 1988.
-------
20. U. S. Environmental Protection Agency. Off ice of Emergency
and Remedial Response. Community Relations in Superfund:
A Handbook (Interim Version) (EPA/540/G-88/002, OSWER Directive
9230.0-3A), June 1988.
21. U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. CERCLA (Comprehensive Environmental
Response. Compensation and Liabil i ty Act) Compl iance with Other
Laws Manual (EPA/540/G-89/006, OSWER Directive 9234.1-01),
August 1988.
22. U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Guidance for Conductinq. Remedial
Investiqations and Feasibility Studies Under CERCLA
(Comprehensive Environmental Response. Compensation. and
Liabilitv Act) (Interim Final) (EPA/540/G-89/004, OSWER
Directive 9355.3-01), October 1988.
23. U. S. Environmental Protection Agency. Off ice of Emergency
and Remedial Response. Community Relations in Superfund: A
H~ndbook (Interim Version), Chapter 6 (OSWER Directive 9230.0-
3B), November 3, 1988.
24. U. S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Desiqn. Construction. and
Evaluation of Clay Liners for Waste Manaqement Facilities
(EPA/530/SW-86/007F), November 1988.
25. U.S. Environmental Protection Agency. Office of Emergency
and Remedial Response. Guidance on Remedial Actions for
Contaminated Ground Water at Superfund Sites (EPA/540/G-88/003,
OSWER Directive 92B3.1-2), December 1988.
26. U. S. Environmental Protection Agency. Off ice of Emergency
and Remedial Response. User's Guide to the Contract Laboratorv
Proqram (OSWER Directive 9240.0-1), December 1988.
27. U. S. Environmental Protection Agency. Risk Reduction
Engineering Laboratory. Technoloqv Evaluation Report: SITE
Proqram Demonstration Test Terra Vac In situ Vacuum Extraction
System Groveland. Massachusetts. Volume I (EPA/540/5-89j003a),
April 1989.
28. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. A Guide on Remedial Actions for
contaminated Ground Water (OSWER Directive 9283.1-2FS),
April 1989.
29. U.S. Environmental Protection Agency. Office of Research
and Development. Requirements for Hazardous Waste Landt ill
Desiqn. Construction and Closure (EPA/625/4-89/022), April
1989.
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30. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. ARARs O's & A's (OERR 9234.2-
OlFS) , May 1989.
31. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Land Disposal Restrictions:
Summary of Reauirements. June 1989.
32. U. S. Environmental Protection Agency. Risk Assessment
Work Group, Region I. Supplemental Risk Assessment Guidance
for the Superfund Proaram (Draft Final) (EPAj901j5-89j001),
June 1989.
33. U. S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Superfund LOR Guide #1. Overview
of RCRA Land Disposal Restrictions (LDRs) (OSWER Directive
9347.3-0lFS), July 1989.
34. U. S. Environmental Protection Agency. Off ice of Solid
Waste and Emergency Response. Superfund LOR Guide #2. Complyina
wi th the California List Restrictions Under Land Disposal
Restrictions (LDRs) (OSWER Directive 9347.3-02FS), July 1989.
35. U. S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Superfund LOR Guide #3. Treatment
Standards and Minimum Technoloay Reauirements Under Land
Disposal Restrictions (LDRs) (OSWER Directive 9347. 3-03FS),
July 1989.
36. U. S. Environmental Protection Agency. Off ice of Solid
Waste and Emergency Response. Superfund LOR Guide #4. ComplYing
With the Hammer Restrictions Under Land Disposal Restrictions
(LDRs) (OSWER Directive: 9347.3-04FS), July 1989.
37. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Superfund LDR Guide #5.
Determinina When Land Disposal Restrictions (LDRS) Are
Applicable to CERCLA Response Actions. (OSWER Directive:
9347. 3-05FS) ,
July 1989.
38. U. S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Superfund LDR Guide #6A.
Obtainina a Soil and Debris Treatability Variance for Remedial
Actions. (OSWER Directive: 9347.3-06FS), July 1989.
39. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Risk Assessment Guidance for
Superfund. Human Health Evaluation Manual Part A. July 1989.
-------
40. U.S. Environmental Protection Agency. Office of Research
and Development. Technical Guidance Document: Final Covers on
hazardous Waste Landfills and Surface Impoundments
(EPAj530-SW-89-047), July 1989.
41. U. S. Environmental Protection Agency. Off ice of Solid
Waste and Emergency Response. CERCLA (Comprehensi ve
Environmental Response and Liability Act) Compliance with Other
Laws Manual -Part II: Clean Air Act and Other Environmental
Statutes and State Reauirements (EPAj540jG-89j009, OSWER
Directive9234.1-02), August 1989.
42. U. S. Environmental Protection Agency. Off ice of Solid
Waste and Emergency Response. CERCLA Compliance with Other Laws
Manual- RCRA ARARS: Focus and Closure Reauirements
(OSWER Directive 9234.2-04), October 1989.
43. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. The Feasibili tv Studv:
Development and Screenina of Remedial Action Al ternati ves
(OSWER Directive 9355.3-01FS3), November 1989.
44. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. The Remedial Investiqation: site
Characterization and Treatability Studies (OSWER Directive
9355.3-01FS2), November 1989. .
45. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. State and Local Involvement in
the Superfund Proqram (9375.5-01jFS), Fall 1989.
46. U. S. Environmental Protection Agency. Off ice of Emergency
and Remedial Response. Risk Assessment Guidance for Superfund -
Volume I: Human Health Evaluation Manual (Par.t A -Interim
Final) (EPAj540j1-89j002), December 1989.
47. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. Superfund LOR Guide #7.
Determinina When Land Disposal Restrictions (LDRs) are Relevant
and Appropriate to CERCLA Response Actions. (OSWER Directive
9347.3-08FS), December 1989.
48. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. CERCLA Compliance with Other Laws
Manual - CERCLA Compliance with State Reauirements (OSWER
Directive 9234.2-05jFS), December 1989.
49. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. CERCLA Compliance with Other Laws
Manual - Overview of ARARs Focus on ARAR Waivers (Publication
9234.2-03jFS), December 1989. .
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50. U. S. Environmental Protection Agency. Risk Reduction
Engineering Laboratory. Handbook on In Situ Treatment of
Hazardous Waste-Contaminated Soils EPAj540j2-90j002),
January 1990.
51. U.S. Environmental Protection Agency. Risk Engineering
Laboratory. proiect Summary State of TechnoloGY Review: Soil
Vapor Extraction Systems (EPAj600jS2-89j024), January 1990.
52. U. S. Environmental Protection Agency. Off ice of Solid
Waste and Emergency Response. CERCLA Compliance with Other Laws
Manual CERCLA Compliance with the CWA and SDWA (OSWER
Directive 9234.2-06/FS), February 1990.
53. U. S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. The Feasibility Study: Detailed
Analysis of Remedial Action Alternatives (OSWER Directive
9355.3-01FS4), March 1990.
54.. U.S. Environmental Protection Agency. Office of Solid
Waste and Emergency Response. CERCLA Compliance with other Laws
Manual - Summary of Part 11- CAA. TSCA, and Other Statutes
(OSWER Directive 9234.2-07jFS), April 1990.
55. "Control Technology: A Field Demonstration of the
UVjOxidation Technology to Treat Groundwater Contaminated with
VOCs, "Journal of the Air & Waste Manaqement Association (Vol.
40, NO.4), April 1990, pp. 540-47.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
CENTRAL LANDFILL SUPERFUND SITE IN JOHNSTON, RHODE ISLAND
-------
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE
CENTRAL LANDFILL SUPERFUND SITE IN JOHNSTON, RHODE ISLAND
Community relations activities conducted at the Central Landfill
Superfund Site:
.
EPA issued a fact sheet describing the RIfFS process in
November 1987.
.
EPA issued a press release announcing the completion of
the RI Field work on July 26, 1993.
.
EPA issued a fact sheet announcing
Investigation results in September 1993.
Remedial
the
.
EPA published a notice on February 8, 1994 in the
Providence Journal announcing the establishment of the
Administrative Record for the Operable Unit 1, the dates
for the public meeting and public hearing, and the public
comment period dates.
.
EPA issued a press release indicating that because of
severe winter weather, the public meeting would be
postponed to February 22, 1994.
.
EPA released a
discussing the
alternative.
February 1994,
its preferred
proposed plan, dated
Feasibility Study and
.
EPA conducted a public meeting on February 22, 1994 to
discuss the Preferred Alternative. EPA also conducted a
public hearing on February 28, 1994 to solicit public
comment on the Preferred Alternative. Seventy-four
people signed the sign-in sheet for the public meeting;
eight people testified during the public hearing. A copy
of the hearing transcript is included in the
Administrative Record at the Information Repositories at
the Marion J. Mohr Memorial Public Library and at the EPA
~ecords Center.
.
EPA conducted a public comment period from February 13,
1994 through March 14, 1994. six people submitted
written. comments.
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ATTACHMENT B
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STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS
TOWN OF JOHNSTON
IN RE:
CENTRAL LANDFILL PUBLIC HEARING
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Hearing held on Monday, February 28, 1994, at the
Johnston High School, 345 Cherry Hill Road, Johnston, Rhode
Island, commencing at 7:00 p.m. before Mary M. Guglietti,
Shorthand Reporter and Notary Public within and for the State
of Rhode Island and Providence Plantations.
HEARING PANEL
DICK BOYNTON, U.S. EPA, BOSTON, MASSACHUSETTS
JIM BROWN, EPA
AMY ROGERS, EPA
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MONDAY. FEBRUARY 28. 1994
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(COMMENCING AT 7:00 P.M.)
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MR. BOYNTON:
Good evening.
My
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name is Dick Boynton, I'm from EPA's Region I Boston
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office from the Waste Management Division, and I have
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supervisory responsibilities for NPL sites, National
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Priority List sites, Superfund sites in Rhode Island.
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I'll be the Hearing Officer for tonight's hearing.
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What we're going to talk about tonight or what we're
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going to receive comment on tonight is EPA's proposed
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plan for containing contamination at the Central Landfill
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Superfund site, which is defined as a 154 acre licensed
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portion of the landfill.
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And with me tonight is Jim Brown, who is EPA's
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Project Manager for the Superfund site, Amy Rogers, who
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is outside of the door, she's our Community Relations
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Coordinator.
And, as I said, the purpose of this hearing
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is to formally accept oral comments on our proposed plan
for containing contamination at the site.
I want to emphasize that EPA does' not have
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regulatory authority for solid waste operations at
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landfills in the State of Rhode Island.
That is strictly
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a state regulatory authority.
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Since this is a hearing, we will not be responding
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to comments and questions tonight.
We were here last
week on I believe it was Tuesday night in this room and
we talked to you about our proposed plan and some of the
questions, and we had a question-and-answer session.
We
will be responding to all comments that we receive
tonight and during our comment period, which began
February 13th and will end on March 14th, and we will
respond in writing to all of those comments in a document
called the Responsiveness Summary that becomes part of
our decision document, which is called the Record of
Decision.
NOW, let me describe the format of the hearing.
First, Jim Brown, Project Manager, will give a brief
overview of our proposed plan for the Superfund site.
Following Jim's presentation, we will accept oral
comments for the record.
Those of you wishing to comment
should have indicated that you wanted to comment by
filling out an index card with your name on it at the
front table, and I will call the names on the cards as I
received them for people to come up, . and if you would.
come up to the microphone and state your name and speak
very cl early when you're called because our reporter. is
recording everything you say for the record.
So are there any questions about how we plan to
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conduct the hearing?
With that, I think III I ask Jim to
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give a brief overview of our proposed plan.
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MR. BROWN:
For the benefit of
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those who weren't here last Tuesday night, in addition to
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presenting the proposed plan, I'll also briefly go over
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the major conclusions of the investigations that were
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done at the Central Landfill site.
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The Central Landfill site is located within a 610
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acre parcel of land off Shun Pike in Johnston, Rhode
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Island.
The 154 acre licensed landfill is typically
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described a.s in two components, a 121 acre area -- the
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colors don't show up very good in "this light, but the 121
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acre is this green area and a 33 acre area just to the
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west, which is also sometimes called the Phase II and the
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Phase III areas, and this 121 acre area is sometimes
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referred to as the Phase I area.
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Most of the waste that's been deposited at the site
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has been deposited in the Phase I area, and most of the
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waste in this area is just municipal solid waste.
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However, prior to 1980, in addition to municipal solid
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waste disposal in this area, some hazardous substance may
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have also been disposed of.' We do know that in the mid
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to late 1970's, there's an area of the site located right
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here, this is an area where large volumes of liquid
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industrial waste were disposed of in trenches that were
excavated into the bedrock.
This area's been termed the
"hot spot" area of the site because of the concentrations
that we find in this area are so much greater than the
concentrations of contamination found anywhere else on
the site.
And we do believe that it's this area of the
site, the hot spot area's the major source of
contamination of the Central Landfill site.
All of the municipal -- all of the landfilling
activities have ceased in this area here, the 121 acre
area, as of April, 1993.
Currently, all the waste that's
brought to the Central Landfill site is disposed of in
this 33 acre expansion area.
There's a 12 acre area
that's been prepared in the northern portion of that. area
and that's the area of the site right now where non-
hazardous municipal solid waste is being disposed of.
Using groundwater level data from 41 -- .from
monitoring wells located in 41 different spots around the
Central Landfill and by using data provided by the U.5.
Geologic Survey, we're able to determine that most of the
groundwater that flows underneath the Central Landfill
site is flowing toward the upper Simmons Reservoir.
These yellow arrows here show the direction of
groundwater moving at the site.
There is a small
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component of groundwater that flows underneath the 121
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acre area that does flow toward the Alroy Reservoir.
This
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yellow line here indicates a groundwater divide, water on
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this side -- groundwater on this side of the line fiows
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in that direction, the groundwater on the other side of
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the line flows in this direction.
So you can see that
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most of the groundwater underneath the site, you know,
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flows in this general direction.
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None of the data that we collected at the site
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indicated that the groundwater flowed toward the west
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toward the Scituate Reservoir.
The Risk Assessment that
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we performed and all of the data that was collected
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during the investigations concluded that groundwater was
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a pathway of concern at the site.
In a sense, we've
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concluded that a potential risk to human health would
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occur if groundwater at the site was presently used as a
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drinking water sourc.e.' If the contaminated groundwater
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from the site were allowed to continue to migrate off-
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site and that off-site groundwater were to be developed
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as a drinking water source in the future, that a
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potential risk could also occur from drinking that water.
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Currently, though, there is no human health risk because
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no one is drinking the groundwater on-site and any
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potentially affected resident in the v icini,ty of the
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Central Landfill is on public water.
I prepared a plan for controlling the contamination
at the site.
It was selected from a list of nine plans
that were analyzed in detail in the Feasibility Study
Repor t.
Let me just briefly go over some of the existing
site conditions before I talk about the proposed plan.
This is the 154 acre licensed landfill area.
This is the
Phase I area, the 121 acre area, and the 33 acre Phase II
and Phase III areas.
Currently, there are two areas of
the 121 acre site -- 121 acre area that are capped with a
State approved cap.
It's the Area 1 and the Area 2.
The
remainder of the 121 acre area is capped with a temporary
soil cover, it's about one-foot thick temporary soil
cover.
Also, methane that is being generated from the
decomposition of solid waste in the Phase I area is being
collected and burned at a facility located right here,
and the energy from burning the methane is being used to
generate electricity.
That facil ity is not owned by
Rhode Island Solid Waste Management Corporation.
It was
installed by a private power compa~y and is operated and
maintained by that private company. .
The purpose of the preferred plan is -- as Dick said
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earlier, is to control the sources of contamination
located within this 121 acre area, including the hot spot
area.
The plan for operating and closing this area is
the State responsibility, and the plan for operating and
closing that area was approved in April of 1991.
All right.
So what is our proposed plan?
This
schematic is provided in the 40-page proposed plan that
was reI eased to the publ ic.
The proposed plan consists
of six components.
The first component will require capping the 89
.acres of the 121 acre area that are not currently capped
with the State approved cap.
The second component of the plan would require
pumping approximately 30,000 gallons per day of
contaminated groundwater out of the hot spot area,
treating that groundwater on-site and then discharging
the clean water to either on-site surface waters,
potentially Pond No.3 or Pond No.2, or to the Cranston
Wastewater Treatment Plant.
The third component will requir~ long-term
environmental monitoring program.
Weill be monitoring
groundwater around the site,. surface "water and air in the
long-term.
This will allow us to continue to monitor the
site over the future years and to monitor the
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effectiveness of our proposed plan.
The fourth component will require conducting a
detailed evaluation of the existing landfill gas
collection and combustion system.
Just a few moments
ago, I talked about the methane that's being collected
and burned on-site.
The existing system has been
permitted by the State of Rhode ISland and it appears to
be operating well.
However, there are a few more tests
that we want to have done on that system just to make
sure that it is operating as well as any system we would
have put in ourselves.
Also, since the system is not
owned by Rhode Island Solid Waste "Management Corporation,
we want to make sure that it's understood that the system
is a component of the remedy and it's an important
component of the remedy and if, in the future, the
company that is operating that system decides. it no
longer wants to do that, the Rhode Island Solid Waste
will have to assume the responsibility for operating that
system.
The fifth component will require some deed
restrictions on land use and groundwater use at the site.
And the sixth and final component would require
installing a fence to prevent access.
That's it.
That's a summary of the investigations
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and the proposed plan, and I guess that's it.
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MR. BOYNTON:
Thanks, Jim.
I
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have eight people who have indicated that they want to
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comment tonight.
I would ask that you try to keep your
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comments to around ten minutes or so.
If you have
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something more lengthy that you want to submit to us, you
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can do that tonight or you can mail your comments into
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the address that's on page 5 of the proposed plan, which,
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is Jim's address.
Make that ten people.
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So, with that, as I said, if you'll just try to get
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your major points for the record.
Everything you say
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tonight is being recorded, so try' to speak up so that our
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reporter can get the essence of your comments.
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Let me begin with Judy Graham from Rhode Island.DEM
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with the Division of Site Remediation.
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MS. GRAHAM:
Hi, Dick.
The
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Department of Environmental Management, Division of Site
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Remediation, has conducted a thorough review of the
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Operable Unit 1 Remedial Investigation and Feasibility
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Study, as well as other technical documents resulting
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from the Superfund investigations at the Central
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Landfill, including the proposed plan.
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As a result of this review, the Division has
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generated numerous comments which have been
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satisfactorily addressed.
These comments have been
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documented and are contained in the administrative
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record, which is available for public review.
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The Division believes that the final remedy
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selection as outlined in the proposed plan accurately
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defines, recognizes and complies with all promulgated
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State environmental regulations and all existing
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agreements and requirements entered into with and set
4
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forth by the Department of Environmental Management.
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It is broadly accepted that caps are effective in
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controlling the migration of contamination from
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landfills.
The State's regulations for landfill closure
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require a single impermeable barrier cap.
Although this
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type of closure would probably provide sufficient
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protection to human health and the environment, the
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multilayer design provides the added assurance of
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long-term performance.
The Division supports the concept
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for source control at Central Landfill.
The Division
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believes that this design will provide long-term
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minimization of the flow of liquids through the closed
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landfill.
It will function with minimum maintenance and
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it will promote drainage and minimize erosion or abrasion
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of the cover, and it will accommodate settling and
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subsidence so that the cover integrity is maintained.
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Additionally, the placement of bedrock groundwater
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recovery wells. at the hot spot to prevent the migration
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of highly contaminated groundwater through bedrock
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fractures provides further assurance of successful
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containment.
This groundwater extraction and treatment
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system when properly designed and executed will
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adequately address the State's concerns over this
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potential route of exposure.
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This proposed plan and associated Remedial
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Investigation and Feasibility Study is relative to
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on-site conditions only.
Off-site receptors such as the
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upper Simmons and the Almy Reservoirs will be addressed
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in the Operable Unit 2 portion of the studies.
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Additionally, the lower Simmons Reservoir may be impacted
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by conditions at the landfill and will be considered
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during the OU-2 study.
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In conclusion, based upon the Division of Site
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Remediation review of all of the information available to
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the Department of Environmental Management, the DEM
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agrees with the selection of the remedy as proposed by
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the Environmental Protection Agency.
Thank you.
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MR. BOYNTON:
Thanks, Judy.
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Next is Alfred A. Russo, Jr.
Tha t . s R- U- S- s-o ?
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MR. RUSSO:
Correct.
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NR. BOYNTON:
Jr., r i gh t ?
MR. RUSSO:
Correct.
For the
record, as you stated, my name is Al Russo, I am a State
Representative here in the Town of Johnston.
I've read
through the materials and I have a few questions.
First of all, on the preferred plan, what, if
anything, is going to be done to clean up the upper and
lower Simmons Reservoirs?
Is EPA going to dredge the
solids on the bottom of the pond and return the
reservoirs to their pristine state?
No.2, will the groundwater flowing from the
landfill in a southeasterly direction be monitored since
it possesses a potential risk to the health of the
residents?
No.3, what are the estimated contaminated
concentrations that groundwater would have flowing into
the upper Simmons Reservoir?
NO.4, I read on page 12 of the materials that you
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had some deed restrictions"what are these deed
restrictions on the groundwater use and land development
on the property owned by Solid Waste Management
Corporation?
No.5, as to the long-term program.of sampling 'and
analysis of the groundwater, surface water and air
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quality sampling, how often are you ,going to test, how
long will this testing continue and will the tests be
on-site or off-site?
No.6, is the groundwater -- in the groundwater
treatment system what will become of the residue?
I
understand on the bottom, when you take out the irons and
so forth, that material can be very hazardous, and I'd
like to know what's going to be done with that material.
Is that material going to be redeposited in the landfill
or will that be taken off-site to a hazardous waste
facili ty?
I had one question as to the other plans, not with
the preferred plan, and it deals with Plan No.9.
In
that plan, the way I understand it, excavation will be
done to the area of the hot spot where the one thousand
or so yards of material's been identified.
I was
wondering why that plan or Plan No.9 was not selected
and you selected pr~ferred Plan No.5.
I would like EPA to revisit that plan one more time,
look at it and seriously give consideration to the ta'king
of the excavated materials out of the landfill and take
it off the site and take it'to a hazardous treatment
pI ant.
And that's all I have.
Thank you.
MR. BOYNTON:
Thank you,
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Mr. Russo.
Next is Paul Santilli.
HR. SANTILLI:
I'm going to pass
at this time.
NR. BOYNTON:
Okay.
Next is
Rocco Mariorenzi, M-A-R-I-o-R-E-N-Z-I.
MR. l-1ARIORENZ I :
The cor rect
pronunciation is Rocco Mariorenzi.
l-IR. BOYNTON:
Mariorenzi?
MR. MARIORENZI:
Mariorenz i,
just say Mario and then say Renzi and you've got it.
MR. BOYNTON:
Thank you.
MR. MARIORENZI:
I'm th e
President of the Rotary Drive Association and my question
is the bacteria level that flows through a pipe and then
comes into the plat on April Street and empties out
onto -- into the Dry Brook River, the question is the
bacterial level is 230,000 over 230,000 and DEM is
reluctant to tell anybody what this bacterial level is,
including the City Council.
Joe Falvo has been trying to
find out, Councilman Falvo, and President Louis
Perrotta's been trying to find out, and no one seems to
have the answer.
It has been coming within the plat because it's
piped in from outside the plat.
Personally, I believe
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there's such a thing as an underground river and it could
be corning from the landfill, that's what I think.
It's
been brought to the attention of Senator Reed, it's been
brought to the attention of the Governor of the State of
Rhode Island, and everybody avoids the subject.
It's
obvious to me if it is corning from the landfill, they'd
have to close this landfill immediately, but no one wants
to address it.
And, like I said, it definitely isn't
corning from the people's sewage where I live.
They want
everybody to think so, but that isn't the case at all.
About a year ago, they came in, they put a new plat
on April -- a new pipe on April Street, because I
complained about this same subject to Mr. Tomanski (sic).
Obviously, they thought that the pipe was leaking, but we
still have the same problem there.
They're concer"ned,
they're trying to do something, but they haven't corne up
with the answer.
When I met at the Governor's Office --
~orrection, when I met at the State House, I mentioned
the fact that the Dry Brook River and the water corning
from this pipe should be rerouted.
But that would cost a
lot of money and no one wants to hear it.
The Dry Brook
River, which runs behind my plat, could run underground
on Atwood Avenue and empty out on Long Avenue.
Of
course, that would cost millions of dollars and, like I
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said, no one wants to hear it.
50 my question, and I repeat myself, is what is this
230,000 over 230,000?
What is it?
What are they going
to do about it?
Where is it coming from?
And that's the
main question.
Thank you.
MR. BOYNTON:
Thank you,
Mr. Mariorenz 1.
Next is Representative Jennifer
Champagne Martelli.
MS. MARTELLI:
Good evening.
Just for the record, as you stated, Jennifer Champagne
Martelli, and I'm a State Representative in Johnston.
My
first question focuses on the preferred alternative and
it has to do with OU-1-5.
The question is why does
OU-1-5 not include removing the Rhode Island DEM cap on
the existing 32 acres and replacing it with the RCRAC
cap?
One, what short and long-term effects would occur
if the RCRAC cap is not used in that 32 acre area and,
two, what short and long-term effects if OU-1-8 and
OU-1-9 is not completed?
Would you like me to read that
into the record what exactly that is stating?
MR. BOYNTON:
You can if you'd
like or you can give it to us and we'll put it into the
record.
MS. MARTELLI:
Okay.
Now, if
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the Rhode Island OEM cap is replaced and/or the off-site
disposal of the hot spot chemical sludges are removed,
your report suggests that a tremendous amount of off-site
trucking would occur in that area.
My question is do you
suggest any compensation to the Town of Johnston, which
is the host community, or to the area residents for their
exposure to the increased trucking?
Next, I'd like to turn our attention to the
treatment of the groundwater in the southern landfill
boundary, and that's on page 31 of the short report that
I'm referring to.
The quote on that page says that the
treatment of the groundwater in the southern landfill
boundary, quote, may result in a significant lowering in
the water table which could impact the wetlands.
By
first question relative to that is what would the impact
be on the wetlands if you were to go forward with the
treatment of the groundwater in the southern area and,
two, what effect, long and short-term, if this area is
not treated?
My next question focuses on the .EPA's proof that
they may be able to provide that the new so-called state-
of-the-art landfill, meaning Phase II and Phase III, will
not somewhere down the line produce . some. of the same..
chemical sludge that we are now cleaning up.
I real iz e
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that the technical part of the Phase II and Phase III, at
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face value, we can say will not produce the same chemical
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sludge, but if we can focus on what perhaps in the future
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chemicals may be produced from this Phase II and Phase
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III area that we may in the future need to clean up.
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And my final question is focused on why one of the
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alternatives is not to cease all landfill operations in
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that area, and if your answer is that perhaps you don't
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have the authority to do that, I would need a little
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clarification on how we can appeal to the EPA to focus on
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that as an alternative and, further, what -- who you
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believe is vested with that power and why EPA cannot be
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involved in moving forward with ceasing operations in
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that entire area.
Thank you.
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MR. BOYNTON:
Thank yo u, Miss
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Martelli.
Next is Ralph Perrotta.
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MR. PERROTTA:
My name is Ralph
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Perrotta, I'm special counsel to the Town of Johnston on
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landf ill issues.
The Mayor couldn't be here tonight and
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he specifically asked me to corne and to reiterate the.
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remarks he made last week, which were to the effect that
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the EPA's interest and involvement in this issue is long
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overdue and by fifteen years, at least, overdue.
And,
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secondly, that the failure of the Source Control Study to
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even consider or even address or acknowledge that there
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will be Phase II and III landfills piggybacked on top of
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the Phase I site, which you're allegedly closing, is a
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serious deficiency in the study.
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I asked two experts, one a landfill engineer, Dara
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Lynott of Weston & Sampson, and the other a groundwater
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specialist fibrogeologist, Blake Martin, of Groundwater
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Associates in Dracut, Massachusetts, to look at the plan
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and they have both written to me their concerns about it,
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and both of them focus particularly on the point that was
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made by Mr. Brown I believe last week, which is not
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revealed at all in the report, and that is that the top
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of Phase I will not be capped until Phase II is completed
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so that the cap will eventually cover Phase I and Phase
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II.
And that means that there will not be a closure of
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the Phase I landfill until Phase II is completely filled,
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which I think in Mr. Brown's estimate was the turn of the
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next -- of this century.
My engineer tells me that there
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is a capacity potentially in Phase II until 2023.
In any
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case, we have an open-ended -- the possibility of an
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open-ended closure date and not any kind of real clear-
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cut closure, as your plan would imply if one were to take
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it at face value.
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Now, there are real problems created by this opening
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and, also, by the heaping of trash and garbage on the
slope of the existing landfill.
I understand that from
our own landfill engineer that his calculations show that
two-thirds of the trash and garbage dumped in Phase II
will be in the air over the ground over the footprint, I
guess you would call it, of Phase 1.
So we really
have -- when we're talking about Phase II, we really have
an expansion of Phase I.
We do not have a new landfill.
And the notion that we can call it a new landfill just
because we put a couple of layers of plastic between is
simply, simply nonsense.
Let me tell you some of the problems that Mr. Lynott
has raised.
Differential settlement and gross
deformation of the liner, both differential settlement on
top of the existing landfill and gross deformation.~f the
liner on the side slope of the existing landfi!l.
Differentia! sett!ement is due to void spaces within the
existing !andfi!! areas settle and conso!idate at
different rates, which may cause pipes laid at a minimum
s!ope for leachate collection to sett!e and possib!y
break.
The net effect is a bui!dup of !eachate within
the landfill, which wi!l eventua!!y flow through the
existing Phase I under!ying landfi!! and potentia!ly
through the hot spots identified by the EPA.
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21 !
1
Deformation, which is the counterpart of differential
2
settlement, is due to settlement of the existing
4
the side slopes.
Gross deformation of the liner or clay
the weight of new trash placed on ,
I
I
I
I
!
3
underlying landfill and
5
can lead to rupture of the liner.
If this occurs,
6
leachate may flow through the existing underlying
7
landfill and potentially through hot spots identified by
8
the EPA.
9
Now from Blake Martin, who also begins by saying
10
first we understand that closure and capping of the Phase
11
I landfill will be delayed until the Phase II area is
12
completed.
Any delays in the capping/closure program
13
will undoubtedly leave open phases at the existing
14
1andf ill.
That means that leachate will continue to be
15
generated.
If the top of Phase I is left open for five,
16
ten, fifteen years, rain will continue to fall and will
17
continue to drain and leach through the Phase I, which is
18
allegedly closed, and into the hot spot and into other
19
areas wherever it may -- wherever it may find its way
20
out.
As a matter of fact, pumping, which the plan
21
contemplates, pumping water contaminant out of the hot
22
spot area may well serve to suck more leachate through.
23
If you've got an open top and rain is coming down
24
and you're pumping at the bottom, there's a -- it's
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22
1
predictable that you will actually accentuate and
2
accelerate the flow of new leachate through a landfill
3
which purportedly is closed.
Obviously, it is not
4
closed.
It's like trying to drain a tub when you've got
5
the faucet running at the same time.
If the faucet is
6
running, it doesn't matter, you're going to continue to
7
have water in the tub.
You're going to continue to
8
generate leachate.
9
Now, there's another problem that's caused by
.10
leaving the top open.
According to Blake Martin, there
11
would be no way to monitor the effectiveness of any
12
collection at the hot spot.
Changes in groundwater
13
quality due to leachate generation versus changes caused
y
14
by the collection system would be difficult to discern.
15
In other words, how can you tell what your -- what kind
16
of effect your hot spot pumping system is having if
17
you've got a variable in there, namely the opening at the
18
top, which is allowing more rain to fall and.to flow
19
through the system constantly.
You're not going to be
20
able to tell whether the leachate you. got from the hot
21
spot is -- whether you're getting a significant
22
proportion of the leachate that's being generated or not
23
because the rainfall will be a variab1e.factor.
24
Now, there's another concern that Mr. Martin also
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5
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8
9
10
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expressed, which is -- relates to a,different subject,
and that is that contaminant movement along the southern
boundary of the landfill.
Option 6,7, 8 and 9 address
that issue.
Option 5, which is the one selected, does
not address it.
A report prepared by Blake Martin and
Groundwater Associates in March of 1993 at our request,
which we will forward to you, shows that there are
concentrations of volatile organic compounds and metals
significantly exceeding State and Federal standards in
this -- along the southern boundary, particularly the two
compounds mentioned are dissolved thallium and
chlorobenzene at elevated levels he says to the south and
southeast of the landfill.
We will be filing a written
report expressing these concerns in more detail,
including the Groundwater Associates report of March,
1993 .
But I want to reiterate the comments that I made
last week and that is that we are very disturbed at the
failure of the report to even portray the Phase I
landfill in its relationship to Phases II and III in.~
way that reveals what's really happening here, and I
can't help but feel that this is not'an accident.
Mr. Brown was very forthcoming when the question was
asked of him last week but the question need not be
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24
1
asked, and I think the initial posture of the
2
Environmental Protection Agency last week was we have no
3
concern with Phases II and III, they are completely
4
beyond our kin and beyond the scope of this inquiry.
5
I think you all acknowledged last week that you
6
really do need expert advice on the issues that are
7
raised by Blake Martin and Dara Lynott and that is on the
8
impact of the continued open top of Phase I and the
9
expectation that enormous quantities of trash will be
10
deposited on the slope of Phase I for the next five, ten,
11
fifteen, perhaps twenty years.
This study cannot be
12
complete without that kind of an appraisal.
Thank you.
13
MR. BOYNTON:
Thank you.. Now
14
I'd like to call Karen Torti.
15
MS. TORTI:
Hi.
I have a few
16
questions I'd like to state for the record.
My name is
17
Karen Torti, 721 Central Avenue in Johnston, and my
18
concerns are what type of fill will be used in the
19
preferred plan?
Two, where will the fill be purchased?
20
Will the f ill be util ized f rom Sol id Waste Nanagement
21
proper ty?
If so, what portion of the property will this
22
fill be utilized from?
23
I'm also glad to hear last week, like I had
24
mentioned, my concerns about the liners and, also,
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25 :
1
leachate collection system, which I know from reading
2
Hazardous Newsletters that they are totally inadequate,
3
and I am very pleased to see that it was backed up by
4
. what Mr. Blake and Mr. Martin had stated.
5
My concern is, though, from reading this whole
6
scenario that you have come uP' with was I didn't feel
7
comfortable with it and I couldn't really understand why
8
I didn't feel comfortable with it, and then finally last
9
night when I was going over it again, I realized why.
Ny
10
concern is -- like Mr. Perrotta has stated, basically is
11
we have an unlined operational site, which is Phase I,
12
okay, which you have mentioned, now there is one spot
13
called the hot spot that there's a problem in.
14
Our problem is what about the contaminants or the
15
bacteria?
Because I know there's no more hazardous waste
16
being dumped there any longer, but what about the
17
material and the sludge and, also, the bacteria that may
18
be created in that operational site right now and, also,
19
in Phase II and Phase III?
Because the liner systems,
20
according to the Hazardous Newsletter, only last
21
approximately thirteen days and the leachate collection
22
system will only last up to two years.
So what exactly
. . 23
are you going to do to maybe not cause another problem
24
like the hot spot, to prevent?
What type of prevention
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1
2
3
4
5
6
7
8
9
10
11
9
12
13
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15
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17
18
19
20
21
22
23
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will you do to dredge up the material that is used?
I
mean, everyone thinks that because there are liners there
that we are safe, when we are not safe, and because
there's a leachate collection system.
So my question is basically what are you going to do
to prevent further contaminants going into the hot spot
or other areas?
And, also, in relation to that, if there
is a problem with the Scituate Reservoir, I know right
now there isn't a problem, supposedly, from all of the
tests that have been created and have been utilized, if
there is a problem to ever exist with the Scituate
Reservoir, what would your reaction be and what type of
process would you do to remediate that problem?
Also, if a problem does occur while utilizing this
process, who will be accepting the liability, if a
liability does occur?
Has the preferred process been
used in any Superfund site?
If so, how long has the life
of the process been?
I had asked that question last week
and I just wanted to go over it again.
And, also, will
the process have an odor?
My next question is will the
process have any emissions into the air?
If so, w ill the
air quality of the residents in the area be affected by
this?
And I thank you for your time.
MR. BOYNTON:
Thank you.
Regina
-------
1
Marks.
Did I get the right name?
Is it Eugenia or --
27 i
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2
totS. toIARKS:
Yes, my name is
3
Eugenia Marks, I'm Director of Issues at the Audubon
4
Society of Rhode Island.
I hold a Master's degree in
5
Environmental Studies from Brown University.
Audubon's
6
interests in this case are to protect public and
7
environm'ental heal th while at the same time providing the
8
services of an already developed and an already altered
9
site for landfilling solid waste.
,10
He ask that the proposed plan consider the long-term
11
contamination of the upper Simmonsville Reservoir.
We
12
are concerned that erosion is occurring on the existing
13
'grassed southeastern face of the landfill contributing
14
not only to the sedimentation of the Cedar Swamp Brook
15
and, ultimately, the upper Simmonsville Reservoir but
16
that there also may be some contribution of contaminants,
17
of particular concern would be cadmium, chromium and
18
mercury, in the solid waste that's being de~sited there
19
and which may leach as organic acids from the refuse or
20
acidified precipitation continues at, current pH levels if
21
the erosion on that southeast face continues over Rhode
22
Island DEM single barrier cap.
23
Our concern is for the health of f'ish and of any
24
persons who may consume them.
Although risk is low on a
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28'
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, 1
2
3
4
5
6
.7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
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population scale, we believe that this toxicological
pathway should be addressed.
We understand that there
are off-site studies continuing which will provide data
on which to base decisions.
Nonetheless, the treatment
of the cap and the extraction of groundwater in the
proposed plan under which we comment tonight having
impact on water quality and fish health in the upper
Simmonsville and Alroy Reservoirs.
We ask that the possibility of extracting
groundwater from the southern landfill boundary be held
as a contingency should off-site studies indicate levels
of concern.
The wetlands in the area have already
suffered degradation, and I do not believe that the
withdrawal of water is -- could hurt them more,
especially as they would serve as any wildlife habitat.
We also ask that consumption of fish be considered
under recreational fishing, and I was not clear on that
in the current report.
Although I understand that
standards for metals and organics in fish tissue are not
federally set yet, some states are creating their own.,
standards.
We are concerned that the groundwater extraction and
treatment by EPA will not continue in perpetuity and,
thus, we would prefer that the chemical sludges
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1
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3
4
5
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7
8
9
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13
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10
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29 !
I
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themselves be removed as proposed in al ternative No.9 to i
prevent long-term movement of groundwater which arises
from other sources than the landfill, which will be
capped.
This groundwater moves through the area in the
remains of glacial deposits that were not taken during
the former saline and gravel operations and through the
bedrock factors as well.
Since the hazardous materials
are nonaqueous, their presence may last for much longer
than the proposed treatment and may continue to cause the
problem we see currently after the treatment is
completed.
As an alternative, we suggest that additional GO
membrane be installed over the existing DEM cap on the
northeastern face of the landfill as well as assuring
sufficient coverage in the cove around the hot spot.
Although water will not collect and percolate through the
slope in the volume that it does on the cap because of
erosion and the concentration of contaminants in the hot
spot area, we ask that the protection of an additional
layer be considered.
I also ask to what degree will --
the contaminants removed during treatment, what is the
degree of removal on those contaminants?
Surely, it's
not a hundred percent.
Thank you for this opportunity to
comment.
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30
, ,
1
MR. BOYNTON:
Thank you.
Lo u i s
2
A. Perrotta, Town Council President, Town of Johnston.
3
MR. PERROTTA:
Thank you.
My
4
name is Louis A. Perrotta, President of the Johnston Town
5
Council.
I wasn't here at the last meeting, I was out of
6
town, so if -- I just don't knOw what was said and maybe
7
I'll just be saying some of the same thing, but I just
8
wanted -- for the record, I want to relate to the EPA's
9
Docket No. 84-1045 dated June 29th, 1984, signed by
10
Michael Deelon (sic), Regional Administrator, and I quote
11
that report in the EPA findings on hazardous waste
12
manifest on file with the RI DEM, it is estimated that
13
during 1978 and 1979,1.5 million gallons of hazardous
14
wast~ from Rhode Island was deposited at the site.
And
15
from the Nassachusetts DEM, an additional one millIon
16
gallons were deposited by Massachusetts, also.
At som e
17
areas of the dump, the levels of contamination are as
18
high as 34,000 PPB of chlorobenzene.
The substances
19
listed in this report have been shown in scientific
20
studies to have adverse effects on human health.
The
21
presence of these chemicals in the groundwater under and
22
adjacent to the site indicates that the landfill was and
.23
may continue to be a source of releases of hazardous
24
waste into the environment.
Based upon the findings, it
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31
1
is hereby determined that hazardous waste has been
2
disposed of at the site, that the release of such waste
3
may have occurred, may continue to occur, may have
4
presented and may present a substantial hazard to human
5
health and on the environment.
6
In your EPA Environmental News dated February 1,
7
1994, on page 3, it says that in 1986 Rhode Island Solid
8
Waste Management Corporation in conjunction with RI DEM
9
and the Town of Johnston initiated a project to provide
10
public drinking water to area residents as a
11
precautionary measure.
Just let me say this, this
12
project was not undertaken as a precautionary measure.
13
There are many wells in the area and on the watershed of
14
the Scituate Reservoir that were -- are polluted, and
15
that's also referenced on page 5 of Docket No. 84-1045.
16
My question is that if this hazardous waste has and
17
is flowing and poll uting wells, what is going to stop it
18
from continuing?
And if the Cedar Swamp Brook, which
19
flows to the bay, is contaminated, what effects does this
20
have on the bay?
Would your program guarantee that wells
21
further away the Cedar Swamp Brook and the upper Simmons
22
Reservoir be protected?
I know Representative Russo has
23
already implied that and asked that question and
24
Representative Martelli has asked, if these things are so
-------
32
,~
1
severe,
do you have the power to close this dump, if you
2
in your own report say that the hazards are so great?
3
Thank you.
4
l-IR. BOYNTON:
Thank you.
Next
5
is Robert -- I'm just going to spell this, I think it's
6
C-H-S- Z-B- E-R-T- I-S.
7
MS. ROGERS:
He changed his
8
mind, he wasn't sure he wanted to speak.
9
MR. BOYNTON:
Okay.
Fine.
..10
Kevin J. McNichols.
11
MR. McNICHOLS:
Good evening.
12
Unfortunately, I wasn't here last week so I'm not aware
13
of everything that's going on about the project.
Ny
14
basic question is as the Councilman had said, the EPA has
15
already identified a severe hot spot on this dump and
16
labeled it as a super --
17
THE STENOGRAPHER:
Excuse me,
18
could you please speak up.
I can't hear you~
19
tom. McNICHOLS:
The gentleman
20
said you had no jurisdiction on the ~peration of the
11
21
dump.
The State of Rhode Island has seen another EPA
22
site, Picillo Pig Farm, which is one of the top ten
23
Superfund sites in the country.
EPA seems to have a.
24
record in Rhode Island or Rhode ISland has a record with
-------
33
1
EPA.
You gentlemen don't show up until it has become a
2
severe emergency.
And you're sitting here saying that
3
the operation here is going to be under the jurisdiction
4
of Rhode Island DEM, which apparently has a very bad
5
track record in controlling its own problems.
I'd like
6
to know what the criteria for EPA's assuming jurisdiction
7
on this operation will be.
And if you folks don't have
8
direct operational control, what do we do to give you the
9
direct operational control?
Thank you.
10
MR. BOYNTON:
Thank you.
That
11
concludes the comments --
12
MR. SANTILLI:
May I approach
13
now?
14
MR. BOYNTON:
Mr. Santilli, you
15
want to speak now?
All right.
16
MR. SANTILLI:
Thank you.
Paul
17
Santill i, 9 Albert Dr ive, Johnston.
I'd like to know --
18
there's two questions that I want to key on.
I want to
19
know who will be doing the testing, the water testing and
20
the air quality testing at the landfill, and if it --..if
21
the answer's going to be Solid Waste Management and/or
22
DEM, even though I know that there's an oversight of ten
23
percent, I'd like to know why EPA doesn't do independent
24
testing up there with sample -- with these samples going
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34 I
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11 1
~ J
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
out to a lab out of State so it has nothing to do here in
the State of Rhode Island.
And I would like to know --
for obvious reasons, I'd 1 i ke tha t question answered"
and, secondly, while I know that you're here because
you're supposed to be eliminating the hazardous waste up i
at the landfill and containing it, the question that I
have is with the landfill surrounded by three reservoirs
and acres and acres of wetland, why EPA does not get
involved with the Town in shutting the entire landfill
down.
I think that that would be the best alternative
with all the problems that are going on up at the
landf ill.
This is the first time we're having EPA come in and, i
obviously, I know, again, for the hazardous waste, but I
think you have a greater duty to the Town and to the
I
,
I
that that entire I
people and to the environment of seeing
landfill is closed down.
Thank you.
MR. BOYNTON:
Thank you.
That
concludes the comments that I had on the cards.
Are
there any other comments anybody would like to make?
Could you give us your name and address, please.
MS. CERRA:
Councilwoman Mary
Cerra, 975 Atwood Avenue.
MR. BOYNTON:
Can you spell the I
i
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35
1
last name for --
2
MS. CERRA:
C-E-R- R-A, simpl e.
3
MR. BOYNTON:
Thank you very
4
much.
5
MS. CERRA:
My first question is
6
does the cleanup plan that is being proposed fit into the
7
State master plan approved by Statewide Planning?
8
Ques tion No.1.
How long will it take to complete this
9
project and how effective will it be?
I know I' m
10
repeating many of the things that were said but these are
11
questions I'd like answered.
Are there Federal
12
regulatory guidelines and how close would they be working
13
with all of the other agencies?
How safe is the plan?
14
what. will happen to the trenches or pools of liquid .that
15
have already been pinpointed there by satellite when EPA
16
was doing their investigation?
17
As we know, there are many, many of material was
18
dumped into that landfill, and I have a newspaper article
19
here that does indicate much of that.
I can make a copy
20
of it and I can leave it to you.
It's dated November 21,
21
1989.
When I mail my questions to you, I can also send
22
you a copy of this newspaper because it surprises me to
'.23
see that in the old photographs there are obviously
24
trenches of pools of liquid Robinson said is not your
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36
il
1
typical solid waste.
For about three years, the
-- "
2
Sylvestres took in liquid waste pouring them into the
3
three trenches and letting the liquid seep into the
4
,
ground. So, you see, there's a lot of trenches here, as I
was pinpointed by EPA satellite. And my concern is what i
will be happening when you're working with this proposed
12
5
6
7
plan.
8
We know that this all happened in the 1970's, we're
9
familiar with that.
I believe that was much discussed at
10
the last meeting.
In the Seventies there was a lot --
11
like the Mayor said, we're all saying, where was EPA
12
fifteen years ago, and who and how many agencies were
13
responsible before the -- whatever comprehensive plan,
14
before any regulatory guidelines were in effect and who
15
else was responsible for dumping in this area?
I just
16
feel that, ironically, you'd be surprised when you read a
17
newspaper article and find out.
Okay.
So you will have
18
the newspaper article mailed to you at the time of my
19
Questions.
Thank you very much for having me say a few
20
words.
21
MR. BOYNTON:
Is there anybody
22
else that would like to make any comments?
The comment
23
period will remain open till March 14th and if you think
24
of something or you want to mail us comments, you can do
-------
37
1
tha t.
The address is on page 5 of the proposed plan.
2
And if you do have any questions in the meantime about
3
commenting, you can call either Amy or Jim and I believe
4
their numbers are in the proposed plan.
I want to thank
5
everybody for coming and giving comments.
This hearing
6
is closed.
Thank you.
7
(HEARING AOOOURNED AT 8:10 P.M.)
8
9
.10
11
12
13
14
15
16
17
1"8
19
20
21
22 .
23
24
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1!
- .J
STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS.
PROVIDENCE, SC.
I, MARY M. GUGLIETTI, do hereby certify that the
foregoing transcript is true and accurate according to my
stenographic notes.
IN WITNESS WHEREOF I hereunder set my hand and
I
I
affix I
my notarial seal this 2d day of March, 1994.
(~y Commission expires June 23, 1995)
-------
ATTACHMENT C
WRITTEN COMMENTS RECEIVED DURING THE
-------
UNITED STATES ENVIRONMENTAL
PROTECTION AGENCY - REGION 1
JAMES BROWN. PROJECT MANAGER
AMY ROGERS. COMMUNITY RELATIONS
FEBRUARY 28. 1994
RE: E.P.A. PUBLIC MEETING TO DISCUSS THE PROPOSED
CLEAN-UP PLAN FOR THE CENTRAL LANDFILL SUPERFUND
SITE (JOHNSTON, RI)
I attended the public informational meeting on February
22, and February 28, at 7:00P~I. The meetings were held in
the auditorium of Johnston High School, Johnston, RI.
I would like the following comments/questlons to be
consldered as part of the hearing process and be made part
of record.
1. DOES THE CLEAN-UP PLAN THAT IS BEING PROPOSED FIT INTO
THE STATE MASTER PLAN APPROVED BY STATE WIDE PLANNING?
2. HOW SAFE IS THIS PLAN?
3. HOW LONG WILL IT TAKE TO COMPLETE? AND HOW EFFECTIVE WILL
IT BE"
4. DURING THIS PROCESS, WHAT WILL HAPPEN TO THE TRENCHES
AND/OR POOLS OF LIQUID, ETC.?
5. ARE LINED LANDFILLS LEAK-PROOF?
6. SINCE THE TOWN DOES NOT OWN THE LANDFILL, WHO WILL HAVE
TO FOOT THE CLEAN-UP BILLS?
Enclosed are newspaper articles that were presented for
any information that may in some way help to assist you with
your proposed plan.
Sincere y,
-)}[tLi~ C--t(.,./L-
Mar Cerra
Vice President
-------
(j)
rHF. PIlUVIO\:NCl JUUIINAL ,UULLETIN
'l A":',
- Ij~J
.s.JL¥('
"f -; \ Je! (,.' "J~.,
C)J;I.> 1
rJ-I
lQ '7
WASHINGTON
First federal landfill standards will require regular n
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W ASIIiNGTON --. In an effort 10
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drinkinJ: watrr. the Er1\'ir'Jllrnt'l1lal
I'rol.'clinn i\gP'H'\' ~'I"tf'r'la\' 1111.
vl'ih.d the lirst led""al ,land;lrol" 1,.1'
l"n,lIilk
Th.. nalion's li,tHIU laI1tHi~:.' will
1I,,"'r I" install 'I','(ial cif',,'i(.,s tn
IllIIl1itll" the 1110\'1' III'.' II t ,,)i :,111111:1"
/(r""nll cnntalllinanls, (I"al' "I'
!(rolll1d watrr polilited h,\' t:'ash al1d
cover I,he dlllllp daily with snil to
prcvrnt pes I infrslation, Nrw land.
fills will ha\'" tn III' I'illlllll'd wilh II
sl'f~cial clay and plaslic liner 10 prr-
Vl'l1t I.!ak~,
lilt! 1'11\ irnnmen!~~~i>' ,,~',:;',~~,.<~,:.',: . ':,'.:::, ;',::" >";~/"~:'::):~\;'{It,'('r~~:!:\\~l.';::\...;!.;
~
-------
. .. ". -.. .
+'t'l L~'
, ... . .. ~ .
THE PRO\,If)r::'\CFc JOt.;R:-':AL.SL;LU-:TI 'i
I 9'( f..,
RHODE ISLAND
/I
.~~
Pollution check OK'd at state landfill
$275,000 study to
aJuae threat to
b b
Scituate Reservoir
waste dumped .:It the Rhode Isl:lnd by thl' U.S. ~nvironmental P~otec'
Centr:lI L:II1c1fill ill Johnston is ti"n l\gl'ncy. ''''hich was concerned
lhreatening ground water in.:ludir.g 3;)0ul pUII'm:;:l contamination from
the waler supply for more than ha:i h:LZ:Ird(.us waste dumped at lhe
of Rhode Island. I:Jndfill.
The Rhode Island Solid Waste "We know hazardous waste was
By BOB WYSS Management Corporation, which dumped lhe~e in the ~9iOs, and \l"L'
Joum~I.BuU.tin Swf Writer owns the landfill. approved lhe W;J;1[ to know where it is goir.g,".
PROVIDENCE - A $275,000 study, which willwke 25 months l0 l'xplainl'd Ke::neth Wenger. project
study was apprO"'ed yesterday that complete. It stems (rum an adminis. manager (or the EPA in Boston.
is designee! to discover if hazardous trative order issued in June, 193.;. The sludy will try to see if po!!u.
, ,-( ,~- :I~"-"""- ,..,;,.;~- ,-- ,,,,,;;''\:;r:"\~-~ ~. ,-, ,-- ,-, '-' ,-- ..' tiol: has infi!trated ground waler
I ~~~""":""""".""R'"-~-v.~"""~'V"~""'-'::"~ ~-; -=:--...- ,.:,.,. ~"~~"~""~""~"~~>' around lhe massive dump anu
"'" .. . r ~ whether it is threatening the wells
I. , (J{" . ~ of nearby homes or the Sci~uate.wa-
~ I S" ~ tershed. the primary water source
~-JL.-~''t 1& I 1 ~ ~;.".":.~'" "'" "","""din,
Q,...ll1)t:/ ~~:' Pollution ev.Idence lacking
loi -
7 4 Wenger said that there is. no
~ strong evidence indicating that pol-
~ !ution from the landfill has entered
~ the Scituate watershed or has
:fj. caused problems' in wells still in use.
~. But. h~ added~ no firm conclu,sions
;. ., ~ are possib}:..~~_~.~.~~is' fi.t;1.-
)~. . The ~~~y will determine only if ;.
~. f problem exists and how serious it is. -
}..;-r.. After that. Wenger said. the options
i ~ range from doing nothing to closing
i '« the landfill ane! launching a massive
I ~~ cleanup. While the 1a.ndfillls on 'the
I federal Sup~rfund cleanup list. .
i Wenger said. the corporation would i
\ ~ probably have to pay for any ,.'
\,~ cleanup because Superfund money /.
\ ~ is used only as a ~ resort. . /
, Records indicate that more tmfu
1.5 million gallons of h~ous
waste were dumr.ed py1978 and
~ 1 'hell th~id:fill was owned
~ by Albert an l.nthony Silvestri.
~ The corporation pdd $10.1 million
i€ for the !a8dfill in December. 1980.
~ . and Albert Silvestri rem.a.ined a
~ $500-a-montb consultant at the fa-
~ cility until he was disinissed last
~ month. .
. ~ Albert B. West, lawyer for the
~ solid waste agency, said the Sl1ves-
~ tris will be asked to' pay for the
'... landfill while he owned it and that
- "r th, "'.....Ooa', pu
-------
. ..'...
Ii. ::~\::~;;l;;;~~;;~ P~~bl;;;1~ h;d"l0 h~
: filed by .!\.::1c. 1982.
I \'v'est re~pvnded that the Silvcs,'
: :r:., :~;:,;., ~~;.":::ltedly been put on no-
: licc :!~ey wo\.:id be liable for studies
I s':C:1 a;; this one and that the June.
1982. date docs not apply. He also
conc~ded the claim will probably
...:. . .- :.. --'. -..:~~~..-:
II 'r;l\' iJruJt:';:. callt:d a hyd:Oc;':ulo-
gic s:uJy, in ...olves a series of tests
of t!H' gro1;r.d water including the
I <::;.:::::.: "f :21 new wells in and
\ :::v~I:~ ::,.; ...:\.:Ifill to sc:u-ch for con-
wmin:.w:S. The work will be con-
c,..c:cd :JY ci~gineers for Goldbe:g.
ZOln0 I>: As...:>ciates (GZ.~) of New-
ton. ;\1;J.SS.. ;.md Wehran Engineering
uf :-'\iddletu'xn. N.Y.
i\licl1::el powers of GZA said th:lt
the results will then be analyzed and
the pott:ntial health risks on sur-
r"a:-:Jillg rcs:dents3SSessed. The de-
~;'cc (/ ~:,,~ will dete:-mine what ac'
tivl1S shuuio1 be taken. he said.
t\ grouP of Johnston residents or'
gani:l:cd as WATER (We Are the En-
dal1gt'n~d Residents) filed suit to
close dUW'1 the landfill because of
con<.:\:rIlS that pollution was poison-
ing t::':~i wells and the Scituate Res-
er\"ui:". .
\1;' ,\ TER recently settled that suit
on the condition that it recei\'es
S35.000 a \'ear from the solid waste
agency so' that it can hire consul-
tants to oversee work at the landfill
and 0:1 tr::s study.
T::,' -.:! N. Smithfield Cumberland Greenvtll~ Johnston
INJURED
A T WORK?
I;: so: PETITIONS FOR
6::-.IEFITS will be filed and
tned before The Rhode Island
'Norkmen's Compensation
Commission by an atiorn!'(.
AT NO CHARGE
OR COST TO YOU
Fees Paid By Insurer
Excluding Commutations
ROBERT C. HOGAN, INC.
-------
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JOH:\ST(;~; - ':'i.,' S.;,,,:c ;;,,:-
tich Co, of E:ls. (jr""nw,.:h "':~.::"
vertently" dumped 400 pou::Js u:
sodium cyanide at the Slalc'S t\:l.tral
landfill last month, but state om-
cials say it poses no immcdi:lle
threat to public i:.':.llth or 5:Jf.'I';.
1\1:.1:1 (j~lh~~,. l'nvi:";.,a:al':ll:J; sp".
cialisl for .hl' ",jr:lpauy. ye~L'rt!;..,
told st~i.~t\ ,Jf(:~::.:.:;o; ':l~llh,-, .:b.\.li.:~.:
Vv'a~ :\l"ri :;I! tak-
en to the landfill, he said.
"We realize it's a il:1I...'.:""'.'
waste that came here," G.H,'; :;;;;"
yesterd::y ::ftc'moon after m"d:n;;
with st:1te officials at the landfill.
"We admit to that. We want to co- THOMAS WRIGHi: director of the sC3te Solid Waste M:ln3gL'mcnt Corp., says
operate" with the investigatiC'o and mediate danger from the dumping of sodium cyanide a.t che~~te's cencr:J.ll:mdf
cleanup. -1';.,
Gates declined ~o el~boratc on cleanup ~osts, and the company The site has bee~ roped off :md C
what h:lppened. s;JYlOg his comp:lny could hI' (Inl'd. co..";,,.! wi.;; ,,1...-;.,,-. S:.a;.ky..!k;s-
was still investigating. The compa- Thom:l..<; Wright, director of the tich has hirE:d M:lcDo'1:11d and Wat-
ny manufacturers staples, nails and st:lte Sol:d Waste Management Cor.. son Waste Co. to test air samples
other fasteners :lnd fastening ~quip- poration, said landfill crews have i!nd drill to d.;t"r;nir:e eX:lctly
merit. The\' use suuium cyaJ:i~!.: in identifi~d, through daily records,:; where the chemicals are :md wheth-
their manu"facturing prucess. 40U.. by lCO.foot :lrea 30 feet deep er they could - or sh.luld.- be re..
where they think the sodi'lm cya- moved. '
Several agcndcs prou;:l~ nide was buried. Wright said th:J.t 'he rocklike
Several SlatC agencies are :I~SO in.. "Right now we dun't see any im- chunks or ~cdium c~"~ide were bur-
vestig:lting because it is iHcp,::l to r.:t'r.liate d~nger" caused by the haz. ied in yellow bay.: and open pails
dump haz:!1'dous waste in Rho.:!,: Is.. :lrLJous material buried there, but that thev mav :Je difficult to find
land. Officials said St:mlt:y-[',ostich Wright said, The area, however, is bec.aUSdht:;: ha':" no m::rkings indi-
will be responsible Cur le:;Lip.i: anti still being testcd. cating th:lt the ~onlents are hazard.
___---"H.""'" -- ..,.. .--' -".' ~ -... -:-.....~;::".-;;.;~,..._~,",,! . ous.
MacDon::~j :lnd Watson will also
test similar chunks of sodium cya-
nide from the Stanley-Bostich plant
to determine potential dangers to
the atomosphere 'or ground water,
Wright said.
Robert Bendick, director of the
state Department of En\ironmental
M:lnagement, said that one of the
biggest concerns is that the cyanide
will mix with acids or acidic leach-
ate at the dump, creating deadly hy-
drogen cyanide gas.
No cy:lnide was found in air sam-
I';' '1.'1 ,~ ..
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~.1.~-~......-J,..~._'f 'V.1;;' "''''''.;..0;.-:.1.......'* i
..;
Poison vias mixed
accidently with
tr'l<..l1 "\.."T"nn'!n'," ,: ",',,<
c...... ) ~ .. \.. . ~ . -~. It,..' . ..' . .'. .
B;. ;..\, ~,:,'. ,'.iE:" :;:
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110 '
l$hoppes
rs BIRTHDAY
f~;7",';:4
STARTS
TODAY
~
-.a.
"'W'
~
~
-.c
£
-w-
.~.
..:.1)'.: -';
'.-::." 'T
"';:" ,..
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-JUi.O.rll~l.u..:ilc:~n Ptll.
'Itisor
fatal poisons
ing the body
gen. The hec.
are usually c
"tcant
gaseous fer..
taste and OC
Inhaling as fI:
of the 93s or
3CO milligrarr
causa death
ITem secon(
ounce equa~
. CyanidE
in certain rc
silver and IT
graphic soIu
products.
. Symptc
clude nause
anxiety. con
feeling of Sl
-------
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- -.. ,',
on
"!n;..
.:-iirr
Cleanup' costs. :lod the comp:lny
c0uld hI' fir. rc1 ,
"Ii" "".s \\'~:,.,.t d;rt!ctor of tnt:
st.1te's~iid w;;~~'M:ld:lgement Cor-
poration, said l:lndfiIJ crews h:lve
identified, through daily records, a
400- bv 100-foot area 30 feet deep
where - they think the sodium cya-
nide \\':!S buried.
"Right now we don't see any im-
~rdiat" danger" cuused by the huz-
a~~()us m:lteM:l1 buried therl:,
\V;-;ght slid. T!;L' :IrL'J. f!owpwr. is
srdJ bl'in~ It'stl'U.
:md
'Jip-
: in
The site has been roped off and
~O\'c:u': "'."'.:. :"'u"':' :':~:':'- :"
tich h:ls hired ;\1:lcDoi:.:;id :lnd \;'':r of t~I:'
state Departr.:cnt of Er....iruuiI,cr:t..:
i\-Ianagement, .".;lit! tll:l! one f,i ~h,'
bigut!st <.:onCl'rn~ is [hut lJa: cyaJi:d::
wili m.ix with adJs vI' aL'idic leach-
atl~ at the dump, crcatirlg de;:d~;i (;y'
drogen cy:mide gas. "
No cV:lnide was found 10 :llr S:lm-
pies taken yesterday, l:!enciL'k :;:Jd.
I u~:) i.. ~~C'Y1't :lnn~:'r t}-lii- rhprp':.; anv
h~;d~~'~~~ith'~t this timc."
However, a permanent air moni-
tor will be instuJled, :lnd SLate offi-
cials will monitor the ure:; to ens\..n:
I that thc' .chemical d,oesn't SP:~;ld. (.~:
I dissolve mto g:-oUn(l water. jj~ndl\."
[ said.
I
in-
tu
..
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i:d
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STARTS
TODAY
iHDAY
.'T V
~L~
.
:zne
)
A notification first
Bendick and Wright "'-lid that this
is th., first tilll(' th:.:t 111l'y've I)\:l'u
notifit.-d of h:LZardous W:J.Stc being
dumped:lt the landfill.
. "The company reported it to us,
and th:n's a first," Bcndick said. "1
can't rC\;all a comp.1ny reporting,
'Oops. W.:: put a bunch of stuff in
the trash and it got taken (0 the
landfill.' ".. I don't rec:l1I a situation
like that." ,
The Solid W:lstc Management
Corporation contructs with Muc-
. ",.." -,:::""" :::.) ,'.7;-
Cyanide facts
I
I 0 :: is (;ne of the most rapidly
I 'Z:ul ;:c:s~~s ~now.~ to man. block-
:l1g the t:ccy s abd'ty to use oxy-
-;;en. The r.c3rr. brain and kidneys
I :;:i: USu~!ly attec!ec first. .
I $ ;! :In be In powcer. liquid or
: :~~:"-'::; ;:;:::: and typic::ily has the
i :':~t.e ;:1.:: ',.:er of birr.er almond.
: '. ":''''''; ~:) :,\lle as iOO milligrams
! ':i the g:;:; cr S"Nui:owlOg as little as
3X miili;rams of cyanide salts C3n
c::u~;) lie" ,h in a peried ranging
fr~:n se:c~C$ to minutes. (An
~U!lce C(i;;~:S 28,350 miiligrams.)
II CY:lI1H:,~ is cOmmonly found
.r, t.:t:rram (J t and pest poisons.
~::ver at'd ~"'tal pelishes. photo-
I :';'~:;~IJI: ;;,,:,;:,:)os and f~miyating
i ;:;:'~'(1uCts,
: $ SYrI';:!oms of poisoning in-
I L;:.;de f1Jt.:se3 without yor:niting,
I' ;:::-:;(,~ry. c"r;i;;siOIl. S!~G!;snng: a
ii:::!:ny of st.:Hccation, lower Jaw
I :':.ii!:t!~,;, c::;n~u!sior.s. paralysis
I Jr.c ::oma. Re(;overy from ;;,,: ,:11-
l ~:;~~':~~::";c;:~n~:~;;e~~;~;':;' :::: I:
. ~--" ~--. ~~
Dor.:::!d und Watson to check t:very'
10;:<1 of tr;Ish that cnters the landfill
to ensure th:lt no hazardous materi.'
als are dumped thcn~- But. Wright"
~:::u. :he th,ce'rJ1un crew c:mnot in-
s,.,,'::: :JII .i,ti\1U tons (If trash dumped
~f [!h" bla!EH cvery d~y. A.'ld t~cy
;wgi:: lIot h:..\e recognized tbt: sodi-
um c'>anide, anyway, he added.
"'f.,erc's ne\'er any guarantee
lh::: hazardou;; waste isn't going to
ge: into thc landfill," Wright said. ;
Ut:t Johnston Mayor Ralpt,.
aHussu s:;id he's going to insist on:
striC[t::- monitoring of l'\'C:Y load or
tr:!~h" .'1 Ulir:k they should have a
gu:!r:!llt(.c th~t this wi!: r:c:\'er hap-
p~o "'-gain." .
/ '~
~~
.'"
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f\ "
;
-J.n. "::..,.a:.tlleun PtloLO
IEIGHBORS: This 1979 photo shows the proximity of the Rhode Island Central Landfill, the former
"i1vest . th? Simmons Upper Reservoir in Johnston. --
--~- ~
Satellites pinpoint S(jurc~
of toxic waste in Johnston
needs mor~
neighbor tt
Bv BOB JAGOU:-.;ZER
Journ.~.BuUetin Sl.tf \\'rH.:r
S,,-UTHFlELD - Tht, cti"putl' be-
tween the town and thl' ,;talc' De-
partment of Transpo:-tat:on ()ve~ an
indoor salt storage facihtc'. which
appeared to have been Sl"!:ln! last
week. is apparently about tu he.,: tIP
again.
This time it's a property u\""'~'
Richard Conti. who wants the t,,','.n
to act. Conti's land abuts lhe -I:"
chosen for the barn at the inte~"n .
tion of Washington Highway (Routt'
I !6)and Douglas Pike (Route 7),
Cunti, through his attorney.
James P. Marusak. has Sent a letter
to lhe Town Council asking it to
force the DOT to comply with tOWrl
zonin6 and environmental laws be-
fore the facility is built. The letter is
scheduled to be considered at to-
night's council meeting.
Specifica!ly. :-lar'Jsak is urging
the- IOwn tu f()~cf' thi' DOT to get ap-
pro,"al uf [1011: t!l,' Z,)nin~ Board of
R('\"i~\\' anct th," h.\':n's so~i ~rosio("j
off\,'t" twill:-" ~1:-\,\,..".t"'ding r~l:'thl':"
~.:th dHl,lt"\h :1'IIL
~1..~uS;I" ,-,Ill th~ stalc's sitl'"
Whllh lllllll'r,,,,-" ;,o"ullwO acres, j,
Z,1!:,.,1 fllr H:I:...,;t~ial U~. "A sal"
st"~;,!:" f.,,:1::~" " nllt permitted ir
;111 i(~d\."tri": leitH' without a vari.
,.n.:: f~or;: tr.t" Z.~.r.lng Board:' h,
:..,ii;;.
":-:."t: ')\':::> "C()~t 13 acres of Ian."
t;:",: ::.:>~::' :he :'!.ate property on bot
~"".:". t:a:iier this Year, the counc
ru.:>:,.ed it from industrial to villa~
c0mmercial, Marusak said.
CC'oti wanlS to put in a shoppir:
centt:r, with half a d07.en stO~e-s. a:'
he fe-ars the pr";,, ~_.; 'x;:i '" .:',",.,
ued t>v th? ,i.::' :.h :..:", : ;;.'. ..:""
other 'conel'ms :;\Jet! /1:1' Lra1hc th.
the fJdlit)' will generate. would I
~addrF..sed at a ZoolngBoard hea
Ing. Marusak added-' ."
"bOT wants to build an enclos
...., .~".:..:.: .....it! aliuw ::;HNSTON - Usually the gov-
lent's spy sate!lites spend their
monitoring fleets and armies
.nd the globe. But last year one
ed detect a different enemy -
under the ground in Johnston.
t the time, federal and state en-
Central Pike
-------
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. ;_..~:).
/-
If:\
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\ .:1
'-.. -'
..-..
-Juurnal.Bulieun 1'11010
NEIGHBORS: This 1979 photo sho\vs the proximity of the Rhode Island Central Landfill. the former
Silvest,ridump. to the Simmons Upper Reservoir in Johnston.
i Satellites pinpoint source
! I of toxic waste in Johnston
""-----,-L... By' JOHN mLL' ~~~' '-5/~,,,,~_-:/i-,:,'~>--j,., ...... . . ....... .
Central F-ike
JOHNSTDN
f"'" -,...,~~.~~?",'-t\: ..~"_.
I!~,..';"'..
;' ,'"''- '
: \'
i
LEGEND ;
.
R.I. CENTRAL LANDFill
Size:
Conlamination found:
Superfund designated:
. Buried trenches and' ',/
proposed !"oniloring ,/~{
..111._. 0 ~
154 aeras
1983
1984
-Joumal.8ull8tir Graphjc:
Conti Wanl,
center. with h"
he fears the ~
ued by the' ,
other :onc~
the facility WI.
addressed at "
lng. Marusak a
DOT wants
barn lilat wiU .
be stored lnde
, loaded into tru
'\ covered or icy
I
)
Tov
in Ie
By HEU
J"IUUaI.B~
NORTH PRC
dence attorne:
who represent,
in its court figt
lng Corporatio
completely pale
McAllister h.
der earlier this
ministration pa.
the first pan of
The case off
tember when th
ed liot co appea'
cision that a1.....
keep a dispur'"' "
urn building "-
minium Compl,
McAllister ti:
for $3.686.60 f
dOlje since he
check.
But now, t:
McAllister StiU r
This time It '
has apparently
McAllister. Co
10011. of the co
mittee, said th
bogged down \
Thanksgiving games still grid se:
'60~.
'"That was against a tough {Fran:
'Monk' Maznicki team:' he recalled.
had a quanerback by the name of (B
Cornell who was real good and the g
was scoreless when I got hurt and ti-
me to the hospital. .
"They put seven Stitches in my Ii
sent me back to the field. 1 was surp:
game was still going on. but they tol
hell broke loose just alter I left," he
continued. "They told me there had;"""
brawl and the Brothers took the ter ,
field and made them aU sit in the bl
or 15 minutes to cool them oft. I still
know what started it. but they told r
players. fans. everyone got into iL V.
the game. 6-0."
D...._..._l.....-l....,..... ...._-_.~
Local g:idders are keeping one eye on
the football and the other on the turkey this
final week of the regular Interscholastic
season. Two of the four contests in the
Metro West area will have a bearing on the
final division standings, but neither will play
a part in Citizens Bank Super Bowl XVIII
one week from Saturday, '
Football on Thanksgiving is as
traditional as grandma's dinner and mom's
apple pie, As traditional as eating tov much
turkey and falling asleep in front of the
television set watch'jng whatever ball g~me
that happens to be on.
The longest running Turkey Day ~ries
in this region is bet ween Smithfield and
North Providence with this year's game
marking the 20th meetinl( between the two
Bowl appearance against Central. While the
Cougars have the usu~i bumps and bruises.
the S.:ntin..ls may nave r.> go without senior
quar.erback P,J. Williams who is n:cowring
from a separated shouider he sufCered liste in
the season. Coach Jim Dunn says there are
probably seven or eight players who may
miss the game because of injury or illness.
but Nvrth Providence's ~mie Pina knows
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...~-_.--'- '
,~ .IO..W j C; ...
~a{ell]leS pinpoint source 01
, .~~._-~~>;(y~l ~';
I. Th. M",o W." " ,~,~ of -
rior Ca'.lrt ordered the operatiOli
[O~;.i\..
'~\ 'aste
closed in 1978,
The F.i'A esti:nates it can destroy
~or~ tr.,ir. 99 ;:h::'\:ent v! the con tam.
!!!Ld::1g \)i6J.t1ic ~vm~vul~JS by bur~-
ii:~ the sui: i~ ;j high.Ll'!11perJ[~1re in...
;':,::'\':":11,\;:-', 1~!:\.' e:d:~ll:..;t \'~'~1I. go
~!.:.r.l..:~~ ..i: !;:~i:!" ,:.'qU;pl~lt"!1l Q~ture
:'l'i:Jj: ~.I'::';t:...i'('i ::itO tlh' ~tnl()~phcre.
'!'!ll' :n';ltl'cI soii will be tested for
,:".,,:.. :!~.'l;lt:\, '..\"hi~:l ;l!"(':~'t dc...
::':.' :~l~: :'.' :n....::1t'!"'-LUUD, Cll:~:' soil
'::... :'w :.St~c! :1,'; fiii. and s..il that re-
rTl~U~~ '::;!1tanH!1atcd \'.'iI( be dumped
;0: a spt'.,:i:llla::cf::! p~epared accord-
ir:~ l(; !'(.,jer~!1 ~'.:ide:~nes,
::i,~ !h,' g,o'~nd wa!,'~, F.PA wants
t:-: ":;:;>111\' wi:a! it .:a:ls the "pump
ani: !:.\:~!t" :.i!tt:'r~al:\'e, Extraction
, , ' .
',;"j'::., \\',::'11\.1 ii\.:!11jJ t:le \\'3lr!" trom
t~:" :t,::~i[P:"'$ ;'H~d :
-------
G)
THURSDAY. SEPTEMBER 12, 1991
A-6
:INGTON
"iVill require regular monitoring
':car, None of Ihe garhaKl' meets the
i',l'i\ dclinition 01 "hazardolls," IIlIt
:ignilicallt {Iallgers arc p{osed by
umsehold pesticides, mercury in
"'rtain paint:;, II!iut in hatteries :lI1d
"cw,'print and cadmium in pla::ti\:
,'r\lduCIS,
Nl'arly a IIUari/'r ..1 thp n:lli\ln's
"orst tuxiC'-\.\,'uslt. ~ill\s are. forll\""
uullills, alld Iht, U',\ Illulld \:1111'
,lIninated ground water at I 'Ii;
:lImps in a I !18~ stlldv,
I-:PA ,\dlllinistrahH' William :\,
:l'ill~' :;aid Ih,' 111'\\' ;(,.llolar.I:; ",ill
"assure the integrity" of landlills,
The rt!lIlIirement to monitor the
ground water of active landlills
twice a year - and once a year for
clo:;ed dllmps - "'iil rcsult in the
.j,.'~t!Clir.H1 \IIHI cIl)\\lHIj' I..f contami"
nants bl'ft'rc th,~~' i'I:~'::1 community
water supplif's, 1\1,:11\' said, Fewer
than a qllart!'r .11 landlills n(IW rt'gu-
iilrly clH'd{ ',.'r 11I1dl.'r,;;,lIund leaks,
:\mong th~ pr"visions criticlled
;,-.. "lI\'irllnrnenlalists is an exp.lI1p'
lilln lrolll tl1f! lin~r rC'IlIirenH'nt IlIr
';lIIali t:l'lIlInlilliti,':; tl;at h,I\'" 1111
practical alternative to landfills. AI.
len Hershkowitz, of the Natural Re.
sources Defense Council, criUclzed
the regulations for, failing to require
the cleanup of surface water pollut.
cd by landfill leaks and the treat.
ment of certain wastes :Jefore they
enter landlills,
I>lIn Weiss. {If th.' Sierra Club,
said the regulation gives too much
authurity to states tn create their
own c::.:-.::". " -""::",, ,,"':'~\:::;";'.::;;:'.~~:~~;..;:...,~~-:".:';\"'.~'."'..{'::'.:.,::";"'~'::',~:'''~;;,~~,~~'',,":.:f..I.
: ~ .September.:';,~,1,2~~" ,1:,3~~~""~.~)t~!;~:~\:~,~~,fi}::~'~d:,J;~~,~:",,,:;:,
.') ""'., '"',. '. ";" ...."' " ,",.', ',' " ..,'.I,-.....~./- 0..1......-.. " ".'. '. :.." ,.J.I'I" ..1...1.",'1..", .,
n
't~~
~
'"1~.
-~t.'," 1, ""
..: h~!.1} ..'~' ." h,.
rtt-,,,, '\}I;.", ,;"J~~))<"
,-,...¥.,,'i."', ., ,
I~;~_'I
'f,~,:,< ).
~r~. '
'~~.~"
-.';,""
t'j,'
-------
.f'. ,..
,"YJ
:OJ.}
,s.
~ At
~g :
1St
Jt
tion of risk-taking - finds its roots rn me D1DU(;J.i
story of Adam and Eve's partaking of the forbid-
den fruit.
"They took a gamble - I might say a very
large gamble - and we are all paying the price of
~.l;.5 ...0 ;.,;.,,~ ir~ ... -- .. ., .J .
is on the increase. And while the num!;", ~ '.'
questions remain. .
"This is a relatively new field," Labonte said.
"We're basically at where alcohol treatment was
. :l:Y g ...'W. L.
"A;; the I
"But it's estiJ
who gamble'
"'\. Public EP A meeting
~ on Central Landfill
ry\
'K . Hearings will be held later
~ on the impact of .
, \4 c~ntamination off the landf1ll
~".~ sIte. an EP A spokeswoman
.. N said.
\
By JOSEPH R. LaPLANTE
JcKinIaI.BuIIecIa sun wrtlel'
~ JOHNSTON - The U.s. Envi-
\j ronmental Protection Agency will
J. ntroduce its plan for cleaning the
" Superfund site at the State Central
)) Landfill at a public meeting tomor.
f'\ ' row evening, when it will report on
the extent of contamination and .
he&1th risks there.
The session. originally set for
Feb. 12 but postponed because of
snow,. will start at 7 p.m. in the
Johnston High School auditorium.
The federal agency proposes to
cap the final 89 acres of a landfill
section designated Phase I and to in-
tegrate It with the cap on 32 more
acres now monitored by the Depart-
ment of Environmental Manage-
ment.
The agency also proposes to
pump out,and treat contaIninated
ground waUj from "hot spots" at
the landfill. It also plans to place
deed restrictions 00' ground-water
use and land development in the
southern end of the buffer zone sur-
rounding .the landfill. which Is
I..
,~
owned by the State Solid Waste
Management Corporation.
The agency's plan will also be the
subject of a public hearing next
Monday at 7 p.m. in the high school
w~tori~ .
A separate pair of meetings will
be held to discuss the impact of con-
tamination off the landfill site, said
agency spokeswoman Amy Rogers.
The Central Landfill remains the
major dumping site for trash in
Rhode Island, receiving about 85.
percent of the state's sqlid waste.
Governor Sundlun last summer
released a set of goals for the Cen-
tral Landfill that identify a sequence
of four new landfills that would re-
place the closed 121 acres that are
the target of the cleanup, by using
the remaining 33 acres on the 154-
acre property for garbage disposal.
Together. the new landfills -
called. Phases II and III - could han-
dle the state's trash until 2023.
which angers Johnston residents
and Mayor Ralph R:. aRusso. who
signed an agreement with the sta~
in 1989 with then-Governor Ed.
ward D. DiPrete to close all landfill
operations by July l.
The agency will hold the Feb. 28
meeting so that the public can make
comments about the cleanup plan
and submit statements.
,
Gasoline spill shuts down section
of Route 6 in Swansea for 5 hours
SW ANSEA. Mass. - Asectlon of
Route 6 was closed to traffic for
. . about S~ hours, undllO last night,
. : after about 30 gallons of gasoline
, " spilled onto the roadway from a
: pump at the Cumberland Farms
Store at Route 6 and Maple Avenue.
Minutes after the highway was
closed, at 4:30 p.m., nearby Bushee
Road also was closed.
Fire officials said a hazardous
condltion persisted when the gaso-
line mixed with melting snoW and
drifted along the high way.
Firefighters and employees of the
state Departments of Public Works
- - . ... . -. ._.,.
and Environmental Protection were
still cleaning up the scene at 11 p.m.,
said a spokesman for the Fire De-
partment. .
The area of the spill Is not far
from the Coles River. As a precau.
don, the Coast Guard and the Spe-
cial Hazards Unit of the Seekonk
Fire Department were also called to
the scene, the spokesman said.
The cause of the spill was un-
clear. A pollce officer speculated
that the gas pump may have been
hit by a car.
Journal
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~
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reports \OJ
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-------
Audubon Society
of Rhode Island
~ ~ 3.: - ;e"s::'~! ~CC.::
...------.
... .' -=- -
- ..........-. -,... ,...,...
. "''''~. ..-~C\..........
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-=::- : S..:-.:s:e~.';;-
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James M. Brown, Remedial Project Manager
U. S. Environmental Protection Agency
Waste Management Division (HSV -CANS)
JFK Federal Building
Boston, MA 02203-1911
re: Central Landfill:
EPA's prooposed Plan under CERCLA
2/28/94
Dear Mr. Brown:
I presented oral testimony on February 28. 1994, at the public hearing on the above-
referenced case in Johnston, Rhode Island. However, I would like to emphasize Audubon's
position that the chemical sludge be removed from the hotspot in order to prevent future
groundwater contamination after the remedial treatment has been completed.
Because groundwater will be formed as precipitation infiltrates land outside the capped
landfill footprint, groundwater will continue to come into contact with the sludges dumped
during the Silvestri Brothers operation of the area. According to U.S.G.S. surficial geology
maps there are glacial deposits in the area which transmit groundwater easily. These are the
deposits which the Silvestri Brothers sold in their sand and gravel operation. We also
understand that the sludges were dumped into open pits cut into the bedrock and fissures in
the bedrock may also serve in the transport of groundwater. General patterns of groundwater
movement would indicate that the groundwater moving over and around the hotspot would
eventually recharge the surface water in Cedar Swamp Brook which flows into Simmonsville
Reservoir. We believe that the long-term health of the groundwater quality and the surface
water it recharges will be best served by removing the hotspot sludges.
Audubon's interests in this case are to protect public and environmental health while at the
same time providing the services of an already developed and already altered site for
landfilling solid waste.
We ask that the proposed plan consider the long term possibilities for contamination of the
Upper Simmonsville Reservoir. We are concerned that erosion is occurring on the existing
grassed southeastern face of the landfill, contributing not only to sedimentation of Cedar
Swamp Brook and ultimately the Upper Simmonsville Reservoir, but also contributing some
contaminants. Of particular concern would be the heavy metals cadmium, chromium, and
mercury which may leach as organic acids form in the refuse or acidified precipitation
continues at current pH levels if erosion compromises the RI DEM single cap barrier. Our
concern is for the health of fish and of any persons who may consume them. Although the
risk is low on a population scale, we believe that this toxicological pathway should be
addressed. We understand that there are off-site studies continuing which will provide data
on which to base decisions. Nonetheless,. the treatment of the cap and the extraction of
groundwater in the proposed plan on which we comment tonight have an impact on water
Quality and fish health in the Upper SimmonsviIle and Almy Reservoirs.
We ask that the possibility of extracting groundwater from the southern landfill boundary be
held as a con.tingency should off-site studies indicate levels of concern.
SerJing Rhode !s:=-.d Sif'ce 1897
-------
We also ask that consumption fish be considered under recreational fishing. Although I
understand that standards for metals and organics in fish tissue are not set federally, some
states are creating their own standards.
Thank you for this opportunity to comment.
Cordially,
~-_...: ". "
- -~
Eugenia Marks
-------
.;Stlrl2 af ~qlJ~e ~9lanD anb JrlJtri~enre Jlantatinn9
i(:PRESENT A TlVE
JENNIFER .:... CHAMPAGNE MARTELLI
i 9 Warren A..,en-ue
:I:
~
Comminee on Health. Education
and Welfa,e
Johnston, Rhode Island .02919
Join! Commil!ee on Accoun!s
and Claims
ROQm 21, Slo!e ,;ouse
Provide,,,e. Rhode Island 02903
R!ts.: 401.231.8510
~use af ~pre5entatiDe5
March 8, 1994
Mr. James M. Brown
Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division (HSV-CANS)
JFK Federal Building
Boston, MA 02203
Dear Mr. Brown:
Please find enclosed a written review of the questions and comments
publicly presented at the February 28, 1994 public hearing at the EPA
Hearing on the EPA Source Control Plan for the Central Landfill
superfund Site.
espectfully submitted,
'~\ 8. (. -r IjfJJvti~ {j
ennifer A. ~hampagne Martelli
epresentative - District 56
JACM/jak
Enclosure
-------
~t2rl2 af ~~aDe ;BslanD anD JIroniD2nre JIantzltians
REPRESENT A TIVE
JENNIFER A. CHAMPAGNE MARTElU
19 Warren Avenue
Johnston. Rhode '.Iond 02919
Room 21. 510le House
Providence. Rhode Island 02903
:I:
~
Committee on Heolth. Educarion
and Welfare
Joint Commift'ee on Actounts
and Coi."s
Res.: 401.231-8510
~use of ~pre5enhttine5
The Preferred alternative OUl-5 does not include removing the RIDEM
cap on the existing 32 acres and replacing it with the RCRA C cap.
What short and long term affects would occur if the RCRA C cap is not
used on that 32 acres?
What short and long term affects if OUl-8 and OUl-9 are not
completed?
If the RIDEM Cap replaced and/or the
. chemical sludges removed your report
of off-site trucking would occur.
off-site disposal of the hot spot
suggests that a tremendous amount
What compensation do you suggest to
community or the area residents for
trucking.
the (Town of Johnston) host
their exposure to the increase
I will now focus on the treatment of groundwater in the Southern
Landfill boundary the report states that the treatment of groundwater in
Southern Landfill boundary, "may result in a significant lowering in the
water table, which could impact wetlands."
1. What would the impact be on wetlands if you went forward with the
treatment of the groundwater in the southern area?
2.
What effect short/long term if this area is not treated?
What proof can EPA provide that the new Bo-called State Of The Art
Landfill, Phase II, III, will not produce the same or similar chemical
sludge that we are not cleaning up?
All nine Source Control Alternatives were examined and are proposed by
the EPA, I would like to know why is not ~ of the alternatives to
cease all Landfill operations considering it's close proximity to the
Re'servoir?
I request a legal opinion as to what .authority the EPA posses to
recommend the closure of the State Landfill operations in the Town of
Johnston. Further, in EPA's legal opinion, what body is vested with the
power; what body possesses the responsibility, to recommend complete
cestation of Landfill operations in the Town of Johnston.
-------
Weston & Sampson
E N G : .'J E E R S. INC.
:;'.'a C-=~~er"~:c~ :".../e
~9'-::::~C'1 \i1CSS.::::~~s;:.'s 0 1Ccc.;~a5
~ei "::3) ::;2-' .;c: ;:=1. '5C8) c:-:- -: ~:o
.'X
En~'irl":!1IC1!:.:1 C..'iI~ld:.,!!:s :;iJlt.":.' 1599
March 9, 1994
USEPA, Waste Management Division
HSV - CANS
JFK Federal Building
Boston, Massachusetts 02203-1911
Re:
9319.1 Central Landfill Site
Johnston, Rhode Island
Proposed Plan, Comments
Attention:
..
James M. Brpwn, Esq.
. Remedial Project Manager
Dear Mr. Brown:
In accordance with the request a,nd the authorization of the Mayor of Johnston, RI. Mr. Ralph
R. aRusso a review of the proposed plan for remediation of the Central Landfill, Johnston, RI
was completed by this office.
It is our understanding that the Environmental Protection Agency (EP A) has proposed, in the
Source Control Plan for the Central Landfill Superfund Site, to cap 89-Acres of the landfill and
extend the cap over that portion of the 33 acre expansion that "piggy backs" the existing unlined
landfill. If it is the intention of the EPA to delay closure of 89 acres of the landfill until the 33
acres expansion is capped then the flow of leachate through the so called "hot spots" will
continue unabated until such time as the eA-panslon area is closed. It is anticipated that phase
n and m will continue operation until 2023. We recommend that the EP A complete a
construction schedule for the 89 ~re closure and prepare an analysis of groundwater -
contamination due to delayed closure.
.By moving forward with an expansion which "piggy-backs" on the existing unlined landfill the
potential exists for a) differential settlement on top of the existing landfill and b) gross
defonnation of the liner on the side slope of the existing lan~.
Differential Settlement is due to void spaces within the existing landfill. Areas settle and
consolidate at different rates causing pipes laid at minimum slope for leachate collection to settle
and possibly break.' The net effect is a buildup of leachate within the landfill which will
eventually flow through the existing unlined landfill and potentially through "hot spots" identified
o.~I."'''$: .~.:: .J.:-'e~ ;~~...~"'\ H, (::.. ~.~IC-:~:': -::"':n .:. 71"'1. 5 =CO'l;-::: ?a.i}' ~~ $r."'~!'\ ~rc:"'::s W "':""...s.('-a'...:: :'=:~"'::': ~ :::":~e,:', ~:....i::;' ;.,~:... .iOl":n ~ .:::s
.,,-.;:=..,-.i~rtL~: '",'" :~=i "; !-="'l-e~ 1.:::~1'huS 5 =,:)~~:*I.:;I ,,~..,..g.t~ ..... :..:r:sc~ ~C:i:::"'~c" ::--...!"":: ~:..:-.:~ ,". 5<:-:; :..~
....:~~
-------
Weston & Sampson
IE N GIN IE IE R S. INC.
James M. Brown, Esq.
March 9, 1994
Page 2
bv the EP A. Deformation is due to settlement of the existing unlined landfill and the weight of
n~w trash placed on the side slopes. Gross deformation of the liner or clay can lead to rupture
of the liner. If this occurs, leachate may flow through the existing unlined landfill and
potentially through "hot spots" identified by the EPA. It is our request that the EPA provide
documentation in support of their proposed closure design and in particular on the effects of
differential settlement and gross deformation of the lined expansion.
If you have any further questions or require any additional information please do not hesitate to
call. .
Very truly yours,
5;:~~rnEERS
. J. Darn Lynott, P.E.
Project Engineer
JDL:lag
cc:
Mr. Ralph R. aRusso, Mayor of Johnston
Mr. Ralph J. Perrotta, Esq.
f: \wp\cuenl\jolmstoa\c\9319\022S94-1 Jell
-------
GROUND WATER ASSOCIATES, INC.
16 Commercial Drive, p,O, Box 280, Dracut, Massachusetts 01826 (508) 970-5388
March 11, 1994
Mr. James M. Brown, Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division (HSV-CAN5J
JFK Federal Building
Boston, Massachusetts 02203-1911
Re: Proposed Source Control Plan
for Central Landfill Site
Dear Mr. Brown:
Having reviewed EPA's proposed Source Control Plan summarized in the
February, 1994 document, several areas of concern are noted.
First, we understand that closure and capping of the Phase I landfill will be
delayed until the Phase II area is completed. Any delays in the capping/closure
program will undoubtedly leave open faces at the existing landfill. Such open areas
will allow rainfall infiltration and greatly enhance opportunities for leachate generation.
Our report of March, 1993 indicated that both leachate generation and contaminant
migration from the "hot spot" had already caused significant impacts to ground water
quality both on-site and off-site. Also, additional leachate generation would hinqer
efforts to monitor the effectiveness of any collection at the hot spot. Changes in
ground water quality due to leachate generation versus changes caused by the
collection system would be difficult to discern.
The second concern is related to capture and containment of both the hot spot
contamination, and contaminant movement along the southern boundary of the
landfill. Although the EPA summary indicates that no risk reduction benefits can be
gained by capturing contaminated ground water beyond the hot spot area,
concentrations of VOC's and metals significantly exceeding state and federal
standards are found beyond the extent of the Phase I landfill. In Ground Water
Associates' report of March, 1993, data is presented, showing the presence of
dissolved thallium (54-457 ppb) and chlorobenzene (300-474 ppb) at elevated levels
to the south and southeast of the landfill (see GWA, 1993, pages 40-43).
Without capture and containment of these contaminants of concern, an
elevated continued risk to human health and the environment can be
expected. Only options aU1-6, aU1-7, aU1-8, and aU1-9 address this
issue--not au 1-5.
~il1Jlllll@
-------
Mr. Jam,es M. Brown, Remedial Project Manager
March 11, 1994
Page Two
Options 7 through 9 are discounted due to their impacts on wetlands. However,
discharge of treated water on-site is a possible alternative. Thus, the Source Control
Plan should consider the ability to maintain wetlands by on-site recharge. .
In summary, any Source Control Plan which allows continued generation of
leachate while not fully capturing and containing ground water contamination should
be re-evaluated, as it does not ensure an adequate level of protection for human
health and the environment.
Very truly yours,
GROUND WATER ASSOCIATES, INC.
7fMA' ~
Blake A. Martin
District Manager
-------
March 1,- 1994
Mr. James M. Brown, Remedial Project Manager
U.S. Environmental Protection Agency
Waste Management Division (HSV-CAN5)
JFK Federal Building
Boston, Ma 02203-1911
RE:
Central Landfill Site
Johnston, RI
-,-
Dear Mr. Brown,
I am writing to you with a great feeling of frustration.
Is there no possible way you can CAP the existing portion of the landfill prior to
Phase II and Phase III being filled to capacity by the Rhode Island Solid Waste
Agency? It seems to my uneducated mind that continued rain infiltration into Phase I
will only increase the amount of leachate and therefore the amount of liquid to be
pumped from the "Hot Spot" presenting a disposal problem of its own.
After sitting thru countless meetings with Rhode Island OEM and Solid Waste
Management years ago, and being gullible enough to believe the hearing officer,
Kathleen Lanphear, when she rendered her decision that the landfill would close, I
find my faith in Government - all divisions - to be sorely tested.- I believed, as I am
sure many of my fellow residents of the west end of Johnston believed, that EPA in its
infinite wisdom would protect our environment for our Mure generations. Wrong
again.
Another concern J would like addressed is does your agency have any solutio~s to
deal with the increasing problem of seagulls in and around the landfill? Compared to
Hazardous Waste contaminating our lives this would seem a minute concern but it is
- definitely a growing problem as more and more fly over and land in the Reservoir and
surrounding bodies of water. It seems to me that sometDing should be done to
control this problem.
Hopefully your proposed plan is the best available and will be implemented in a
timely manner. Help to restore my belief that right will .prevail over wrong and that
-------
page 2
Government truly does care for the "little people". We do need all the help you can
provide and we need it now.
Thank you for answering my concerns.
Sincerely,
~~h '
Sandra Dennehy 7
(Mrs. Donald Dennehy)
49 Pine Hill Road
------- |