RECORD OF DECISION
LANDFILL & RESOURCE RECOVERY, INC. (L&RR) SUPERFUND SITE
OPERABLE UNIT 02
NORTH SMITFIFIELD, RHODE ISLAND
EPA SITE ID: RID093212439
PREPARED BY:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1 - NEW ENGLAND
A.
APRIL 2020
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PART 1: THE DECLARATION FOR THE RECORD OF DECISION 1
A. SITE NAME AND LOCATION 1
B. STATEMENT OF BASIS AND PURPOSE 1
C. ASSESSMENT OF SITE 1
D. DESCRIPTION OF SELECTED REMEDY 1
E. STATUTORY DETERMINATIONS 3
F. SPECIAL FINDINGS 3
G. DATA CERTIFICATION CHECKLIST 4
H. AUTHORIZING SIGNATURES 4
PART 2: THE DECISION SUMMARY 5
A. SITE NAME, LOCATION, AND DESCRIPTION 5
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES 5
C. COMMUNITY PARTICIPATION 9
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 9
E. SITE CHARACTERISTICS 10
F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES 16
G. SUMMARY OF SITE RISKS 16
H. REMEDIAL ACTION OBJECTIVES 24
I. DEVELOPMENT AND SCREENING OF ALTERNATIVES 2 5
J. DESCRIPTION OF ALTERNATIVES 25
K. COMPARATIVE ANALYSIS OF ALTERNATIVES 29
L. THE SELECTED REMEDY 33
M. STATUTORYDETERMINATIONS 45
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES 47
0. STATE ROLE 48
PART 3: THE RESPONSIVENESS SUMMARY 49
PUBLIC COMMENTS AND EPA RESPONSES 49
TRANSCRIPT OF PUBLIC HEARING 51
APPENDICES 62
Appendix A - Rhode Island Department of Environmental Management Letter of Concurrence 63
Appendix B - T ables 66
Appendix C - Figures 92
Appendix D-ARARs Tables 111
Appendix E - Acronyms and Abbreviations 136
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum 138
Appendix G -Administrative Record Index and Guidance Documents 146
Page M
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PART 1: THE DECLARATION FOR THE RECORD OF DECISION
A. SITE NAME AND LOCATION
Landfill & Resource Recovery, Inc. (L&RR) Superfund Site 0U2
North Smithfield, Providence County, Rhode Island
CERLCIS ID#: RID093212439
B. STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Landfill and Resource Recovery,
Inc. (L&RR) Superfund Site. Operable Unit 02 (OU2), in North Smithfield, Rhode Island (the Site),
which was chosen in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 as amended (CERCLA, also commonly referred to as "Superfund"), 42 U.S.C. §
9601 et seq., and, to the extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) as amended, 40 C.F.R. Part 300. The Region 1 Director of the Superfund and
Emergency Management Division (SEMD) has been delegated the authority to approve this Record of
Decision (ROD).
This decision was based on the Administrative Record for the Site, which has been developed in
accordance with Section 113(k) of CERCLA, 42 U.S.C. § 9613(k). The Administrative Record is
available for review online at www.epa.gov/superfund/lrr, and via computer at the Municipal Annex
Building located at 575 Smithfield Road in North Smithfield, Rhode Island, and at the U.S.
Environmental Protection Agency (EPA) Region 1 Records Center located at 5 Post Office Square,
Boston, Massachusetts. The Administrative Record Index (Appendix G of this ROD) identifies each of
the items comprising the Administrative Record upon which the selection of the remedial action is based.
The State of Rhode Island, as the support agency, concurs with the selected remedy (see Appendix A of
this ROD for a copy of the concurrence letter).
C. ASSESSMENT OF SITE
The remedial action selected in this ROD is necessary to protect the public health or welfare or the
environment from actual or threatened releases of hazardous substances, pollutants, or contaminants into
the environment. The April 2020 Remedial Investigation (RI) Report for the Site summarizes the nature
and extent of the contamination and was used to prepare the June 2020 Feasibility Study (FS) Report that
identified all the remedial alternatives considered for cleanup of the Site.
D. DESCRIPTION OF SELECTED REMEDY
This ROD sets forth the selected remedy for OU2 of the Site, which is a comprehensive cleanup approach
and is based on a combination of remedial alternatives set out in a Proposed Plan issued for public
comment in July 2020. The selected remedy addresses groundwater outside the boundary of the waste
management area (WMA) associated with the closed landfill (OU1). The selected remedy utilizes in-situ
treatment and sequestration and institutional controls to prevent the migration of COCs from OU1 and to
restore groundwater outside of the waste management area to its beneficial use as a source of drinking
water.
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The remedial measures selected in this ROD include the following:
Groundwater
EPA's selected remedy for Groundwater is Alternative 4: Two-Stage Reactive Treatment Zone,
Institutional Controls, and Monitoring which includes the following components:
• Treatability/Pilot Testing: Treatability testing is underway and will be completed to determine the
effectiveness of the innovative technologies selected to treat Site-specific conditions.
• Pre-Design Investigations: Pre-design investigations will be used to refine the horizontal and
vertical extents of the plume and to identify target treatment zones.
• In-situ Chemical Oxidation (ISCO) Treatment Zone: The remedy uses a combination of
potassium persulfate and sodium persulfate injections to treat the contaminant mass.
• ISCO Injections: The remedy includes targeted ISCO injections in areas downgradient of the
ISCO treatment zone.
• Activated Carbon (AC) Injections: The remedy includes an activated carbon barrier extending
approximately 5 to 60 feet below ground surface and 750 feet across.
• Wetland Restoration: Wetlands that are disturbed as part of construction will be restored and
impacts to any floodplain are expected to be temporary.
• Monitoring: Monitoring includes groundwater and surface water monitoring.
• Institutional Controls: Institutional controls (ICs) would be implemented for groundwater use in
all areas necessary to prevent exposure.
• Five-Year Reviews: The Site will be reviewed at a minimum of every five years to assess
protectiveness of the remedy.
If EPA, after consultation with RIDEM, determines that the selected remedy will not meet performance
standards, the contingency remedy will be implemented. EPA's contingency remedy for Groundwater is
Alternative 3: Groundwater Extraction with Ex Situ Treatment, Institutional Controls, and
Monitoring, which includes the following components:
• Pre-Design Investigation: Pre-design investigations would include an additional groundwater
investigation to determine optimal extraction well placement.
• Treatability/Pilot Testing: Treatability and pilot testing would be used to optimize treatment
components and finalize treatment design based on the results from pre-design studies.
• Extraction and Injection System: The groundwater extraction system would consist of a series of
extraction wells that would capture contaminated portions of the aquifer.
• Treatment Plant: Extracted groundwater would be treated by a series of processes including
advanced oxidation (AO) and granular activated carbon (GAC) treatment.
Operation and Maintenance of the Treatment System: Operation and Maintenance (O&M)
would include monitoring to evaluate that all parts of the extraction and treatment system are
operating properly.
• Wetland Restoration: Wetlands that are disturbed as part of construction will be restored, and any
impacts to floodplains are expected to be temporary.
• Monitoring: Monitoring would include groundwater and surface water monitoring.
• Institutional Controls: Institutional controls (ICs) would be implemented for groundwater use in
all areas necessary to prevent exposure.
• Five-Year Reviews: The Site will be reviewed at a minimum of every five years to assess
protectiveness of the remedy.
PART 1: THE DECLARATION FOR THE RECORD OF DECISION
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E. STATUTORY DETERMINATIONS
The selected remedy and contingency remedy are consistent with CERCLA and, to the extent practicable,
the NCP. The selected remedy and contingency remedy are protective of human health and the
environment; comply with federal and State requirements that are applicable or relevant and appropriate
to the remedial action; are cost-effective; and utilize permanent solutions and alternative treatment
technologies to the maximum extent practicable. The selected remedy and contingency remedy satisfy the
statutory preference for treatment as a principal element of the remedy.
Because this remedy will result in Site contaminants remaining in groundwater above levels that would
allow for unlimited use and unrestricted exposure, the remedial actions for OU2 will be incorporated into
the existing Five Year review cycle for the Site, to ensure all Site remedial actions provide adequate
protection of human health and the environment. Five-year reviews for the Site will continue as long as
waste remains at the Site above levels that would allow for unlimited use and unrestricted exposure.
F. SPECIAL FINDINGS
Issuance of this ROD embodies the following specific determinations:
Wetlands Impacts
Pursuant to Section 404 of the Clean Water Act (CWA), 44 C.F.R. Part 9, and Executive Order 11990
(Protection of Wetlands), EPA has determined that because of the existence of wetlands at the Site and
the levels of Site-related contamination that exist in these wetlands and underlying groundwater there is
no practicable alternative to conducting work in these areas. EPA has also determined that the selected
remedy and contingency remedy which impact wetland areas are the least environmentally damaging
practicable alternatives for protecting wetland resources. EPA will minimize potential harm and avoid
adverse impacts to wetlands by using best management practices to minimize harmful impacts on the
wetlands, wildlife or their habitat, and by restoring or replicating, if necessary, these areas consistent with
federal and state wetlands protection laws. Any wetlands affected by remedial work will be restored or
replicated, if necessary, with native vegetation as a wetland area and such restoration will be monitored
until the wetland vegetation becomes re-established. Other mitigation measures will be used to protect
wildlife and aquatic life during remediation and restoration, as necessary. As required under applicable
federal wetlands regulations, EPA solicited public comment regarding the remedies' potential impacts on
wetland resources and received no negative comments (see Part 3 of this ROD).
Floodplain Impacts
Pursuant to Executive Order 11988 (Floodplain Management) and federal regulations at 44 C.F.R. Part 9,
EPA has determined that there is no practicable alternative to activities that affect or result in the
occupancy and modification of the 100-and 500-year floodplain. EPA has also determined that the
selected remedy and contingency remedy will cause temporary impacts to 100-year and 500-year
floodplains but will not result in the occupancy and modification of floodplains. Best management
practices will be used to minimize temporary impacts to floodplains and excavated areas will be returned
to original grade to avoid diminishing flood storage capacity. Restoration and monitoring activities are
included in the selected remedy. As required under applicable federal floodplains regulations, EPA
solicited public comment regarding the remedies' potential impacts on floodplain resources and received
no negative comments (see Part 3 of this ROD).
PART 1: THE DECLARATION FOR THE RECORD OF DECISION
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G. DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for this Site.
Chemicals of concern (COCs), also known as contaminants of concern, and their respective
concentrations.
fables G1-G2
0
Baseline risk represented by the COCs.
fables G5-G10
0
Cleanup levels established for COCs and the basis for these levels.
fable L-2
0
Current and reasonably anticipated future groundwater use assumptions used in baseline human
nealth risk assessment.
Section F
0
Current and potential future groundwater uses as a result of the selected remedy.
Section L
0
Estimated capital, annual operation and maintenance (O&M), and total present worth costs,
discount rate, and the number of years over which the remedy cost estimates are projected.
fables L2-L3
0
Decisive factors that led to selecting the remedy.
Section K
H. AUTHORIZING SIGNATURES
This ROD documents the selected remedy for groundwater associated with the Landfill and Resource
Recovery, Inc. (L&RR) Superfund Site - Operable Unit 02. This remedy was selected by EPA with
concurrence of the Rhode Island Department of Environmental Management. A copy of the State's
concurrence letter is attached to this ROD (Appendix A).
RRVA M HI CAM Di9'tal|y Signed by BRYAN OLSON
Dn I MINI ULjUIM Date:2021.04.15 16:40:50-04'00' „
By: Date:
Bryan Olson. Director
Superfund and Emergency Management Division
PART 1: THE DECLARATION FOR THE RECORD OF DECISION
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PART 2: THE DECISION SUMMARY
A. SITE NAME, LOCATION, AND DESCRIPTION
The L&RR Superfund Site (CERCLIS ID#: RID093212439) or "Site" is located in North Smithfield,
Rhode Island. EPA is the lead agency and RIDEM is the support agency.
The L&RR Site includes a 28-acre closed/capped landfill that is part of an undeveloped portion of North
Smithfield, Rhode Island. The landfill is bounded to the west by a gravel road referred to as Old Oxford
Turnpike, which is part of a network of gravel roads maintained for truck use by the Holliston Sand
Corporation located farther to the north. An extensive wetland complex associated with Trout Brook is
located east of the landfill. Trout Brook flows north toward Trout Brook Pond located farther to the north
and east of the landfill. The north, south, and eastern edges of the landfill are bounded by high voltage
electric transmission lines. A photovoltaic solar array was recently constructed on a large undeveloped
land parcel south of the landfill. Another solar developer has obtained construction permits for a solar
array to be located on the parcels to the northwest of the landfill. A series of single-family residential
homes and two-unit single-floor condominiums are located approximately one quarter mile to the east
along Pound Hill Road. These residences include private drinking water wells for household consumption
and use. A Site Locus Map is provided as Figure 1-1 in Appendix C and a Site Plan is provided as
Figure 1-2 in Appendix C.
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
History of Site Use
The L&RR Superfund Site was initially used as a sand and gravel pit given the extensive glacially derived
materials within this portion of Rhode Island. The volume of sand and gravel mined remains unknown. It
is estimated that most of the sand and gravel was excavated to the elevation at which groundwater was
encountered. According to the NUS Corporation's Remedial Action Master Plan, acceptance of waste for
disposal began in 1927 and continued until 1969 when the facility became a solid waste disposal area. In
1974, the waste management area was sold to L&RR, Inc. and operations expanded to include acceptance
of commercial, domestic, and industrial waste, in addition to solid waste.
L&RR, Inc. obtained a solid waste management facility license issued by RIDEM in December 1976.
Acceptance of hazardous waste began in November 1977 and ceased by September 1979. Hazardous
wastes were thought to have been disposed of in the north-central area. Between December 1980 and
December 1981, operations at the Site were in a state of flux following expiration of the solid waste
management facility license on December 1, 1980. This led to a series of court appeals that eventually
ruled in the landfill owner's favor and allowed operations to resume. In January 1985, a Rhode Island
State Superior Court issued a determination that landfill operations were to permanently cease. The
landfill ceased accepting waste materials in 1985.
History of Investigations, Remedial Actions and Enforcement Activities
Operable Unit 1
Efforts to reduce landfill leachate generation began in 1979 when, under the direction of RIDEM, an area
referred to as a "hazardous waste area" was covered with a 20-mil PVC liner by L&RR, Inc. to reduce the
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potential for hazardous waste leachate generation. In 1986, under the direction of RIDEM, additional
areas of the landfill were covered with 20-mil PVC geomembrane and soil and supplemented with
shaping and grading to enhance landfill drainage.
Numerous subsurface investigations were undertaken for OU1 beginning in 1977 when RIDEM required
the past owner of the landfill to submit copies of waste manifests.
Between 1980 and 1981, EPA conducted a preliminary site assessment of the L&RR Site which resulted
in the Site being added to the National Priorities List (NPL) in 1982 (47 Fed. Reg. 58476, December 30,
1982). A Remedial Action Master Plan (RAMP) was completed for the Site in 1983. The RAMP
evaluated existing data sources, identified data needs and recommended remedial action activities. In
1985, L&RR, Inc., began to close the landfill under a Court Order and Consent Order and Agreement
with RIDEM. EPA was not a party to that Court Order and began a federally funded RI/FS in May 1986.
The RI included extensive subsurface investigations to characterize the nature and extent of past landfill-
related activities along with a landfill closure assessment. The RI and FS were completed in 1988. Data
obtained during the RI were used to support screening and selection of a remedial alternative for OU1 as
part of the ROD.
EPA issued the OU1 ROD on September 29, 1988 which was subsequently modified by two Explanation
of Significant Differences (ESDs) on March 8, 1991 and September 16, 1996. The selected remedy
included the following components:
• Landfill closure upgrades including installation of a perimeter fence, developing a post-closure
monitoring plan, surface water management improvements, slope stability improvements, covering
the uncovered northeast portion of the landfill, and soil cover/vegetation establishment;
• Installation of a landfill gas collection (using 18 gas extraction wells) and thermal destruction
system;
• Remediation of nearby wetlands (modified in 1991 via ESD); and
• Periodic environmental monitoring for a period of at least 30 years.
Implementation of institutional controls for land and water use at the landfill and adjacent areas was
required by a 1997 Settlement Agreement and Consent Decree.
On June 5, 1986, EPA notified L&RR, Inc., of its potential liability with respect to the Site. On July 29,
1988, EPA sent a notice letter to L&RR, Inc. which formally demanded reimbursement for past costs,
requested information regarding activities at the Site, and requested voluntary participation in undertaking
forthcoming remedial activities. On July 29, 1988, EPA also notified additional parties who either
generated wastes that were shipped to the facility, arranged for the disposal of wastes at the facility, or
transported wastes to the facility, of their potential liability with respect to the Site.
On January 30, 1992, EPA entered into a de minimis settlement pursuant to Section 122(g) of CERCLA,
42 U.S.C. § 9622(g), with 46 potentially responsible parties each of which, according to EPA, disposed of
less than 1% of the hazardous substances at the Site.
In February and March 1990, EPA issued special notice letters to potentially responsible parties to engage
in settlement negotiations for the performance of the remedial actions and recovery of response costs at
the Site; the negotiations did not result in a settlement between any of the parties. EPA issued a Unilateral
Administrative Order ("UAO"), pursuant to Sections 104(e) and 106(a) of CERCLA, on June 29, 1990,
for performance of response actions at the Site. Certain of the respondents subject to the UAO performed
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remedial activities pursuant to the UAO, including construction of the remedy set forth in the final 100%
Design for the remedy at the Site approved by EPA pursuant to the UAO.
Following a remedial design period from March 1993 to September 1993, implementation of Remedial
Action activities began in May 1994. These activities included placing a new PVC cover system over
previously uncovered areas, extending the eastern slope, and constructing a gas collection system. The 18
gas extraction wells were connected using a series of pipes (headers) for conveyance of landfill gas to a
40-foot high enclosed flare unit for treatment via thermal destruction. The gas collection system began
operation in February 1995. The Post-Closure/O&M Plan was submitted in 1996.
The gas collection and treatment system has successfully operated to reduce landfill gas emissions and
control methane levels since 1996. The flare currently operates on a part-time basis due to low methane
concentrations typical of aging landfills. The OU1 remedy remains subject to the ARARs set forth in the
OU1 ROD, including Rhode Island's solid waste regulations.
The ESD issued on September 16, 1996 clarified that the groundwater standards referenced in the ROD
(Maximum Contaminant Levels, or MCLs) are to be used to judge the performance of the landfill cap
and closure and are not, by themselves, cleanup or performance standards for groundwater. At the time of
the initial ROD, air quality emissions were the primary risk driver for which remedial actions were
implemented. EPA stated in the ROD (and restated in the 1996 ESD) its reservation of the right to address
groundwater in the future if EPA determined that groundwater poses a threat to human health or the
environment.
In 1997, the United States and certain settling defendants entered into a Settlement Agreement and
Consent Decree that resolved certain claims of the United States and required the settling defendants to
perform the work described in the Consent Decree, including: the remaining components of the remedial
action not completed pursuant to the UAO; surface water monitoring and institutional controls for land
and water use; and all activities required to maintain the effectiveness of the remedial action as required
under the Operation and Maintenance Plan and/or Post Closure Operation and Maintenance Plan
approved or developed by EPA pursuant to the UAO or modified and approved pursuant to the Consent
Decree.
Operable Unit 2
Following closure of the landfill, annual environmental monitoring was performed, which included
collection of groundwater and surface water samples to evaluate water quality as part of Post-Closure Site
Monitoring (PCSM) requirements. Review of groundwater data indicated detections of select VOCs and
metals above regulatory standards at select locations along the perimeter of the landfill. These standard
comparisons took into consideration the 1996 ESD which clarified that MCLs were specific to evaluating
changes in water quality as part of post-closure monitoring activities.
To support institutional control efforts, field investigation activities involving Lot 23 (Figure 1-2 in
Appendix C) began in July and August 2013. The initial approach involved advancement of three
groundwater profile locations (WL-1, WL-2, WL-3) to obtain high-resolution vertical profiling data.
Select VOCs and arsenic had been historically detected above MCLs at the CW-5 and MW-102 well nests
near the landfill boundaries upgradient of the respective lots. The results from the 2013 groundwater
profiling confirmed the presence of a limited subset of VOCs (including 1,4-dioxane) and metals, in the
overburden aquifer at concentrations that in some cases were above MCLs.
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As a result of these detections, a second phase of investigation was initiated in March and April 2014 to
further evaluate groundwater and surface water hydraulics and bedrock aquifer conditions. Groundwater-
surface water interactions were evaluated using a network of piezometers installed in Trout Brook Pond.
Bedrock assessment occurred using a borehole (BH14-1) east of the landfill on Lot 23 followed by
geophysical logging to identify potential water-bearing zones. Groundwater samples were collected from
the borehole on two separate occasions using packer isolation techniques. Potentiometric data obtained
from the network of piezometers on May 15, 2014 were used to develop vertical flow gradients within the
wetland complex surrounding Trout Brook. At four of the five piezometers (PZ-1, PZ-3, PZ-4, and PZ-5),
the surface water elevation was higher than the groundwater elevation and supported downward
groundwater flow and discharge of surface water to groundwater for the time of year. At only one
piezometer (PZ-2), the surface water elevation was lower than the groundwater elevation. This
piezometer was installed furthest in the wetland complex and the calculated vertical gradient indicates
upward groundwater flow consistent with historic observations. Borehole BH14-1 was drilled and logged
using standard geophysical methods in March 2014. Bedrock was encountered at 36.5 feet below grade;
permanent casing was installed to facilitate air rotary drilling, and the boring was advanced 96.5 feet into
rock (corresponding with an elevation of 142.9 feet above mean sea level [AMSL]). The geophysical
results identified two possible transmissive fracture zones in the borehole, located from approximately 44
to 49 feet below the top of casing and at approximately 73 feet and 86 feet below the top of casing. Heat-
pulse flow meter (HPFM) measurements recorded under ambient conditions and while stressing the
borehole confirmed that the primary transmissive zone was between 44 and 49 feet, where water enters
the borehole through a nearly vertical fracture located just below the casing. A small amount of water also
enters the borehole through the fracture zone located at 73 feet. A packer system was subsequently used
to isolate these zones and collect groundwater samples during two mobilizations in March and April
2014. Two sampling events were completed primarily due to diverse laboratory results between EPA's
Chelmsford, Massachusetts lab and the Respondent's lab.
Multiple VOCs (including 1,4-dioxane) and metals were detected in samples from these events with only
concentrations of tetrachloroethene (PCE) and trichloroethene (TCE) detected above MCLs.
Following a review of analytical data for groundwater samples from BH14-1, residential drinking water
samples were initially collected from 10 residences to the east and south of the Site along Pound Hill
Road in April 2014. These samples were used to evaluate current drinking water conditions based on the
bedrock groundwater results obtained from BH14-1. Concentrations of VOCs including 1,4-dioxane were
not detected above the laboratory's minimum reporting limit, with the following exceptions: naphthalene
was detected at one residence and chloroform was detected at another address. Naphthalene detection was
a one-time occurrence, while chloroform detection is attributed to use of chlorine bleach by the
homeowner to disinfect the well. These residences continue to be sampled on a semi-annual basis and
Site-related constituents remain undetected. Recent analysis of per- and polyfluorinated alkyl substances
(PFAS) from residential samples identified very low detection of a subset of PFAS, well below EPA
guidelines and RIDEM's standards. Monitoring activities will continue to include PFAS, along with
VOCs and 1,4-dioxane, on a semi-annual basis.
EPA's Fourth Five-Year Review (2014) determined that the OU1 remedy currently remains protective of
human health and the environment. However, to support long-term protectiveness requirements, EPA
concluded that (i) institutional controls are still required, and (ii) on-going assessments of groundwater
quality need to continue to determine the nature and extent of subsurface impacts and evaluate the need
for response actions.
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EPA issued Special Notice Letters to potentially responsible parties on April 8, 2015. These Special
Notice Letters were followed by a response and Good Faith Offer correspondence on June 8, 2015, which
outlined the Respondent's willingness to conduct RI/FS activities. EPA and the Respondents entered into
an Administrative Order on Consent for the RI/FS for OU2 on August 17, 2015.
The Settling Defendants elected to perform an electrical resistivity survey in November 2015. The
electrical survey involved an area significantly beyond the extent of the landfill footprint. Results and
interpretations from the resistivity survey were used to refine bedrock borehole locations based on
indicators of potential water-bearing bedrock zones.
Implementation of RI/FS activities began in June 2016. The RI report was completed in April 2020 and
the FS report was completed in June 2020.
A summary of the work conducted during previous investigations, including the dates and
contractor/agency that performed the work can be found in Table 1-1 of the April 2020 RI Report.
C. COMMUNITY PARTICIPATION
The RI/FS Reports and Proposed Plan for the L&RR Superfund Site OU2 were made available to the
public in July 2020. They can be found in the Administrative Record file and the information repository
accessible via computer at the Municipal Annex Building 575 Smithfield Road North Smithfield, RI
02896 or online at www.epa.gov/superfund/lrr. The notice of the availability of these documents was
published in The Valley Breeze on July 30, 2020. EPA also provided notice to the Town of North
Smithfield and nearby residents via a postcard mailing. A public comment period was held from July 29,
2020 to August 28, 2020 during which EPA accepted public comments by e-mail, fax, mail, and
telephone. A virtual public meeting was held on August 12, 2020 to present the Proposed Plan to the
community. At this meeting, representatives from EPA presented information and answered questions
about OU2 and the remedial alternatives. This meeting was followed by a Virtual Formal Public Hearing
at which community members could provide oral comments. EPA's response to the comments received
during this public comment period is included in the Responsiveness Summary, which is part of this
Record of Decision.
D. SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
EPA selected the remedy for Operable Unit 1 (OU1) in a ROD signed in September 1988, which
addressed the closure of the landfill at the Site. Operable Unit 2 (OU2), the subject of this ROD,
addresses the groundwater outside the boundary of the waste management area that has been impacted by
the closed landfill. EPA has determined that there are future potential threats to human health at the Site
due to uncontrolled migration of contaminated groundwater from the landfill. The presence of VOCs
(including 1,4-dioxane), metals, PFAS and other contaminants have been identified throughout
groundwater at the Site at levels that present an unacceptable risk to human health and the environment.
The OU2 remedy will address the unacceptable risks and meet the cleanup objectives for OU2.
Groundwater outside the boundary of the waste management area will be restored to beneficial reuse and
will no longer act as a source for surface water contamination in Trout Brook. Trout Brook Pond, or the
associated tributaries. OU1 and OU2 together comprise the L&RR Superfund Site.
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E. SITE CHARACTERISTICS
The most recent significant Site findings can be found in the April 2020 RI Report and the June 2020 FS
Report and are summarized below.
Physical Setting
The Site is bound to the west by a gravel road referred to as Old Oxford Turnpike. The area surrounding
the Site is predominantly conifer forest to the north, west, and south. A large wetland complex to the east
of the landfill includes a mixture of open emergent swamp and forested swamp. Trout Brook flows within
this wetland complex before connecting with Trout Brook Pond farther to the north (see Figure 1-3 in
Appendix C). More information about the land uses at and around the Site can be found in Section F.
Site Geology
Surficial overburden deposits near the Site consist of glacial stratified drift that are part of a regional
kame delta further categorized into two sub-units consisting of an upper kame delta sequence, which
includes well-sorted fine sand and silt, and a lower unit including variable sequences of coarse sand and
gravel associated with ice contact deposits and high-energy meltwater resulting from deglaciation.
Bedrock beneath the Site consists of a quartz-biotite gneiss. Logging of select cores indicated minor
amounts of ferromagnesian minerals and foliation. Bedrock was encountered at depths ranging from
approximately 30 to 130 feet below ground surface (bgs), with corresponding elevations ranging from
approximately 250 feet above mean sea level (AMSL) at the western end of the landfill, to approximately
180 feet AMSL at the eastern toe of the landfill, to approximately 220 feet AMSL near Pound Hill Road,
east of the landfill.
The bedrock surface generally slopes north/northeast towards the edge of the landfill and aligns with a
buried bedrock valley that was infilled with post-glacial sand and gravel deposits. This bedrock valley
forms a basin-like depression in the vicinity of the CW-5 clusters (northwest), BH16-1 (northeast), CW-1
(southwest), and BH16-3 (southeast). The morphology of the bedrock surface is generally aligned with
the channel reach of Trout Brook before it enters Trout Brook Pond.
A series of geologic cross-sections were developed based on overburden interpretations and bedrock
drilling during the OU2 RI (see Figure 1-4 in Appendix C for cross-section locations). These cross-
sections are ordered as D-D' (Figure 1-5), E-E' (Figure 1-6), and F-F' (Figure 1-7). These cross-sections
highlight the contrast in bedrock depth from deeper elevations near the eastern edge of the landfill to
shallower depths east of Trout Brook and near Pound Hill Road. These cross-sections also include the
elevation of potential and likely water-bearing fractures identified during borehole logging. The degree,
distribution, and aperture of fractures varies at each borehole. Only one shallow fracture beneath the
overburden interface was identified at BH14-1, adjacent to Trout Brook with the remaining boreholes
supporting competent upper bedrock surface.
Hydrogeology
Groundwater flow is generally from the landfill east toward Trout Brook and the associated wetland
complex. Flow in the shallow overburden deposits is strongly influenced by surface water and
groundwater exchange effects. This hydraulic dynamic is evident between the Brook and the wetland,
where overburden shallow groundwater flow likely deviates further within floodplain areas when seasonal
precipitation levels are elevated. During low flow periods, horizontal flow is presumably less as the
wetlands adapt to groundwater losses. Flow during seasonally elevated precipitation levels leads to
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gaining conditions. These alternating hydraulic periods likely contribute to a scenario where Trout Brook
may function as a hydraulic boundary or divide, consistent with U.S. Geological Survey (USGS)
observations and model results. Figure 1-8 in Appendix C presents interpretive overburden shallow and
intermediate groundwater contours from gauging in March 2017.
Groundwater flow in the deep overburden and bedrock zones also maintains a consistent west to east flow
pattern, but there are likely zones along the edge of the wetlands where depositional heterogeneities result
in localized anisotropic flow. This is presumably based on the distribution of the deeper ice contact
deposits and finer-grained seams. Flow in bedrock also maintains the west to east configuration, before
reaching Trout Brook, where flow shifts northward consistent with regional flow. Figure 1-9 in
Appendix C presents interpretative contours from deep overburden and bedrock gauging in March 2017.
Hydraulic conductivity estimates obtained during the OU1 RI using a variety of test methods indicated
that the ice contact sand and gravel (2.2 x 10~2 centimeters per second [cm/sec]) is more than two orders
of magnitude as permeable as the kame delta (4.4 x 10~4 cm/sec). Similarly, vertical gradient estimates
using data from May and October 1987 for the network of OU1 RI wells confirmed a downward direction
of flow from the finer-grained upper kame unit to the lower ice contact deposits. More recent
groundwater elevation measurements obtained during the OU2 RI were consistent with these estimates,
with a few exceptions notably occurring further to the east and beyond the network of wells installed as
part of OU 1.
Surface Water and Wetlands
Extensive freshwater wetlands associated with Trout Brook and its tributaries are located east of the
landfill. The wetland complex likely plays a significant role in mediating surface water flow (gaining
conditions) and groundwater recharge (losing conditions) based on the time of year. Trout Brook flows
northward, widening into Trout Brook Pond, and ultimately joins the Slatersville Reservoir, part of the
Branch River and located less than a mile to the north of the Site.
Surface water from the landfill surface is conveyed into detention basins by a series of drainage swales
and ditches. These channels flow east toward the wetland complex east of the landfill via two
predominant tributary features that are aligned with the southeastern boundary of the landfill and a broad
southwestern oriented channel that originates near the northeastern portion of the landfill. These
tributaries ultimately connect with Trout Brook, which flows north and drains into Trout Brook Pond.
Slatersville Reservoir, Trout Brook, Trout Brook Pond, and the associated tributaries are designated as
Class B water bodies by RIDEM, which indicates that they are suitable for fishing, swimming, and other
recreational activities.
Conceptual Site Model
A conceptual site model (CSM) is a three-dimensional picture of site conditions that illustrates
contaminant sources, release mechanisms, exposure pathways, migration routes, and potential human and
ecological receptors. The CSM documents current and potential future site conditions and is supported by
maps, cross sections, and site diagrams that illustrate what is known about human and environmental
exposure through contaminant release and migration to potential receptors.
The text in this section is also supported by a flowchart based CSM (see Figure 1-14 in Appendix C).
Known and Suspected Sources of Contamination
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The source of OU2 groundwater contamination is the hazardous waste disposed of within the landfill on
OU1. These wastes include, but are not limited to:
waste oil containing metals, asbestos, calcium fluoride sludge with lead, scrap paints containing volatile
organic compounds ("VOCs") and alcohols, chemical compounds containing VOCs, batteries containing
mercury, metal hydroxide sludge containing copper and nickel, lime sludge containing iron and copper, paint
sludge containing VOCs, waste sludge containing hydroxide, calcium and zinc sludge, HPR 106 containing
butyl acetate and xylene, filtrate waste containing methanol and organic byproducts, tank rinse containing
sodium hydroxide and organic byproducts, rinse water containing ammonia and ethylene diamine tetracetic
acid (EDTA), sodium oxylate sludge containing metals, organic latex and organic latex wash containing
copper, nickel, chromium, silver and VOCs, waste oil and solvents containing VOCs, water soluble dye and
fibers containing acids and VOCs, solvents and alcohol containing acetone, toluene, methyl ethyl ketone,
isopropanol, isobutyl acetate and cyclohexanone, waste coating material containing methyl ethyl ketone,
isobutyl acetate, cyclohexanone and ethylene vinyl acetate, waste oil containing arsenic, cadmium,
chromium, mercury, lead, selenium and silver, organic latex waste containing styrene and ammonia, waste
solvents containing 1,1,1 -trichloroethane, grinding swarf containing selenium, mercury and arsenic, fine wire
tank waste water containing metals, and adhesives and solvents containing methylene chloride, ketones and
esters.
Hazardous substances, including liquid wastes, were either poured directly into the landfill at the Site or
deposited in drums into the landfill.
The primary source of surface water and sediment contamination is groundwater discharge. Other
sources, such as stormwater runoff, may also contribute to contamination in the water bodies.
There is no Principal Threat Waste identified at OU2.
Nature & Extent of Contamination
Investigation data have been divided into a series of sub-areas generally oriented from the landfill to
hydraulically downgradient zones. Refer to Figure 1-4 in Appendix C for the areal extent of each sub-
area and corresponding sample locations.
Landfill Area - Includes the landfill perimeter and upgradient locations.
Downgradient of Landfill -Located beyond the landfill perimeter and within the transitional zone
upgradient of the wetland complex.
Wetland Area - The centrally-located wetland complex east of the landfill which also confines the
floodplain and channel features of Trout Brook.
Near Receptor - The area containing nearby residences along Pound Hill Road, as well as upgradient
wetland locations east of Pound Hill Road.
The following subsections summarize the nature and extent of contamination at OU2.
Groundwater
Groundwater is the primary impacted media at the Site. Figure 1-10 in Appendix C provides the extent
of preliminary remediation goal (PRG) exceedances in groundwater.
Of the constituents, 1,4-dioxane was detected the most frequently. These concentrations extend from the
Landfill area to the Downgradient of Landfill area consistent with groundwater flow patterns toward the
wetlands and Trout Brook. Concentrations of 1,4-dioxane are approximately one to two orders of
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magnitude greater in overburden than in shallow bedrock. Detections of 1,4-dioxane in bedrock were
limited to shallow bedrock depths and results generally indicate decreasing concentrations with depth.
Levels of 1,4-dioxane decrease significantly further to the east across the Wetland sub-area with low level
detections in overburden and bedrock adjacent to Trout Brook. This trend continues eastward with no
detections of 1,4-dioxane in bedrock groundwater in Near-Receptor Area nor in the Residential Wells,
along with non-detect levels at the northern borehole location (BH18-1).
The distribution of CVOCs in groundwater was less extensive than that of 1,4-dioxane. Higher detections
were associated with intermediate breakdown products from PCE and TCE degradation, including cis-
1,2-dichloroethene (cis-l,2-DCE) and vinyl chloride. PCE and TCE were detected less frequently and at
significantly lower levels which confirms the prevalence and sustainability of naturally occurring
breakdown processes. Vinyl chloride was the only CVOC detected above regulatory standards. The
distribution of CVOCs in groundwater was also less extensive compared with the network of monitoring
locations where 1,4-dioxane was detected.
Various metals were also detected in groundwater. Arsenic was one of the more frequently detected
metals and often at concentrations above standards/guidelines at monitoring locations in proximity to the
landfill perimeter.
A limited subset of PFAS, primarily perfluorooctanoic acid (PFOA), were detected in groundwater
samples collected in 2018. Elevated concentrations of PFOA were identified in samples collected at wells
along the eastern edge of the landfill and slightly downgradient of the landfill. The distribution of PFOA
in groundwater in these areas was generally consistent with 1,4-dioxane with respect to horizontal nature
and extent as well as vertically, where overburden concentrations were nearly two times greater than
bedrock locations. PFOA was the primary compound detected above Site-specific standards used for
comparison. Low levels of perfluorooctane sulfonate (PFOS) were also detected and contributed to
exceedances of standards based on the summation of PFOA and PFOS.
Surface Water
Surface water detections within each of the sub-areas were used to assess nature and extent of
contamination. Contaminants detected included VOCs (both CVOCs and non-chlorinated VOCs), 1,4-
dioxane, metals, and pesticides. In general, more frequently detected VOCs included acetone,
chlorobenzene, and dichlorobenzene isomers along with 1,4-dioxane. Frequently detected metals included
arsenic, cadmium, lead, and zinc. This subset of metals also included more frequent detections above
water quality criteria. Higher concentrations of VOCs, semi-volatile organic compounds (SVOCs), and
metals were associated with the area of groundwater discharge near the transition between the
Downgradient of the Landfill and Wetland sub-areas. Figure 1-12 in Appendix C provides a summary of
the distribution of impacts to surface water.
Pore Water
Co-located pore water samples were collected concurrently with surface water during the wetland and
ecological sample collection programs in 2016 and 2017. Based on groundwater-surface water hydraulics
in the transitional area aligned with the Downgradient of the Landfill and Wetland sub-areas, there are
notable consistencies with the distribution of compounds detected in pore water and both groundwater
and surface water detections. More frequently detected VOCs, along with 1,4-dioxane, included benzene,
chlorobenzene, and 1,4-dichlorobenzene. Consistent with surface water results, arsenic was the most
frequently detected metal.
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Sediment
Sediment samples were collected from two depth profiles, 0-6 inches and 6-12 inches to support nature
and extent objectives and evaluate ecological risk. VOCs detected in sediment generally included 1,4-
dichlorobenzene, 1,4-dioxane, acetone, benzene, isopropylbenzene, methyl ethyl ketone (MEK), and
toluene. Acetone and MEK were the most frequently detected VOCs. Lesser concentrations of SVOCs,
metals, and pesticides were also detected and, in some cases, exceeded ecological benchmarks. Multiple
metals exceeded ecological benchmarks, with arsenic and selenium being the more frequently detected
constituents above benchmarks. While arsenic was more widely distributed in sediment, selenium
exceedances occurred more frequently in the Downgradient of the Landfill and Wetland sub-areas, with
fewer exceedances at Landfill sub-area locations. Figures l-13a and l-13b in Appendix C provide a
summary of the distribution of impacts to sediment.
Contaminant Fate and Transport
Groundwater
Groundwater is the primary impacted media at the Site, as a result of various transport mechanisms,
including advection, dispersion, diffusion, and desorption. Transportation of dissolved-phase
contaminants downgradient of the landfill has occurred due to prevailing groundwater flow gradients and
hydrogeologic properties of aquifer materials.
Prior waste disposal practices contributed to leaching of contaminants from vadose zone soils, adsorption
of contaminants to soils, and seepage into bedrock from limited shallow bedrock fractures, along with
primary groundwater flow conditions from west to east and prevailing downward vertical flow,
particularly on the western side of Trout Brook and the wetland complex where overburden deposits were
proportionally greater. Conditions in this key transitional area were associated with the following
observations and interpretations:
• Shallow overburden groundwater flow gradients become upward, as the hydraulics in this area
alternate towards predominantly gaining as groundwater discharge occurs to sustain wetland
conditions and functionality. This change is supported by higher concentrations of dissolved-
phase contaminants in pore water and surface water.
• Intermediate and deeper overburden impacts generally decrease with depth, while residual levels
of COCs from these deeper units remain in deeper groundwater with the potential to flow beneath
the Wetland sub-area.
• The slope of the bedrock surface decreases laterally across the interpreted buried channel adjacent
to the landfill. As this transition occurs, the upper surface appears to be less fractured and there
are fewer detections of COCs in bedrock, particularly at the deeper depths associated with
residential drinking water wells.
The evaluation of results from prior to and as part of the RI to assess the nature and extent of
contamination, showed that Site-related COCs in bedrock groundwater and residential drinking water
wells beyond Pound Hill Road are extremely limited. In addition to having few instances of COC
detections, groundwater flow in bedrock suggests an overall lack of connectivity from upper zones to
lower zones, especially in proximity to the adjacent residences. This may be due to the topographic
profile of the upper bedrock surface which is limited to depths approximately 35 feet bgs in the vicinity of
the residences along Pound Hill Road, compared with more than 70 feet bgs closer to the landfill. From
the wetlands towards the Pound Hill Road residences, overburden thickness decreases significantly and
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few, if any, detections of COCs persist in overburden in the vicinity of the residences. The lack of
detections in these areas remains consistent with regional groundwater flow in this area which is
predominantly northward and conforms with Trout Brook flow.
Routes of Exposure and Potential Receptors
Exposure occurs when humans or other living organisms eat, drink, breathe or have direct skin contact
with a hazardous substance or waste material. There must be a current or potential exposure to a
hazardous substance for there to be a risk to human health. EPA develops various exposure scenarios to
determine potential risks, appropriate cleanup levels for contaminants, and potential cleanup approaches.
Exposure scenarios for OU2 were developed considering the nature and extent of contamination, the
location of the site, current and future potential use of the Site, and potential receptors and exposure
pathways.
Receptors that may come in contact with impacted media include the following:
(i) current/future recreational users who may come in contact with Site contaminants in
sediment, surface water, or fish (if present) in the brook, tributaries, and pond;
(ii) nearby current residents who may be exposed to Site contaminants through potable use
of groundwater wells and indoor air (via vapor intrusion);
(iii) future residents who may be exposed to Site contaminants through potable use of
groundwater wells and indoor air (via vapor intrusion);
(iv) ecological receptors within the Trout Brook area and the adjacent streams/tributaries.
The following table is a summary of human health exposure pathways evaluated for OU2:
Receptor
Population
Scenario
Timeframe
Exposure Medium
Exposure Point
Exposure Route
Resident
Current
Groundwater
Overburden Groundwater
Ingestion
Dermal Contact
Inhalation
Vapor Intrusion (Inhalation)
Bedrock Groundwater
Ingestion
Dermal Contact
Inhalation
Resident
Future
Groundwater
Overburden Groundwater
Ingestion
Dermal Contact
Inhalation
Vapor Intrusion (Inhalation)
Bedrock Groundwater
Ingestion
Dermal Contact
Inhalation
Recreator
Current/
Future
Surface Water
Trout Brook Pond
Trout Brook
Associated Tributaries
Incidental Ingestion
Dermal Contact
Fish Ingestion
Recreator
Current/
Future
Sediment
Trout Brook Pond
Trout Brook
Associated Tributaries
Incidental Ingestion
Dermal Contact
Results of the Screening Level Ecological Risk Assessment (SLERA) and Refinement and of the Baseline
Human Health Risk Assessment (BHHRA) can be found in Section G of this ROD.
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F. CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES
Land Uses
Current land use within OU2 consists of industrial/commercial, recreational, and residential. The
following land features and uses are present in the vicinity of OU2:
• Old Oxford Road - Primarily commercial, with an equestrian center located north of the site;
• Old Oxford Turnpike - Part of a network of gravel roads maintained for truck use by the Holliston
Sand Corporation located further to the north - Industrial use;
• Solar developments located to the south and currently being developed to the northeast -
Industrial use;
• Pound Hill Road - Mixed low-density residential neighborhood and commercial use; and
• The north, south, and eastern edges of the landfill are bounded by high voltage electric
transmission lines - Commercial use.
Ground and Surface Water Uses
Groundwater in the vicinity of the Site is part of the Branch River watershed, which includes the
Slatersville Aquifer, which has been designated as a drinking water source by the State of Rhode Island.
In 1963, the Town of North Smithfield constructed a public water supply well to the north of the Site,
referred to as the Tifft Road Well (see Figure 1-3 in Appendix C), which ceased operating in 2006
following an agreement to purchase water from neighboring Woonsocket.
Residences around the Site, including Pound Hill Road, Black Plain Road, and other nearby roads, use
private wells for water supply. As noted in Section E, Trout Brook Trout Brook Pond, and the associated
tributaries are designated as Class B water bodies by RIDEM, which indicates that they are suitable for
fishing, swimming, and other recreational activities. While Trout Brook and its tributaries are generally
not large enough for these activities, Trout Brook Pond is known to be used for these activities.
G. SUMMARY OF SITE RISKS
Basis for Action
The remedial action selected in this Record of Decision is necessary to protect the public health or
welfare or the environment from actual or threatened releases of hazardous substances from this Site
which may present an imminent and substantial endangerment to public health or welfare.
Baseline Risk Assessment
The baseline risk assessment estimates what risks the site poses if no action were taken. It provides the
basis for taking action and identifies the contaminants and exposure pathways that need to be addressed
by the remedial action. This section of the ROD summarizes the results of the baseline risk assessment for
this Site. The summary of the relevant aspects of the human health risk assessment and ecological risk
assessments, discussed below, support the need for remedial action.
Human Health Risk Assessment
A baseline human health risk assessment (BHHRA) was conducted pursuant to EPA Risk Assessment
Guidance for Superfund (RAGS). The BHHRA followed a four-step process:
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1) hazard 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 and uncertainty analysis, 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 and a discussion of the uncertainty in the risk estimates.
These evaluations are discussed below.
Hazard Identification
Thirty-seven of the approximately 115 chemicals detected at the Site were selected for evaluation in the
HHRA as chemicals of potential concern (COPCs). The COPCs were selected based on toxicity,
concentration, frequency of detection, and mobility and persistence in the environment, and can be found
in Tables 2.1 through 2.7 of the baseline HHRA. From this, a subset of the chemicals was identified in the
HHRA as presenting a significant current or future risk and/or were identified at the Site in excess of the
appropriate chemical-specific ARAR value; these chemicals are referred to as the COCs in this ROD. The
COCs are listed in Tables G-l and G-2 of Appendix B along with the exposure point concentrations
used to evaluate the reasonable maximum exposure (RME) scenario in the baseline HHRA. Estimates of
average or central tendency exposure concentrations for the COCs and all COPCs can be found in Tables
3.1 through 3.9 of the baseline HHRA.
All of the COCs in Tables G-l and G-2 were identified as presenting a significant risk in the baseline
HHRA except for cis-l,2-dichloroethene, bis(2-ethylhexyl)phthalate, perfluorooctanoic acid (PFOA),
perfluorooctane sulfonic acid (PFOS), and antimony in groundwater; these analytes are included because
their maximum detected concentrations in groundwater exceed a chemical specific-ARAR value (e.g.,
MCLs).
The COCs identified for OU2 of the Site are:
Overburden Groundwater
1,4-dichlorobenzene
1.1-dichloroethane
1.2-dichloroethane
cis-l,2-dichloroethene
1,2-dichloropropane
1,4-dioxane
Benzene
Naphthalene
trichloroethene
vinyl chloride
bis-2-ethylhexyl phthalate
PFOA (and total PFOA+PFOS)
Antimony
Arsenic
chromium (VI)
Iron
Manganese
Bedrock Groundwater
1.1-dichloroethane
1.2-dichloroethane
1,4-dioxane
Benzene
cis-l,2-dichloroethene
Tetrachloroethene
Trichloroethene
vinyl chloride
PFOA (and total PFOA+PFOS)
Arsenic
chromium (VI)
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Exposure Assessment
Exposures to COPCs were estimated quantitatively or qualitatively through the development of several
different exposure scenarios. Exposure scenarios were developed based on the nature and extent of
contamination, the location of the Site, current and future potential use of the Site, and identification of
potential receptors and exposure pathways. Potentially exposed populations include recreational users of
Trout Brook Pond and associated tributaries and brook, as well as current and future residents living near
or downgradient of the landfill.
Groundwater data from shallow overburden within areas that could potentially be developed were
compared to EPA Vapor Intrusion Screening Levels (VISLs) to assess whether a vapor intrusion pathway
could present a potential risk to human health if new residences are constructed. Maximum detected
concentrations of benzene, cis-l,2-dichlorethene, TCE and vinyl chloride exceeded the groundwater
VISLs. The area of the Site evaluated for vapor intrusion remains undeveloped, therefore a complete
vapor intrusion pathway currently does not exist; however, the presence of elevated concentrations of
VOCs in groundwater at the Site indicates there may be a need for further evaluation of the future vapor
intrusion pathway if any new buildings are constructed at the Site that may increase the potential for
vapor intrusion to occur.
Potential risk from fish consumption by recreational users was evaluated by comparing detected surface
water concentrations of COPCs against National Recommended Water Quality Criteria and RIDEM
Water Quality Criteria, which are human health-based criteria protective of fish and water ingestion.
Results indicate the following:
• Arsenic, lead, and 1,4-dioxane concentrations exceeded criteria at multiple locations across Trout
Brook, Trout Brook Pond and the Tributaries Area.
• Concentrations of PAHs (such as benzo(a)pyrene) exceeded criteria in two locations in the
Tributaries Area (TRIB-04, TRIB-08), and one location in Trout Brook (TB-08).
• Several other contaminants had concentrations above the criteria, but exceedances were not
widespread and appeared limited to specific locations (TRIB-01, TRIB-04-pesticides; TRIB-01-
thallium; TRIB-09-cadmium)
Based on exceedances of the criteria in surface water, fish populations will be evaluated as part of the pre-
design investigation. Sampling of fish may be conducted if it is determined that sufficient populations of
fish suitable for consumption are present in Trout Brook Pond, in order to further evaluate whether there
is human health risk from fish consumption.
Exposure point concentrations (EPCs) are the COPC concentrations that a receptor is assumed to
encounter during exposure to Site contaminated media. In general, the 95% UCL of the arithmetic mean
concentration was used as the EPC for both central tendency exposure (CTE) and reasonable maximum
exposure (RME) scenarios, where an adequate sample size existed. In cases where a COPC within an
exposure point had a small sample size (<10) or a small number of detected concentrations (<3), the
maximum concentration was selected as the EPC.
Exposure doses are dependent upon the magnitude, frequency, and duration of exposure. They are
estimated by combining the COPC concentration (i.e., the EPC) and the exposure parameters. The
exposure doses are expressed as intakes in milligrams of COPC per kilogram of body weight per day
(mg/kg-day). The lifetime average daily dose (LADD) or the lifetime average daily exposure (for
inhalation pathways), which is averaged over a 70-year lifetime, was used to estimate exposure dose for
carcinogens. The average daily dose (ADD) or average daily exposure (for inhalation pathways), which is
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averaged over the actual exposure duration for each receptor, was used to estimate exposure dose for non-
cancer compounds.
More information about the exposure scenarios developed for this Site can be found in Section E. A more
thorough description of all exposure pathways evaluated in the risk assessment including estimates for an
average exposure scenario, can be found in Section 3 and in Tables 4.1 through 4.8 of the baseline
HHRA.
Toxicity Assessment
Carcinogenic Effects
For cancer effects, the toxicity values are expressed as oral cancer slope factors (CSFs) in units of per
milligrams of COPC per kilogram of body weight per day (mg/kg-day)"1 or as inhalation unit risk (IUR)
factors in units of per micrograms of COPC per cubic meter (fig/m3)"1. EPA has assigned each
contaminant a "weight-of-evidence" category that represents the likelihood of it being a human
carcinogen. Table G-3 of Appendix B presents these cancer toxicity values and cancer classifications for
the COCs which showed significant risk at the Site. EPA's Cancer Guidelines and Supplemental
Guidance (March 2005) have been used as the basis for analysis of carcinogenicity risk assessment.
Non-Carcinogenic Effects
Non-carcinogens refer to contaminants that cause toxic effects other than cancer. Non-cancer effects can
include central nervous system damage, reproductive effects, and other systemic effects. For addressing
non-carcinogenic effects, it is EPA's policy to assume that a threshold level exists, below which adverse
effects are not expected to occur. This threshold level is described by the reference dose (RfD) or
reference concentration (RfC) for inhalation exposures. RfDs and RfCs have been developed by EPA as
an estimate of a daily exposure that is likely to be without an appreciable risk of an adverse health effect
during a lifetime. RfDs and RfCs are derived from epidemiological and/or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will not occur. The RfDs and RfCs relevant
to the Site are presented in Table G-4 of Appendix B.
Risk Characterization
The risk characterization combines the exposure estimate with the toxicity information to estimate the
probability or potential that adverse health effects may occur if no action were to be taken at a site.
Carcinogenic risks were calculated for those COPCs with evidence of carcinogenicity and for which
cancer toxicity values are available. Non-cancer health effects were evaluated for all COPCs (i.e.,
including carcinogens) for which non-cancer toxicity values are available.
Cancer Health Effects
Potential cancer risk from the ingestion and dermal contact pathways was calculated by multiplying the
estimated LADD for each COPC by the chemical-specific CSF. The LADD (or lifetime average daily
dose) is expressed as intake averaged over a 70-year lifetime as mg COPC/kg-body weight per day. The
CSF is the COPC- and route-specific cancer slope factor (mg/kg-day)"1. CSFs are upper-bound estimates
of the excess risk of developing cancer as a result of a period of continuous exposure to a chemical,
averaged throughout the course of a 70-year lifetime and are developed based on the assumption that
there is no threshold level of exposure below which adverse effects will not be seen.
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Potential cancer risk from the inhalation pathway was calculated by multiplying the estimated lifetime
average daily exposure (LADE) for each COPC by the chemical-specific IUR. The LADE is expressed as
intake averaged over a 70-year lifetime as mg of COPC/m3 of air. The IUR is the COPC-specific
inhalation unit risk factor (fig/m3)1. The IUR is the 95 percent UCL of the mean incremental lifetime
cancer risk estimated to result from lifetime exposure to an agent if it is in the air at a concentration of 1
microgram per cubic meter (risk per (ig/m3).
As described in EPA's Supplemental Guidance for Assessing Susceptibility from Early Life Exposure to
Carcinogens, evidence suggests that chemicals with a mutagenic mode of action, which would be
expected to cause irreversible changes to DNA, would exhibit a greater effect in early-life versus later-life
exposures. EPA's guidance on cancer risks recommend the use of age-dependent adjustment factors
(ADAFs) for carcinogens that act via a mutagenic model. The ADAF accounts for susceptibility
differences between early- and later-life exposures and is applied to the cancer slope factor or inhalation
unit risk. ADAFs are combined with age-specific exposure estimates when assessing cancer risks.
Cancer risk estimates can be expressed in scientific notation or as a probability (e.g., 1 x 10"6 or 1E-06 for
1/1,000,000) and indicate (using this example), that an average individual is not likely to have greater
than a one in a million chance of developing cancer over 70 years as a result of site-related exposure (as
defined) to the contaminant at the stated concentration.
All risks estimated represent an incremental risk of cancer from exposures to contamination originating
from the Site, which go beyond an individual's baseline risk of developing cancer. The chance of an
individual developing cancer from all other (unrelated to the Site) causes has been estimated to be as high
as one in three. EPA generally views site related cancer risks in excess of 10~4 (1 in 10,000) as
unacceptable. Current EPA practice considers carcinogenic risks to be additive when assessing exposure
to a mixture of hazardous substances.
Non-Cancer Health Effects
The potential for non-cancer risks is characterized by the hazard quotient (HQ). The HQ is a ratio of the
estimated average daily dose (ADD) (or the average daily exposure (ADE) in the case of air exposures)
and a threshold value below which adverse health effects would not be expected to occur (RfD or RfC). A
HQ < 1 indicates that adverse effects are unlikely. Conversely, a HQ > 1 indicates that adverse effects as
a result of exposure to the contaminant are possible. To account for additive effects resulting from
exposure to more than one compound, a hazard index (HI) is generated by adding the HQs for all
chemicals of concern that have the same or a similar mechanism or mode of action. As a conservative
measure and a common practice, HQs are often added for all contaminants of concern that affect the same
organ or system (i.e., liver, nervous system) since the mechanism or mode of action is not always known,
which results in a hazard index (HI). A HI < 1 indicates that adverse effects are unlikely whereas a HI > 1
indicates adverse effects are possible. Generally, EPA views HI values based on site-related exposure
above 1 as unacceptable. It should be noted that the magnitude of the HQ or HI is not proportional to the
likelihood that an adverse effect will be observed.
The following is a summary of the media and exposure pathways that were found to present a risk
exceeding EPA's cancer risk range or non-cancer risk threshold at the Site. Only those exposure pathways
that will be addressed by the selected remedy are presented in this ROD. See Section 6.5 and Appendix
A, Tables 7, 9 and 10 of the baseline HHRA for a more comprehensive risk summary of all exposure
pathways evaluated for all COPCs, and for estimates of central tendency risk.
Current Resident - Groundwater
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Tables G-5 and G-6 of Appendix B depict the carcinogenic and non-carcinogenic risk summaries for the
COCs in residential groundwater evaluated to reflect current residential potable water exposure
corresponding to the RME scenario. For a current resident using untreated groundwater as household
water, carcinogenic and non-carcinogenic risks exceeded the EPA acceptable cancer risk range of 10~4 to
10"6 and/or a target organ HI of 1 for groundwater. The exceedances were due to the presence of
naphthalene (in one occurrence) in one residential well and chloroform in another (related to the
homeowner's well disinfection activities).
Future Resident - Groundwater
Tables G-7 through G-10 of Appendix B depict the carcinogenic and non-carcinogenic risk summaries
for the COCs in overburden and bedrock groundwater evaluated to reflect potential future residential
potable water exposure corresponding to the RME scenario (under the assumption that groundwater
associated with the Site is used as a source of potable water in the future). For a future resident using
untreated groundwater as household water, carcinogenic and non-carcinogenic risks exceeded the EPA
acceptable cancer risk range of 10"4 to 10"6 and/or a target organ HI of 1 for groundwater. The
exceedances were due primarily to the presence of 1,4-dioxane, naphthalene, trichloroethene, vinyl
chloride, hexavalent chromium, arsenic, and manganese in Site groundwater. Though not listed on Tables
G-7 through G-10, cis-l,2-dichloroethene, bis(2-ethylhexyl)phthalate, PFOA, PFOS, and antimony are
also Site groundwater COCs because their maximum detected concentrations exceed ARARs, even
though the baseline HHRA did not identify them as primary risk contributors.
Uncertainties
The groundwater dataset for target analytes (except for polyfluorinated alkyl substances [PFAS]) was
based on five years of monitoring data, and thus reflects long-term temporal variability in contaminant
concentrations, and provides confidence in characterizing exposure. PFAS, an emergent class of
contaminants, were analyzed in only a subset of wells for up to three sampling events. There is some
uncertainty on whether these data adequately represent temporal and spatial changes in conditions. The
observed concentrations of PFOA+PFOS (combined) in groundwater are higher (up to four times) than
both the EPA Health Advisory and the State of Rhode Island regulatory standard of 70 ng/L.
Accordingly, PFAS concentrations represent an unacceptable risk at the Site.
Overburden and bedrock groundwater were evaluated as future potable water sources. While this is
possible, since the Site is located in an area zoned for drinking water, the probability of use of the
overburden aquifer as a future water supply is expected to be low, since potable wells are more often
drilled bedrock wells.
Groundwater data from shallow overburden within areas that could potentially be developed were
compared to EPA Vapor Intrusion Screening Levels (VISLs) to assess whether a vapor intrusion pathway
could occur if new residences are constructed. Uncertainties in calculating the EPA Vapor Intrusion
Screening Levels (VISLs) include certain generic assumptions about the building dimensions, the amount
of attenuation that occurs, and potential contribution of indoor sources (indoor chemical use).
Additionally, VISLs were based on residential use and assume that exposure to COPCs in indoor air
occurs 24 hours per day, 350 days per year, for the full residential tenure. In all likelihood, this
assumption may overestimate risks for the majority of the population, since a significant portion of time
each day may be spent at school, work, or other locations.
The area of the Site evaluated for vapor intrusion is undeveloped (and will likely remain undeveloped for
the foreseeable future), therefore a complete vapor intrusion pathway currently does not exist.
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Exceedances of VISLs suggest that a complete vapor intrusion pathway may potentially exist in the
future, should this portion of the Site be developed, and that the vapor intrusion pathway should be
evaluated further if buildings are considered for this portion of the Site.
Hexavalent chromium was identified as a cancer risk driver for receptors. Because samples were analyzed
for total chromium, rather than speciated chromium (trivalent and hexavalent), there is considerable
uncertainty as to whether hexavalent chromium is present at the Site. In the absence of site-specific data,
the HHRA conservatively assumed that the entire fraction of total chromium consisted of hexavalent
chromium (the most toxic form) to estimate hazard and risk.
Fish tissue data were not collected at the Site, and so the potential for health risks related to fish
consumption was evaluated by comparing detected surface water concentrations of COPCs against
National Recommended Water Quality Criteria and RIDEM Water Quality Criteria, which are human
health-based criteria protective of fish and water ingestion.
Based on exceedances of the criteria in surface water, fish populations will be evaluated as part of the pre-
design investigation. Sampling of fish may be conducted if it is determined that sufficient populations of
fish suitable for consumption are present in Trout Brook Pond, in order to further evaluate whether there
is human health risk from fish consumption. Risks related to the fish consumption pathway were not
included in the cumulative estimates of hazard/risk for the recreational user scenarios, which may
potentially underpredict risks. However, the water quality criteria for fish ingestion are conservative and
assume that both fishing and ingestion of water in surface water bodies occurs on a regular basis. This
scenario is unlikely for Trout Brook, Trout Brook Pond, and the Tributaries, none of which are significant
recreational fishing or swimming areas (particularly in the Tributaries and Trout Brook areas).
The recreational user (surface water and sediment pathways) and the residential receptors (groundwater
pathways) were evaluated as separate exposure scenarios. It is possible that a local resident (particularly
for future use scenarios where development within the plume core could hypothetically occur) who
contacts Site groundwater could also fish, wade and/or swim in Trout Brook, Trout Brook Pond and/or
appurtenant tributaries, and thus have a resultant higher cumulative risk from Site COPCs than those risks
predicted by each of the separate exposure scenarios.
The complete baseline human health risk assessment can be found in the November 2019 Baseline
Human Health Risk Assessment.
Ecological Risks
A Screening Level Ecological Risk Assessment (SLERA) and Refinement was performed in two phases
to evaluate the risk to ecological receptors potentially affected by the Site. Chemicals originally identified
as chemicals of potential ecological concern (COPECs) potentially related to the Site included metals
(primarily arsenic and lead), DDT, and cVOCs. The habitats potentially affected by the Site include
downgradient Trout Brook and its associated wetlands (east of the landfill), tributaries to Trout Brook,
and Trout Brook Pond. In addition, upgradient areas were investigated for comparison purposes.
Data to support the analyses in the SLERA were collected during two rounds of wetland and ecological
sampling events in June/July 2016 and May 2017 to reflect seasonal diversity. Samples were collected
from pore water, surface water, and sediment. Analyses included VOCs, 1,4-dioxane, metals, PCBs,
pesticides, and SVOCs in each medium, as well as simultaneously extracted metals (SEM), acid volatile
sulfides (AYS), and total organic carbon (TOC) in sediment.
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Two ecologically relevant Exposure Areas (EAs) were established for the purposes of the risk assessment
based on habitat types, contaminant fate and transport pathways, and hydrogeology. These exposure areas
were:
• Trout Brook Area (including downgradient Trout Brook Pond); and
• Tributary Area.
In addition, sample locations in upgradient areas were identified to represent reference locations for each
habitat and media type (surface water, sediment, and soil).
Maximum concentrations of surface water, sediment (both shallow [0-6"] and deep [6-12"]), and pore
water collected in June/July 2016 were screened against ecological benchmarks in the 2017 SLERA to
identify initial COPECs. COPEC refinement, which included benchmark adjustments based on hardness
and TOC, as well as comparison to upgradient results, was performed in the 2017 SLERA, along with
determination of potential data gaps. COPECs resulting from this refinement included:
• Pore water - CVOCs and lead
• Surface water - DDT
• Sediment - Acetone and arsenic.
The SLERA and Refinement concluded the following:
• Concentrations of metals, VOCs, SVOCs, and pesticides exceeded the most conservative
screening-level ecological benchmarks; however, the number of locations where exceedances
occurred is limited and the magnitude of the exceedances was relatively small for most
constituents.
• A comparison to alternative, less-conservative benchmarks indicated that most COPECs are
below effects level concentrations.
• Upgradient Area sample results demonstrate that acetone, metals, and PAHs are present;
however, overall, the Upgradient Area concentrations of most constituents were lower than those
detected in the Tributary and/or Trout Brook Areas.
Based on this evaluation, the SLERA indicated that there is minimal likelihood for adverse ecological
impacts to the majority of the Site as a result of releases from the landfill. However, there are certain
locations in Trout Brook and the Tributary Areas where elevated concentrations of constituents, namely
chlorinated benzene compounds and arsenic, are present at concentrations that may pose a potential risk
to ecological receptors.
Further evaluation of ecological risk through a Baseline Ecological Risk Assessment (BERA) was not
recommended. Presumably, groundwater from the landfill, which was initially capped in 1979 and
underwent a series of upgrades between 1994 and 1996, is upwelling into the wetlands to cause elevated
concentrations of CVOCs and arsenic. An additional round of data collection was recommended to verify
contaminant presence and concentration and evaluate seasonal variability.
Sampling performed in May 2017 was evaluated in the 2018 Interim Final SLERA. This report included:
• A comparison of the June 2016 and the May 2017 wetland/ecological sampling results;
• A review of 2017 results with respect to the findings of the SLERA and Refinement; and
• A determination of whether compounds referred to as "Uncertain" COPECs in the Interim Final
SLERA and Refinement are Site-related and may pose a potential risk to ecological receptors.
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The 2018 Interim Final SLERA concluded the following:
• In general, the types of contaminants and magnitude of concentrations detected in Site media in
2017 are similar to those observed in 2016.
• Exceedances of ecological benchmarks in 2017 are typically in sample locations where
corresponding exceedances were identified in 2016.
• Pore water COPECs include 1,4-dichlorobenzene and lead.
• No COPECs were identified for surface water.
• Sediment COPECs include arsenic and selenium.
In summary, the 2017 analytical results support the conclusions of the 2017 SLERA and Refinement,
with minor exceptions, including the addition of selenium as a COPEC in sediment, and the exclusion of
DDT in surface water and acetone in sediment as COPECs.
Following review of the SLERA and Refinement, EPA concluded that there was no clear indication of
ecological risk for which remedial action would be required, and therefore a BERA was not performed for
OU2 of the Site.
The complete ecological risk assessment can be found in the September 2018 Screening Level Ecological
Risk Assessment and Refinement.
H. REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAOs) are media-specific cleanup goals that define the objective of
remedial actions to protect human health and the environment. RAOs specify the COCs, potential
exposure routes and receptors and provide a general description of what the cleanup will accomplish. The
RAOs are based on available information and standards, such as ARARs, To Be Considered (TBC)
guidance, and site-specific risk-based levels. These RAOs were developed to mitigate, restore, and/or
prevent existing and future potential threats to human health and the environment and to attain ARARs.
The COCs and associated groundwater cleanup levels are presented in Table L-l in Appendix B of this
ROD. The RAOs for the selected remedy for the Site are:
• Prevent exposure by current and future area residents to groundwater containing site COCs that
exceed ARARs or would result in a total excess lifetime cancer risk greater than the target risk
range of 10 4 to 10 fi. and/or a non-cancer hazard index greater than 1.
• Prevent exposure by future building occupants to indoor air vapors emanating from shallow
groundwater containing site COCs that would result in a total excess lifetime cancer risk greater
than the target risk range of 10 4 to 10 fi. and/or a non-cancer hazard index greater than 1.
• Restore groundwater containing site COCs to its beneficial use as a potential future drinking
water source by reducing concentrations of contaminants so that they do not exceed ARARs or
result in a total excess lifetime cancer risk greater than the target risk range of 10~4 to 10~6, and/or
a noncancer hazard index greater than 1.
• Prevent or minimize migration of site COCs in groundwater in excess of cleanup levels to Trout
Brook, Trout Brook Pond, and related wetlands and tributaries.
• Prevent or minimize migration of site COCs in groundwater in excess of cleanup levels to the
residential drinking water wells along Pound Hill Road.
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I. DEVELOPMENT AND SCREENING OF ALTERNATIVES
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. The goal of the Superfund program as
stated in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) at 40 C.F.R.
§300.430(a)(l)(i) is to select remedies that are protective of human health and the environment, that
maintain protection over time, and that minimize untreated waste. In addition, Section 121 of CERCLA
establishes several other statutory requirements and preferences, including: 1) a requirement that EPA's
remedial action, when complete, must comply with all federal environmental and more stringent state
environmental and facility siting standards, requirements, criteria, or limitations, unless a waiver is
invoked; 2) 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 3) a preference for remedies in which treatment permanently and
significantly reduces the toxicity, mobility, or volume of the hazardous substances is a principal element
over remedies not involving such treatment. Remedial alternatives were developed to be consistent with
these statutory requirements and preferences.
Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial actions are evaluated and selected. In
accordance with these requirements, a range of remedial alternatives were developed for the Site. As
discussed in Section 3 of the June 2020 FS report, groundwater treatment technology options were
identified, assessed, and screened based on implementability, effectiveness, and cost.
Section 4 of the June 2020 FS report presents a limited number of remedial alternatives that attain site
specific cleanup levels within different time frames using different technologies, including an innovative
treatment technology; an alternative that involves little or no treatment but provides protection through
institutional controls; and a no action alternative. Each alternative was then evaluated in detail in Section
5 of the June 2020 FS report.
J. DESCRIPTION OF ALTERNATIVES
This section provides a narrative summary of each remedial alternative retained following screening and
evaluated in the detailed analyses (Section 4.0) of the June 2020 FS report. These alternatives were
developed by combining response actions and technologies to address the estimated exposure risks to
human health and the environment. The alternatives were also developed, to the extent practicable, to
represent a range of effectiveness, duration of time required to achieve the RAOs, and cost to implement.
The specific details of each remedial alternative are conceptual and are used for costing purposes. The
specific design details and costs for the selected remedy will be re-evaluated during the remedial design.
The costs are intended to be within the target accuracy of -30 to +50% of the actual cost. All present
worth costs associated with O&M and periodic expenditures are based on a 7% discount rate over 30
years.
The remedial action alternatives for OU2 are presented below. They are numbered to correspond with the
FS. More complete, detailed presentations of each alternative can be found in Section 4.0 of the June
2020 FS report.
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Alternative 1: No Action
Alternative 1 was developed as a baseline case, as required by the NCP, to which all other alternatives
may be compared. Under this alternative, no action would be taken to address exposure to groundwater or
to reduce the toxicity, mobility, or volume of contaminated groundwater at the Site. As required by
CERCLA, a review of Site conditions and risks would be conducted every five years since contamination
would remain on the Site above levels that allow for unlimited use and unrestricted exposure.
The estimated present worth cost associated with Alternative 1 is $430,000. The range of costs based on a
-30 to +50 range of accuracy is $301,000 to $645,000.
Alternative 2: Limited Action: Institutional Controls and Monitoring
Alternative 2 was developed as a limited action alternative. Under this alternative, no action would be
taken to reduce the toxicity, mobility, or volume of contaminated groundwater at the Site, however,
institutional controls would be implemented to protect human health by preventing or controlling
potential exposures to contaminated groundwater. As required by CERCLA, a review of Site conditions
and risks would be conducted every five years since contamination would remain on the Site above levels
that allow for unlimited use and unrestricted exposure.
The estimated present worth cost associated with Alternative 2 is $2,300,000. The range of costs based on
a -30 to +50 range of accuracy is $1,610,000 to $3,450,000.
Alternative 3: Groundwater Extraction with Ex Situ Treatment, Institutional Controls, and
Monitoring (This is EPA '.s contingency remedy)
Alternative 3 includes the implementation of active groundwater extraction and ex situ treatment,
institutional controls, and monitoring. This alternative consists of installation of a groundwater extraction
system to intercept, collect, and treat contaminated groundwater across a three-dimensional target capture
zone. Treated water would be injected in rapid infiltration basins. Figure 4-1 in Appendix C of this ROD
depicts the general components and target treatment areas of Alternative 3.
Alternative 3 includes the following components:
• Pre-Design Investigation: Pre-design investigations would include an additional groundwater
investigation to determine optimal extraction well placement. Pumping tests and other studies
would be conducted to assist in determining pumping rates, locations, and depths of extraction
wells. Sampling and analysis of extracted groundwater would be used to assist in the development
of the groundwater treatment system design. Infiltration tests and hydraulic modeling would be
needed to support the infiltration of treated groundwater.
• Treatability/Pilot Testing: Treatability and pilot testing would be used to optimize treatment
components and finalize treatment design based on the results from pre-design studies.
• Extraction and Injection System: The groundwater extraction system would consist of a series of
extraction wells that would capture contaminated portions of the aquifer while minimizing
extraction of uncontaminated groundwater and impacts to the wetlands. The extraction system
would also include pumps, electronic controls, and a network of underground piping that would
convey extracted groundwater to a central treatment location. Treated water would be conveyed to
infiltration basins constructed outside the treatment area. The infiltration basins allow the treated
groundwater to slowly seep into the ground.
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• Treatment Plant: The treatment system would occupy an approximate 60 by 60 square foot
footprint on the landfill property. Extracted groundwater would be treated by a series of processes.
The pre-treatment elements would focus on metals and suspended solids removal. These pre-
treatment processes would be followed by contaminant-specific treatment processes including
advanced oxidation (AO) for 1,4-dioxane treatment and granular activated carbon (GAC) treatment
for PFAS removal.
• Operation and Maintenance of the Treatment System: Operation and Maintenance (O&M)
would include monitoring to evaluate that all parts of the extraction and treatment system are
operating properly. Equipment replacement and repair would be completed in accordance with an
O&M plan approved by EPA.
• Wetland Restoration: Treatment system piping will likely be constructed within a wetland
because groundwater impacts extend below the wetlands adjacent to Trout Brook. The remedy will
be designed to minimize wetland and floodplain impacts. Wetlands that are disturbed as part of
construction will be restored, and any impacts to floodplains are expected to be temporary.
• Monitoring: Monitoring would include groundwater and surface water monitoring. The monitoring
program includes the current OU1 Post Closure Site Monitoring (PCSM) program, monitoring of
wells installed as part of OU2 Remedial Investigation activities, and monitoring of new wells
intended to enhance the Site-wide network to evaluate if contaminant concentrations are decreasing
by natural processes. Surface water monitoring is included in the PCSM and Long-Term
Monitoring (LTM) programs. Monitoring of residential drinking water wells is also included in this
alternative. Remedy performance monitoring would include the installation and sampling of
additional performance monitoring wells and extraction wells to evaluate remedy performance.
• Institutional Controls: Institutional controls (ICs) would be implemented to restrict groundwater
use in all areas necessary to control exposure. ICs may also be necessary for the protection of the
selected remedy including limitations on uses and activities that interfere with or disturb
components of the remedy. ICs are also necessary to require a vapor intrusion assessment and/or a
vapor barrier for new building construction in areas where Site related groundwater contamination
is present.
• Five-Year Reviews: The Site will be reviewed at a minimum of every five years to assess
protectiveness of the remedy.
The estimated timeframe for cleanup for groundwater hydraulically upgradient of the extraction well
network ranges from 40 to 92 years. For the downgradient aquifer zones located beyond the extraction
well network, cleanup levels are expected to be achieved between 11 and 19 years following
implementation of the remedy.
The estimated present worth cost associated with Alternative 3 is $14,600,000. The range of costs based
on a -30 to +50 range of accuracy is $10,220,000 to $21,900,000.
Alternative 4: Two-Stage Reactive Treatment Zone, Institutional Controls, and Monitoring
(This is EPA '.s selected remedy)
Alternative 4 includes in situ treatment and sequestration, institutional controls, and monitoring. The in
situ groundwater treatment strategy includes two technologies that would be used together in a two-stage
reactive treatment zone to address Site COCs. The two technologies include: (i) ISCO with potassium
persulfate, a slow-release form of chemical oxidant, to address CVOCs, 1,4-dioxane, and some PFAS
(notably perfluorinated carboxylic acids (PFCAs); and (ii) sequestration/stabilization with injectable
activated carbon for PFAS that are not susceptible to ISCO, primarily PFSAs associated with the sulfonic
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acid/sulfonate sub-group. Metals are not specifically addressed by these technologies; however, metals
are expected to become less mobile in the subsurface as groundwater shifts towards prevailing oxidizing
conditions following persulfate injections. Performance monitoring will be conducted to evaluate whether
the treatment of VOCs has resulted in conditions which will reduce the mobility and associated
concentrations of metals in groundwater. Figure 4-2 in Appendix C of this ROD depicts the general
components and target treatment areas of Alternative 4.
Alternative 4 includes the following components:
• Treatability/Pilot Testing: Treatability testing is underway and will be completed to determine the
effectiveness of the innovative technologies to treat Site-specific conditions. Treatability testing
provides information to design the pilot test and the full-scale remedy. Pilot testing will be
performed to provide additional information for implementation (such as, injection volumes, radius
of influence, field-scale solubility/longevity of the reagents, and the Site-specific method(s) for
injection).
• Pre-Design Investigations: Pre-design investigations will likely include steps to refine the extent
of horizontal and vertical impacts in the vicinity of the proposed footprint of the two-stage reactive
zone, understand contrasts in overburden permeabilities, and identify target treatment zones.
• In-situ Chemical Oxidation (ISCO) Treatment Zone: This alternative uses a combination of
potassium persulfate and sodium persulfate injections as the first step to treat the contaminant mass
and non-target oxidant demand, respectively. An iron activator may also be used to facilitate the
oxidative processes.
• ISCO Injections: In addition to the ISCO treatment zone, the remedy includes targeted ISCO
injections in areas downgradient of the ISCO treatment zone in areas of elevated 1,4-dioxane
concentrations.
• Activated Carbon (AC) Injections: The remedy includes a second step consisting of an activated
carbon barrier extending approximately 5 to 60 feet below ground surface and 750 feet across.
• Wetland Restoration: In-situ treatment zones may need to be constructed within a wetland or
floodplain because groundwater impacts extend below the wetlands adjacent to Trout Brook. The
remedy will be designed to minimize wetland and floodplain impacts. Wetlands that are disturbed
as part of construction will be restored and impacts to any floodplain are expected to be temporary.
• Monitoring: Monitoring includes groundwater and surface water monitoring. The monitoring
program includes the current OU1 Post Closure Site Monitoring (PCSM) program, monitoring of
wells installed as part of OU2 Remedial Investigation activities, and monitoring of new wells
intended to enhance the Site-wide network to evaluate if contaminant concentrations are decreasing
by natural processes. Surface water monitoring is included in the PCSM and LTM programs.
Monitoring of residential drinking water wells is also included in this alternative. Remedy
performance monitoring will also include the installation and sampling of additional performance
monitoring wells upgradient of the ISCO injections, between the two stages, and downgradient of
the AC zone to monitor remedy performance.
• Institutional Controls: Institutional controls (ICs) would be implemented to restrict groundwater
use in all areas necessary to control exposure. ICs may also be necessary for the protection of the
selected remedy including limitations on uses and activities that interfere with or disturb
components of the remedy. ICs are also necessary to require a vapor intrusion assessment and/or a
vapor barrier for new building construction in areas where Site related groundwater contamination
is present.
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• Five-Year Reviews: The Site will be reviewed at a minimum of every five years to assess
protectiveness of the remedy.
The estimated timeframe for cleanup for groundwater hydraulically upgradient of the treatment zones
ranges from 55 to 119 years. For the downgradient aquifer zones located beyond the two treatment zones,
cleanup levels are expected to be achieved between 8 and 19 years following implementation of the
remedy.
The estimated present worth cost associated with Alternative 4 is $11,700,000. The range of costs based
on a -30 to +50 range of accuracy is $8,190,000 to $17,550,000.
K. COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(1) of CERCLA presents several factors that, at a minimum, EPA is required to consider in
its assessment of remedial alternatives. Building upon these specific statutory mandates, the NCP
articulates nine evaluation criteria to be used in assessing the individual remedial alternatives.
A detailed analysis was performed on the remedial alternatives for OU2 using the nine evaluation criteria
in order to select a Site remedy. The comparative analysis of alternatives was presented in Section 6 of
the June 2020 FS report. 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 for the alternatives to be eligible for selection in
accordance with the NCP.
1. Overall protection of human health and the environment addresses whether 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 a remedy will meet all Federal environmental and more stringent State environmental
and facility siting standards, requirements, criteria, or limitations, unless a waiver is invoked.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate the elements of one alternative to another
that meet the threshold criteria:
3. Long-term effectiveness and permanence address 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.
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.
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7. Cost includes estimated capital and O&M costs, as well as present value costs.
Modifying Criteria
The modifying criteria are used as the final evaluation of remedial alternatives, generally after EPA has
received public comments on the Proposed Plan:
8. State acceptance addresses the State's position and key concerns related to the preferred
alternative and the other alternatives described in the Proposed Plan and FS, and the State's
comments on ARARs or the proposed use of waivers.
9. Community acceptance addresses the public's general response to the alternatives described in
the Proposed Plan and FS.
Following the detailed analysis of each individual alternative, a comparative analysis was conducted
focusing on the relative performance of each alternative against the nine criteria. This comparative
analysis can be found in Section 6 of the June 2020 FS report and Table K-l of Appendix B of this
ROD.
Comparative Analysis of Groundwater Alternatives
1. Overall Protection of Human Health and the Environment
Alternative 1 fails to meet the threshold criteria for overall protection of human health and the
environment because the unacceptable future risks to human health are not reduced, controlled, or
eliminated. COCs would remain in groundwater at levels exceeding the cleanup levels and potential
human health risks would exist during this time.
Alternative 2 meets the threshold criteria for overall protection of human health and the environment
because institutional controls will protect against human contact with contaminated groundwater by
prohibiting certain uses (e.g., drinking water) or requiring pre-treatment of water prior to use.
Alternative 3, which is EPA's contingency remedy, meets the threshold criteria for overall protection of
human health and the environment because groundwater extraction and treatment is an effective and
well-proven means of containment and treatment of impacted groundwater. This alternative would reduce
contaminant mass downgradient of the hydraulic containment zone, and institutional controls would be
used to protect human health during the remedial action.
Alternative 4, which is EPA's selected remedy, meets the threshold criteria for overall protection of
human health and the environment because most of the dissolved-phase contaminant mass would be
destroyed in situ through I SCO and any untreated residual fractions would be sequestered in situ through
adsorption using AC. This alternative would reduce contaminant mass downgradient of the treatment
zone, and institutional controls would be used to protect human health during the remedial action.
2. Compliance with ARARs
Alternative 1 and Alternative 2 do not comply with chemical-specific ARARs within a reasonable
timeframe. The expected timeframe to achieve compliance with RAOs under these alternatives, based on
site-specific hydrogeologic parameters and the extent of groundwater impacts, is 123 to 233 years.
Alternative 3 and Alternative 4 were developed to comply with ARARs within a reasonable timeframe.
Chemical-specific, action-specific, and location-specific ARARs are judged to be attainable with proper
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implementation for both of these alternatives. The ARARs and TBCs for these alternatives are outlined in
Appendix D of this ROD.
3. Long-term Effectiveness and Permanence
Alternative 1 docs not address the unacceptable future risks due to the Site and provides no long-term
effectiveness or permanence. Alternatives 2, 3, and 4 protect human health through the use of institutional
controls, which are effective over the long-term if adequately monitored and enforced. Additionally.
Alternative 3 and Alternative 4 are expected to reduce COCs in groundwater to below cleanup levels
within approximately 20 years downgradient of the remedy, permanently eliminating the potential risk to
human health and the environment. The time to conservatively achieve RAOs throughout the entire OU2
portion of the Site is estimated to take 40 to 92 years under Alternative 3 and 55 to 119 years under
Alternative 4. Alternatives 3 and 4 have similar clean up timeframes, and similar long-term effectiveness.
Under Alternative 3, long-term management of the treatment system components would be required to
maintain effectiveness. O&M would include process control activities, maintenance of extraction wells
and treatment equipment, periodic inspections to perform preventative maintenance, change-out or
regeneration of treatment media, and process water sampling to verify treatment system effectiveness.
Long term monitoring of groundwater would be required to evaluate COC levels in the aquifer and to
assess containment and the effectiveness of the treatment system.
Under Alternative 4, long term monitoring would be required to evaluate performance over time and
additional I SCO injections would likely be required to maintain effectiveness. The timeframe between
additional injections would be determined based on monitoring. The AC treatment zone has a predicted
life span of over 25 years, which is expected to be adequate to address PFSAs at the Site.
Based on these expectations. Alternatives 3 and 4 have similar long-term effectiveness and permanence;
however Alternative 4 has fewer long-term operation and maintenance requirements. Results from the
Treatability Study will assist in the determination of overall long-term effectiveness of Alternative 4.
4. Reduction of Contaminant Toxicity, Mobility, or Volume through Treatment
Alternatives 1 and 2 provide no reduction in toxicity, mobility, or volume through treatment. Alternative
3 would reduce mobility of all COCs through containment by extraction wells and would also reduce
contaminant toxicity through ex situ treatment. Alternative 4 would reduce toxicity of some COCs
(CVOCs. 1,4-dioxane, and some PFAS) through I SCO treatment, and would reduce the mobility of the
remaining organic COCs through sequestration to in situ activated carbon. Mobility of inorganic COCs is
also expected to be reduced follow ing persulfate injections as groundw ater shifts towards oxidizing
conditions. Both Alternative 3 and Alternative 4 are expected to provide similar overall reduction in
toxicity, mobility, and volume.
5. Short-term Effectiveness
Alternative 1 does not address the unacceptable future risks due to the Site, and thus it provides no short-
term effectiveness. Alternatives 2, 3, and 4 protect human health through the use of institutional controls,
which could be implemented shortly after remedy selection.
Alternatives 1 and 2 do not involve any activities that would create any additional short-term risks to
workers, the community, or the environment.
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During implementation of Alternative 3, risks to the community are expected to be low. Risks to the
environment include temporary disturbance to approximately 1,600 square feet of forested wetland (0.1%
of the total wetlands at the Site) caused by construction of conveyance piping for the treatment system.
Temporary impacts to the 100-year floodplain are similar in scale and involve an approximate 1,800
square foot area, with no permanent compensatory storage loss or impacts to the 500-year floodplain.
These risks would be mitigated by using best management practices and all work would be done in
accordance with ARARs. Impacted wetlands would be fully restored after construction. Impacts to
workers involved in construction and implementation of the groundwater extraction and treatment are
minimal and are anticipated to be manageable through use of personal protective equipment (PPE),
implementation of an appropriate health and safety program, and the use of qualified contractors.
Treatment chemicals will need continual management and secondary containment. Treated water would
infiltrate into the ground and would need to be monitored to evaluate potential impacts to the
environment; there is a risk of adverse effects on sensitive biotic receptors in the wetlands or Trout Brook
due to alteration of the local water balance by the groundwater extraction system. There would be
minimal disruption to neighboring land parcels during extraction well construction, trenching, treatment
building construction, and connection to a power supply source for system operation. These construction-
related activities will require some degree of coordination with surrounding landowners and utility
companies.
During implementation of Alternative 4, risks to the community are expected to be low. Risks to the
environment include temporary disturbance to approximately 2600 square feet of forested wetland (0.2%
of the total wetlands at the Site) caused by injections for the ISCO treatment zone. Temporary impacts to
the 100-year floodplain involve an approximate 8,600 square foot area, with no permanent compensatory
storage loss or impacts to the 500-year floodplain. These risks would be mitigated by using temporary
mats to minimize impacts from the equipment, best management practices, and all work would be done in
accordance with ARARs. Impacted wetlands would be fully restored after construction. Impacts to the
workers implementing the remedy include physical hazards from the equipment required for injections
and the potential exposure to the materials being injected. The selected chemicals for the ISCO injections
are corrosive. AC can form a combustible dust and can be an eye or respiratory irritant. These risks are
anticipated to be manageable through use of PPE, implementation of an appropriate health and safety
program, decontamination procedures, and the use of qualified contractors. There would be minimal
disruption to neighboring land parcels during implementation of the remedy. Design and implementation
of the alternative may require some degree of coordination with surrounding landowners and utility
companies.
Based on these expectations, Alternatives 3 and 4 have similar short-term effectiveness as well as similar-
short term risks.
6. Implementability
Alternative 1 is the most implementable as it requires no activities. Alternative 2 follows, as the only
activities required are implementation of institutional controls and monitoring.
Alternative 3, groundwater extraction and treatment, is a we 11-developed technology and is expected to be
readily implementable under current conditions. Significant delays to schedule are not likely to result
from technical concerns; however, bench or pilot testing would be required to optimize treatment design.
Treatment system operation is subject to intermittent shutdowns from power failures, treatment
complication, media changeouts, and well rehabilitation due to fouling. These shutdowns are anticipated
to be short-lived and would not result in extended periods of insufficient hydraulic control. Offsite
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treatment and/or disposal would be required for sludges that accumulate. Spent carbon from PFAS
treatment would require incineration. It is anticipated that there would be capacity for these materials at
an appropriate facility. The technologies proposed in the treatment system should be readily available.
Construction of the groundwater extraction and treatment system could be completed within 6 to 12
months of a final design.
Alternative 4 utilizes two technologies that have both been implemented individually at the full-scale
level and are available through commercial vendors. Amendments would be injected using readily
available technologies. Bench and pilot scale testing will be conducted to confirm effectiveness and
optimize design. A treatability study is currently underway to further refine this alternative and evaluate
the effectiveness of the innovative technologies to treat Site-specific conditions; refer to the Treatability
Study Work Plan for ISCO and AC in Appendix E of the FS. Application of the oxidants and AC to the
subsurface in a manner that promotes adequate contact time with contaminated groundwater will also be
confirmed through pilot testing. Injection methods are flexible and supplementary injections, if required,
would also use readily available and minimally disruptive injection methods. Implementation of the
treatment zone could be completed within 6 to 9 months of final design.
Based on these expectations, Alternatives 4 is somewhat more easily implementable than Alternative 3 as
it does not require building construction or connection to power; however, neither Alternative is
prohibitively difficult to implement.
7. Costs
There is no cost associated with Alternative 1 other than the cost of five-year reviews. The cost for
Alternative 2 is estimated to be $2.3 million; the cost for Alternative 3 is estimated to be $14.6 million;
and the cost for Alternative 4 is estimated to be $11.7 million.
8. State Acceptance
The State of Rhode Island, through its lead agency, RIDEM, has expressed its support for EPA's
preferred alternative presented in the July 2020 Proposed Plan, and concurs with the selected remedy,
including the contingency remedy, outlined in this ROD (see Appendix A of this ROD for the State
concurrence letter).
9. Community Acceptance
EPA's community engagement efforts at the Site included the publication of a Proposed Plan in July
2020; a virtual public informational meeting held on August 12, 2020; and a virtual public hearing which
immediately followed the public informational meeting. A transcript was created for this hearing and has
been included in the Responsiveness Summary located in Part 3 of this ROD. In addition to the one oral
comment received at the hearing, one written comment was also received. The comments were supportive
of the selected remedy but questioned the timing of it and the extent of well testing and monitoring to be
performed to evaluate potential impacts off-site. A summary of the comments and EPA's responses to
these comments are included in Part 3: The Responsiveness Summary of this ROD.
L. THE SELECTED REMEDY
EPA's selected remedy, Alternative 4, provides both short-term and long-term protection of human
health and the environment, attains applicable federal environmental and more stringent state
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environmental laws and regulations, reduces the toxicity, mobility, and volume of contaminants through
treatment to the extent practicable, and utilizes permanent solutions. In addition, the selected remedy uses
proven cleanup technologies including ISCO treatment of groundwater and sequestration of contaminants
using activated carbon. The selected remedy is also generally cost effective while achieving the site-
specific remedial action objectives and cleanup levels in a reasonable timeframe and has fewer impacts to
the community.
For these reasons, EPA believes that the selected remedy for OU2, Alternative 4, achieves the best overall
balance among the nine evaluation criteria required by the NCP. However, although the technologies in
Alternative 4 have been demonstrated to be effective at the full-scale level individually, a treatability
study is underway to determine if they are likely to be effective for in situ sequential treatment of COCs
in groundwater at the L&RR Site. Because additional bench and pilot testing of this approach is still
required. EPA has also identified a contingency remedy. Alternative 3, which best meets the NCP criteria
if it is determined that Alternative 4 will not be able to reduce COC levels downgradient of the treatment
area and throughout the Site to below cleanup levels within a reasonable timeframe.
If, after reviewing the treatability study results, pilot test results, or other data collected during the design
phase, EPA, after consultation with RIDEM, determines that the selected remedy will not be effective in
attaining cleanup levels identified for the Site, and no longer achieves the best balance among EPA's
required evaluation criteria, EPA will provide notice to the public of its intention to implement its
contingency remedy. Specific performance criteria that will be used to assess the results of the treatability
study can be found in the July 2020 Treatability Study Specific Aims and Performance Goals
Memorandum.
EPA's contingency remedy, Alternative 3, also provides both short-term and long-term protection of
human health and the environment, attains applicable federal environmental and more stringent state
environmental laws and regulations, reduces the toxicity, mobility, and volume of contaminants through
treatment to the extent practicable, and utilizes permanent solutions. In addition, the contingency remedy
uses proven cleanup technologies including groundwater extraction and treatment. The contingency
remedy is also generally cost effective while achieving the site-specific remedial action objectives and
cleanup levels in a reasonable timeframe.
Description of Remedial Components
The Selected Remedy: Alternative 4: Two-Stage Reactive Treatment Zone, Institutional
Controls, and Monitoring
The selected remedy for OU2 is consistent with EPA's preferred alternatives outlined in the July 2020
Proposed Plan. Figure 4-2 in Appendix C of this ROD depicts the general components and target
treatment areas of the selected remedy.
The selected remedy is an in situ groundwater treatment strategy which includes two technologies that
will be used together in a two-stage reactive treatment zone to address Site COCs. The two technologies
include: (i) ISCO with a combination of sodium persulfate and potassium persulfate, a slow-release form
of chemical oxidant, to address CVOCs, 1,4-dioxane, and some PFAS (notably PFCAs); and (ii)
sequestration/stabilization with injectable AC for PFAS that are not susceptible to ISCO, primarily
PFSAs associated with the sulfonic acid/sulfonate sub-group. If appropriate, other oxidants or
amendments may also be considered. The application of these two technologies in succession has not
been performed at other sites; however, both technologies have been successfully implemented at the full-
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scale level independently. A treatability study is currently underway to evaluate the viability of this
alternative for Site specific conditions and to optimize system design. Refer to the Treatability Study
Work Plan for ISCO and AC in Appendix E of the June 2020 FS for more information on the Treatability
Study.
The components of the selected remedy include pre-design investigations; bench and pilot testing; in situ
treatment and sequestration via ISCO and AC injections; institutional controls; long term monitoring of
groundwater and surface water to evaluate contaminant status and migration; and a review of Site
conditions and risks every five years. The following is a detailed description of the components of the
selected remedy.
Pre-Design Investigation (PDI):
Pre-design investigations (PDI) will be conducted to refine the extent of horizontal and vertical impacts in
the vicinity of the proposed footprint of the two-stage reactive zone, as well as to better understand
contrasts in overburden permeabilities. PDIs will also include additional studies to further evaluate
potential human health risks through the fish consumption pathway. Additionally, the potential for metals
mobilization will be evaluated as part of pre-design bench- and pilot-scale activities and the remedial
design will include measures to reduce or eliminate the potential for mobilization of metals beyond the
treatment zones.
Treatabilitv/Pilot Testing
Treatability testing is currently under way and results will be used to determine the effectiveness of the
proposed technologies to treat Site-specific conditions. Treatability testing results will be used to design
the pilot test and for the full-scale remedial design. Pilot testing will be performed to provide additional
information on injection volumes, radius of influence, field-scale solubility/longevity of the reagents, and
the Site-specific method(s) for injection. The work plan for the treatability study is provided in Appendix
E of the June 2020 FS.
ISCO Treatment Zone:
It is expected that a combination of potassium persulfate and sodium persulfate will be used to treat the
contaminant mass and non-target oxidant demand, respectively. An iron activator will also be used to
facilitate oxidative processes. The conceptual design includes approximately 100 injection points spaced
on 15-foot centers in two rows in an approximately 920-linear foot array. While the specifics will be
determined during remedial design, it is anticipated that injections will be completed using direct push
technology (DPT) in 1-foot intervals from 5 feet to up to approximately 80 feet bgs, depending on the
depth to the top of bedrock. Potassium persulfate will be injected at a rate of approximately 50 pounds per
linear foot in a 20 to 35 percent solid slurry by weight. Sodium persulfate and the iron activator will be
injected in an amount equal to approximately 10 percent by weight of the potassium persulfate injected.
Full-scale amendment delivery will be designed to distribute additional reagent at the deep overburden
and upper bedrock interface for treatment of contaminants in bedrock using prevailing vertical flow
gradients. It has been assumed that to target the bedrock interval, two-times the potassium persulfate
volume will be injected in the last 5-feet at each location. Amendment distribution will occur via
downward groundwater flow gradients from the upper kame delta deposits to the lower ice contact unit.
Low levels of contaminants in groundwater at the overburden-bedrock interface will benefit from
enhanced reagent contact times as delivered reagents will persist for longer periods due to reduced
vertical flow gradients within these zones.
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Approximately 225,000 pounds of potassium persulfate will be injected during the first year. Additional
injections will be completed based on performance monitoring results and the frequency of reinjection
will be a function of field-scale solubility (that is, based on depletion) of the reagents and groundwater
flux. The conceptual design conservatively includes three additional injections in the first 10 years, two
additional injections in years 10 through 20, and one additional injection in years 20 through 30.
Metals are not specifically addressed by these technologies; however, metals are expected to become less
mobile in the subsurface as groundwater shifts towards prevailing oxidizing conditions following
persulfate injections.
Concentrations of the remaining COCs (1,4-dioxane, chlorinated VOCs, and metals) beyond the treatment
zones are expected to continue to decrease following implementation of the remedial activities through
natural processes including biodegradation (CVOCs), advection, dispersion, sorption, and groundwater
recharge.
ISCO Injections:
Additional targeted ISCO injections will be done in areas downgradient of the persulfate barrier where
concentrations of 1,4-dioxane remain elevated above cleanup levels. It has been assumed that injections
would be done in a grid pattern using a 7.5-foot radius of influence.
AC Injections:
The AC barrier would be installed downgradient from locations where PFAS concentrations exceed
cleanup levels. The conceptual design includes a 750-foot activated carbon barrier extending 5 to 60 feet
bgs. The AC is expected to be injected at 150 locations using direct push technology (DPT). A higher
volume of AC will be injected at the deep overburden/bedrock interface to allow for additional
sequestration of COCs in bedrock. Approximately 100,000 pounds of media or 350,000 gallons of slurry
would be injected. The barrier is expected to be effective for an extended period of time and should not
need to be replaced.
Wetland Restoration:
In situ treatment zones are likely to be constructed within a small portion of floodplain or wetland
because groundwater impacts extend below the wetlands adjacent to Trout Brook. The estimated
temporary disturbance to the forested wetland is approximately 2,600 square feet. Temporary impacts to
the 100-year floodplain involve an approximate 8,600 square foot area, with no permanent compensatory
storage loss or impacts to the 500-year floodplain. Alternatives to avoid wetland disturbance were
considered, such as abrupt termination of the ISCO treatment zone south of the wetland, however this
would result in incomplete treatment of groundwater east of the MW-102 well cluster. The remedy will
be designed to minimize wetland impacts consistent with ARARs and will use best management practices
for working in the vicinity of wetlands (e.g., haybales/silt fencing, temporary mats, and low-ground
pressure construction equipment). A wetlands mitigation and restoration plan will be developed for the
selected remedy as part of pre-design activities.
Monitoring:
Long-term monitoring will include:
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• Ongoing monitoring conducted under the Post-Closure Site Monitoring (PCSM) Program, which
consists of annual monitoring activities at seven existing monitoring wells and six surface water
locations;
• Continued semi-annual monitoring of nearby residential wells on Pound Hill Road;
• Continued monitoring wells recently installed as part of OU 2 RI activities;
• Installation and sampling additional wells intended to enhance the Site-wide netw ork for the
potential future evaluation of natural attenuation processes; and
• Installation and sampling of three transects of monitoring wells to evaluate remedy performance,
including a transect upgradient of the ISCO injections, between the two stages, and downgradient
of the AC zone.
Long-term performance monitoring will include monitoring the COCs, degradation byproducts, and
general physical and chemical parameters that may impact treatment performance. Additionally, during
the injection process, water levels and oxidant dispersion will be monitored from surrounding new and
existing wells. The specific monitoring program will be outlined in project plans to be developed during
remedial design. Monitoring locations, frequency, and analyses may be adjusted overtime.
Institutional Controls:
Institutional controls will be implemented to restrict groundwater use in all areas necessary to control
exposure to Site related contaminants including areas described in the 1997 Settlement Agreement and
Consent Decree that require groundwater use restrictions outside the landfill boundary. Institutional
controls may also be necessary for the protection of the selected remedy including limitations on uses and
activities that could interfere with or disturb components of the remedy. Institutional controls to restrict
fish consumption may also be implemented if determined to be warranted based on future evaluation of
potential human health risk from fish consumption. The details of the institutional controls will be
resolved during the pre-design and remedial design phase in coordination with the parties performing the
Remedial Action, impacted landowners, local officials, and RIDEM. Institutional controls are expected to
be in the form of Environmental Land Use Restrictions (ELURs) but may also be implemented through
measures that include, but are not limited to, other proprietary controls or a local town ordinance.
Institutional controls may also include a prohibition of certain uses (e.g., future drinking water wells) or
require pre-treatment of water (engineering control) prior to use. Institutional controls are also necessary
to require vapor intrusion assessment and/or vapor barrier for new building construction in areas where
Site related groundwater contamination is present.
Five-Year Reviews
At the conclusion of remedy construction, hazardous substances, pollutants, or contaminants associated
with OU2 will remain in place. Therefore, as required by law, EPA will review the OU2 remedy/remedies
to ensure that the remedial action(s) are protective of human health and the environment at least once
every five years. These five-year reviews will evaluate the components of the remedy for as long as
contaminated media remain in place above levels that would allow for unlimited use and unrestricted
exposure. The purpose of the five-year review is to evaluate the implementation and performance of a
Site remedy or remedies to determine if the remedy is, or the remedies are, protective of human health
and the environment. The five-year review will document recommendations and follow-up actions as
necessary to ensure long-term protectiveness of a remedy, or to bring about protectiveness of a remedy
that is not protective. These recommendations could include providing additional response actions,
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improving O&M activities, optimizing the remedy, enforcing access controls and institutional controls,
and/or conducting additional studies and investigations.
The Contingency Remedy: Alternative 3: Groundwater Extraction with Ex Situ Treatment,
Institutional Controls, and Monitoring
The contingency remedy for OU2 is consistent with EPA's contingency alternative outlined in the July
2020 Proposed Plan. Figure 4-1 in Appendix C of this ROD depicts the general components and target
treatment areas of the contingency remedy.
The components of the contingency remedy include pre-design investigations; pilot testing; treatment
system design, construction, and operation and maintenance; institutional controls; long-term monitoring
of groundwater and surface water to evaluate contaminant status and migration; and a review of Site
conditions and risks every five years. The following is a detailed description of the components of the
contingency remedy.
Pre-Design Investigation (PDI):
Pre-design investigations will include additional groundwater investigations to determine optimal well
placement, as well as pumping tests to determine necessary pumping rates and extraction wells depths.
Additionally, infiltration tests and hydraulic modeling will be utilized to support the design of the
infiltration basin. PDIs will also include additional studies to further evaluate potential human health risks
through the fish consumption pathway.
Treatabilitv/Pilot Testing:
Treatability and pilot testing will be used to optimize treatment components and finalize treatment design
based on the results from pre-design studies.
Extraction System:
The groundwater extraction system will consist of a series of extraction wells designed and located (based
on pre-design studies) to hydraulically capture impacted portions of the aquifer while minimizing
extraction of uncontaminated groundwater and pumping-induced impacts to the wetlands. Large diameter
extraction wells (i.e., greater than 6-inches) will be constructed with long screens throughout the
overburden unit. Extraction wells will be located such that areas where exceedances of PFAS cleanup
levels were reported in the shallow fracture zone, will be within the radius of influence. Dissolved PFAS
in overburden will be removed by extraction wells which will reduce the potential for flux into bedrock.
PFAS exceeding cleanup levels in shallow bedrock will be contained, and bedrock impacts will be
reduced as a result of strengthened upward flow gradients. The extraction system would also include
pumps, electronic controls, and a network of underground pipes that would convey extracted groundwater
to a central treatment location (the treatment plant).
Infiltration Basins:
After extracted groundwater goes through the treatment system, the water will be piped to infiltration
basins. The infiltration basins allow the treated groundwater to slowly seep into the subsurface. The
proposed infiltration basin location is upgradient of the landfill. The location was selected based on site
constraints including available space, proximity to the wetlands, and land ownership. Groundwater
modeling will be used during the design phase to evaluate optimal basin location and confirm that the
extraction well network and treatment system are capable of managing additional contaminant loading
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resulting from groundwater recirculation and flushing. If it is determined that the use of an infiltration
basin is not implementable, other treated water discharge methods may be considered and used.
Treatment Plant:
The treatment system is expected to occupy an approximate 60 by 60 square foot footprint on the
property. The proposed treatment plant location was selected based on proximity to the existing landfill
gas treatment system, proximity to power, and minimal land preparation requirements. Contaminated
groundwater that is extracted will be treated by a treatment train that consists of a series of processes that
are applicable to the target contaminants that are being removed. The specific treatment unit operations
will be determined if/when such a contingency remedy is designed. Conceptually, the pre-treatment
elements will focus on metals and suspended solids removal and will consist of an equalization tank to
control flow into the treatment system, followed by flocculation and separation steps, a particle filtration
system, and neutralization. These pre-treatment processes will be followed by contaminant-specific
treatment processes including advanced oxidation (AO) for 1,4-dioxane treatment and granular activated
carbon (GAC) treatment for PFAS removal.
Operation and Maintenance of the Treatment System:
O&M will include monitoring to evaluate extraction pump operational rates, in-well drawdown and
overall hydraulic capture, and extraction well and treatment components operation and performance.
Equipment replacement and repair will be completed in accordance with an O&M plan.
Wetland Restoration:
The construction of the conveyance piping for the treatment system will likely occur within a small
portion of floodplain and wetland because groundwater impacts extend below the wetlands adjacent to
Trout Brook. The estimated temporary disturbance to the forested wetland is approximately 1,600 square
feet. Temporary impacts to the 100-year floodplain are similar in scale and involve an approximate 1,800
square foot area, with no permanent compensatory storage loss or impacts to the 500-year floodplain.
Alternatives to avoid wetland disturbance were considered, such as trenching on the western side of the
electric and natural gas lines and horizontal drilling, however the equipment, costs, and necessary
approvals for these options were deemed disproportional relative to the small extent of wetland to be
disturbed. The remedy will be designed to minimize wetland impacts consistent with ARARs and use best
management practices for working in the vicinity of wetlands (e.g., haybales/silt fencing, temporary mats,
and low-ground pressure construction equipment). A wetlands mitigation and restoration plan will be
developed for the selected remedy as part of pre-design activities.
Monitoring:
Long-term monitoring will include:
• Ongoing monitoring conducted under the Post-Closure Site Monitoring (PCSM) Program, which
consists of annual monitoring activities at seven existing monitoring wells and six surface water
locations;
• Continued semi-annual monitoring of nearby residential wells on Pound Hill Road;
• Continued monitoring wells recently installed as part of OU 2 RI activities;
• Installation and sampling additional wells intended to enhance the Site-wide netw ork for the
potential future evaluation of natural attenuation processes; and
• Installation and sampling additional performance monitoring wells and the extraction wells.
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Long-term performance monitoring would include monitoring the COCs, degradation byproducts, and
general physical and chemical parameters that may impact treatment performance. Additionally,
treatment system influent and effluent will be monitored monthly to evaluate system performance. The
specific monitoring program will be outlined in project plans to be developed during remedial design.
Monitoring locations, frequency, and analyses may be adjusted overtime.
Institutional Controls:
Institutional controls will be implemented to restrict groundwater use in all areas necessary to control
exposure to Site related contaminants including areas described in the 1997 Settlement Agreement and
Consent Decree that require groundwater use restrictions outside the landfill boundary. Institutional
controls may also be necessary for the protection of the selected remedy including limitations on uses and
activities that could interfere with or disturb components of the remedy. Institutional controls to restrict
fish consumption may also be implemented if determined to be warranted based on future evaluation of
potential human health risk from fish consumption. The details of the institutional controls will be
resolved during the pre-design and remedial design phase in coordination with the parties performing the
Remedial Action, impacted landowners, local officials, and RIDEM. Institutional controls are expected to
be in the form of Environmental Land Use Restrictions (ELURs) but may also be implemented through
measures that include, but are not limited to, other proprietary controls or a local town ordinance.
Institutional controls may also include a prohibition of certain uses (e.g., future drinking water wells) or
require pre-treatment of water (engineering control) prior to use. Institutional controls are also necessary
to require vapor intrusion assessment and/or vapor barrier for new building construction in areas where
Site related groundwater contamination is present.
Five-Year Reviews
At the conclusion of remedy construction, hazardous substances, pollutants, or contaminants associated
with OU2 will remain in place. Therefore, as required by law, EPA will review the OU2 remedy/remedies
to ensure that the remedial action(s) are protective of human health and the environment at least once
every five years. These five-year reviews will evaluate the components of the remedy for as long as
contaminated media remain in place above levels that would allow for unlimited use and unrestricted
exposure. The purpose of the five-year review is to evaluate the implementation and performance of a
Site remedy or remedies to determine if the remedy is, or the remedies are, protective of human health
and the environment. The five-year review will document recommendations and follow-up actions as
necessary to ensure long-term protectiveness of a remedy, or to bring about protectiveness of a remedy
that is not protective. These recommendations could include providing additional response actions,
improving O&M activities, optimizing the remedy, enforcing access controls and institutional controls,
and/or conducting additional studies and investigations.
Remedy Modifications
The selected remedy may change somewhat as a result of the remedial design, results of the PDIs,
additional groundwater monitoring, and/or construction processes. Any changes to the remedy described
in this ROD would be documented using a technical memorandum in the Administrative Record, an
Explanation of Significant Differences (ESD), or ROD amendment, as appropriate.
Summary of the Estimated Remedy Costs
SECTION L: THE SELECTED REMEDY
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The estimated total cost of the selected remedy is approximately $11.7 million. The estimated total cost of
the contingency remedy is approximately $14.6 million. A summary table of the major capital
construction and annual O&M cost elements for the selected remedy and the contingency remedy are
shown on the following pages. Detailed tables for the selected remedy and the contingency remedy are
presented in Tables L-2 and L-3 of Appendix B. The discount rate used for calculating total present
worth costs was 7%. The timeframe, estimated in the June 2020 FS report, over which cost expenditures
are calculated is 30 years.
Changes in the cost elements may occur as a result of new information and data collected during the
remedial design or PDIs. Changes may be documented in the form of a memorandum in the
Administrative Record file, an ESD, or a ROD amendment, as appropriate. This is an order-of-magnitude
engineering cost estimate that is expected to be within -30 to +50 percent of the actual project cost.
SECTION L: THE SELECTED REMEDY
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Selected Remedy Cost Table
Alternative 4: Two-Stage Reactive Treatment Zone, Institutional Controls, and Monitoring
CAPITAL COSTS
Construction Activities
Pre-Design Investigation
$
140,000
Pilot Testing
$
300,000
Two-Stage Reactive Barrier
$
3,462,000
New Well Installation
$
301,000
Institutional Controls
$
65,000
SUBTOTAL-TWO-STAGE TREATMENT ZONE, ICs
$
4,268,000
Contingency (20%)
$
853,600
TOTAL TWO-STAGE TREATMENT ZONE + ICs
$
5,122,000
Professional/Technical Services
Project Management
$
256,100
Remedial Design
$
409,800
Construction Management
$
307,400
Health and Safety
$
76,900
Legal
$
50,000
Permitting
$
25,000
TOTAL PROFESSIONAL/TECHNICAL SERVICES
$
1,126,000
TOTAL CAPITAL COSTS
$
6,250,000
ANNUAL OPERATION, MAINTENANCE, AND MONITORING COSTS
Monitoring (Years 1-10) SUBTOTAL:
$
175,100
Contingency (20%)
$
35,000
TOTAL PRESENT VALUE - MONITORING COSTS (10 Years, Years 1-10)
$
1,476,000
Monitoring (Years 11-30) SUBTOTAL:
$
131,100
Contingency (20%)
$
26,200
TOTAL PRESENT VALUE - MONITORING COSTS (20 Years, Years 11-30)
$
848,000
TOTAL PRESENT VALUE OM&M (PV 7%)
$
2,330,000
PERIODIC COSTS
Five Year Site Reviews
$
44,000
Persulfate Reinjections
$
3,044,000
Well Decommissioning
$
16,000
Update LTM Program
$
2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%)
$
3,110,000
TOTAL PRESENT VALUE (7%)
$
11,700,000
Total Present Value Range (-30 %)
$
8,190,000
Total Present Value Range (+50 %)
$
17,550,000
SECTION L: THE SELECTED REMEDY Page | 42
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Contingency Remedy (Alternative 3) Cost Table
Groundwater Extraction with Ex Situ Treatment, Institutional Controls, and Monitoring
CAPITAL COSTS
Equipment Procurement
$
1,422,400
Construction Activities
Pre-Design Investigation
$
125,000
Bench and Pilot Testing
$
370,000
Site Civil/Structural
$
645,500
Mechanical
$
747,200
Electrical/l&C
$
897,000
Start Up and Commissioning
$
59,000
Indirects and O&P
$
618,300
New Monitoring Well Installation
$
228,000
Institutional Controls
$
65,000
SUBTOTAL - GROUNDWATER EXTRACTION AND TREATMENT, ICs
$
5,177,400
Contingency (20%)
$
1,035,500
TOTAL GROUNDWATER EXTRACTION AND TREATMENT + ICs
$
6,213,000
Professional/Technical Services
Project Management
$
310,700
Remedial Design
$
497,100
Construction Management
$
372,800
Health and Safety
$
93,200
Permitting/Legal
$
93,200
TOTAL PROFESSIONAL/TECHNICAL SERVICES
$
1,367,000
TOTAL CAPITAL COSTS
$
7,580,000
ANNUAL OPERATION, MAINTENANCE, AND MONITORING COSTS
Performance Monitoring (Years 1-10)
$
224,100
Contingency (20%)
$
44,800
TOTAL PRESENT VALUE - MONITORING COSTS (10 Years, Years 1-10)
$
1,888,700
Performance Monitoring (Years 11-30)
$
156,100
Contingency (20%)
$
31,200
TOTAL PRESENT VALUE - MONITORING COSTS (20 Years, Years 11-30)
$
1,008,700
Groundwater Treatment - Operations and Maintenance
$
253,000
Contingency (20%)
$
50,600
TOTAL PV - GWTP O&M COSTS (30 Years, Year 1 through 30)
$
3,767,400
General Site Maintenance
$
13,500
Contingency (20%)
$
2,700
TOTAL PV - SITE MAINTENANCE COSTS (30 Years, Year 1 through 30)
$
201,100
TOTAL PRESENT VALUE OM&M (7%)
$
6,870,000
PERIODIC COSTS
Five Year Site Reviews
$
44,000
Groundwater Performance and Optimization Study
$
23,000
Demobilization of On-site Treatment System
$
33,000
Well Decommissioning
$
16,000
Update Institutional Controls Plan
$
2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%)
$
118,000
TOTAL PRESENT VALUE (7% OM&M, 30 Years) $ 14,600,000
Total Present Value Range (-30 %) $ 10,220,000
Total Present Value Range (+50 %) $ 21,900,000
SECTION L: THE SELECTED REMEDY
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Expected Outcomes of the Selected Remedy
Following implementation, it is expected that both the selected remedy and the contingency remedy (if
implemented) will reduce downgradient COC concentrations to levels that are protective of human health
and the environment within 20 years. After completion of the remedy, groundwater (outside the boundary
of the landfill) will be restored to beneficial reuse and will no longer pose a potential risk to future
residents nor act as a source for surface water contamination in Trout Brook. Trout Brook Pond, or the
associated tributaries.
The effectiveness of the remedy will be determined based upon attainment of the groundwater cleanup
levels (performance standards) outlined in Table L-l in Appendix B of this ROD as well as any
additional site-related COCs added through subsequent decision documents. A monitoring program will
be implemented in order to evaluate remedy performance and progress tow ards attainment of cleanup
levels. The details of the monitoring program will be established during the remedial design phase and
will include preparation of a long-term monitoring plan. Monitoring scope and frequency could change
over time based on technical analysis of the remedy, optimization studies, revised conceptual site model,
or other information, as determined by EPA after reasonable opportunity for review and comment by
RIDEM.
The determination that all cleanup levels have been met will consider historical and current monitoring
data, contaminant distribution, trend analysis, and the appropriateness of the compliance monitoring
program (i.e., locations, frequency of monitoring, sampling parameter). After all groundwater cleanup
levels outlined in Table L-l in Appendix B have been met. as determined by EPA after reasonable
opportunity for review and comment by RIDEM, consistent with Agency guidance and State regulatory
requirements. EPA will perform a risk evaluation which considers additive risk from remaining COCs
considering all potential routes of exposure to document the residual risk based on exposure to
groundwater at the Site. The residual risk evaluation will document the potential risk associated with the
concentrations of the COCs remaining in groundwater at the Site (if detected).
Cleanup Levels
Cleanup levels were developed for the COCs identified in the human health risk assessment. COCs are
the chemicals found at the Site that, based on the results of the risk assessment, were determined to pose
an incremental lifetime cancer risk (ILCR) greater than 1 in 1 million (10~6) or an HI greater than 1. COCs
were identified for exposure areas that posed a cancer risk in excess of an ILCR of 10~4, or an HI greater
than 1.
Groundwater Cleanup Levels
Cleanup levels have been established for groundwater for all COCs identified in the baseline HHRA (for
groundwater used as residential potable water) found to pose an unacceptable risk to human health. These
cleanup levels can be found in Table L-l. For the residential potable water scenarios, the cleanup levels
were selected based on federal Maximum Contaminant Levels (MCLs), RIDEM Groundwater Quality
Rules (RIDEM-GQR), health advisories, or risk-based cleanup goals. For those COCs that do not have a
federal or state ARAR at the time this ROD was developed, a risk-based cleanup level was calculated,
(see Section 2.3, Table 2-4, and Appendix A of the June 2020 FS for cleanup level development). Risk-
based cleanup levels are based on the residential potable water scenarios evaluated in the baseline HHRA
with potential future cumulative cancer risks greater than 10~4 or target organ His greater than 1
considering the ingestion, dermal contact, and inhalation exposure pathways. Cleanup level development
included each chemical with an individual cancer risk above 10~6 or with an HQ above 1. For each of the
SECTION L: THE SELECTED REMEDY
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contaminants, risk-based cleanup levels were calculated using equations and exposure assumptions
presented in the baseline HHRA. Toxicity values used in the calculation of the risk-based cleanup levels
are presented in Section G of this ROD.
M. STATUTORY DETERMINATIONS
The remedial action selected for implementation at the Landfill and Resource Recovery, Inc. (L&RR)
Superfund Site - OU2 is consistent with CERCLA and, to the extent practicable, the NCP. The selected
remedy and the contingency remedy are protective of human health and the environment, will comply
with ARARs, and are cost-effective. In addition, the selected remedy and the contingency remedy utilize
permanent solutions and alternate treatment technologies or resource recovery technologies to the
maximum extent practicable and satisfy the statutory preference for treatment that permanently and
significantly reduces the mobility, toxicity, or volume of hazardous substances as a principal element to
the maximum extent practicable.
1. The Selected and Contingency Remedies are Protective of Human Health and the
Environment
The selected and contingency remedies for OU2 will adequately protect human health and the
environment by eliminating, reducing, or controlling exposures to human receptors through in situ
treatment and sequestration, extraction and ex situ treatment, engineering controls, long-term monitoring,
and institutional controls. The selected and contingency remedies will reduce potential human health risk
levels such that they do not exceed protective ARAR levels, or in the absence of protective ARAR levels,
EPA's target risk range of a total excess lifetime cancer risk of 10"6 to 10"4 and/or a non-cancer Hazard
greater than 1.0.
Implementation of Alternative 4 would prevent continued migration of the majority of the groundwater
contaminant mass to residential receptors through in situ treatment and sequestration. If the contingency
remedy is implemented, Alternative 3 would prevent the flow of contaminated groundwater from the
landfill perimeter into the wetlands and Trout Brook and protect downgradient residential receptors
through hydraulic containment and ex situ treatment of groundwater.
Under either remedy, concentrations of the COCs beyond the hydraulic control or treatment capture zone
are expected to continue to decrease following implementation of upgradient remedial actions through on-
going natural processes including biodegradation (CVOCs), advection, dispersion, sorption, and
groundwater recharge. Both remedies utilize ICs, which will provide further protection from exposure to
contaminated groundwater emanating from the Site until groundwater cleanup levels are achieved. It
should be noted that the groundwater remediation at this Site addresses contaminants related to the Site
only.
2. The Selected and Contingency Remedies Comply with ARARs
Both the selected remedy and the contingency remedy will comply with federal and more stringent state
ARARs identified for OU2. (The OU1 remedy remains subject to the ARARs set forth in the OU1 ROD.)
The selected remedy and the contingency remedy will also incorporate procedures and processes
identified by policies, advisories, criteria, and guidance documents (TBCs). Detailed lists of
ARARs/TBCs for the selected remedy and contingency remedy are included in Appendix D of this ROD.
A discussion of the more significant ARAR issues is included below.
SECTION M: STATUTORY DETERMINATIONS
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Wetlands Impacts
Issuance of the ROD embodies specific ARARs determinations made by EPA, pursuant to federal
regulatory standards. More specifically, as defined by Section 404(b) of the Clean Water Act and
regulations promulgated under the Act at 40 C.F.R. Parts 230, 231, and 33 C.F.R. Parts 320-323, EPA has
determined, with issuance of this ROD, that the selected remedy and contingency remedy are the least
environmentally damaging practicable alternatives for protecting wetland resources. EPA will minimize
potential harm and avoid adverse impacts to wetlands by using best management practices to minimize
harmful impacts on the wetlands, wildlife or their habitat, and by restoring these areas consistent with
federal and state wetlands protection laws. Any wetlands affected by remedial work will be restored with
native vegetation as a wetland area and such restoration will be monitored until the wetland vegetation
becomes re-established. Other mitigation measures will be used to protect wildlife and aquatic life during
remediation and restoration, as necessary. More detail regarding wetland management can be found in the
FS.
In compliance with standards with relevant and appropriate Wetland Protection and Floodplain
Management regulations (44 C.F.R. Part 9), EPA solicited public comment through the Proposed Plan on
the proposed cleanup's impacts on wetland resources within the Proposed Plan. EPA did not receive any
comments regarding wetland issues.
Floodplain Impacts
EPA has also determined that there is no practicable alternative to activities that affect or result in the
occupancy and modification of the 100- and 500-year floodplain, and that the proposed and contingency
cleanups will cause temporary impacts but will not result in the occupancy and modification of
floodplains.
While injections (under the preferred Alternative 4) or trenching for treatment system piping (under
contingency Alternative 3) are proposed for areas of the Site located in the floodplain, only temporary
impacts to the floodplains are anticipated. Best management practices will be used during injections,
which will include erosion control measures, proper regrading, and restoration and monitoring of
impacted areas. More detail regarding floodplain management can be found in the FS.
In compliance with standards with relevant and appropriate Wetland Protection and Floodplain
Management regulations (44 C.F.R. Part 9), EPA solicited public comment through the Proposed Plan on
the proposed cleanup's impacts on floodplains within the Proposed Plan. EPA did not receive any
comments regarding floodplain issues.
3. The Selected and Continency Remedies are Cost-Effective
The estimated present worth cost of the selected remedy is approximately $11.7 million and the estimated
present worth cost of the contingency remedy is approximately $14.6 million.
EPA believes that both the selected remedy and the contingency remedy are cost-effective because each
remedy's costs are proportional to its overall effectiveness (see 40 C.F.R. § 300.430(f)(l)(ii)(D)). This
determination was made by evaluating the overall effectiveness of those alternatives that satisfied the
threshold criteria by assessing three of the five balancing criteria: long-term effectiveness and
permanence; reduction in toxicity, mobility, or volume through treatment; and short-term effectiveness; in
combination. The overall effectiveness of each alternative then was compared to the alternative's cost to
determine cost-effectiveness. The relationship of the overall effectiveness of each of these remedial
SECTION M: STATUTORY DETERMINATIONS
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alternatives was determined to be proportional to its costs and hence represents a reasonable value for the
money to be spent.
4. The Selected and Contingency Remedies Utilize Permanent Solutions and Alternative
Treatment (or Resource Recovery) Technologies to the Maximum Extent Practicable
EPA believes that the selected remedy provides the best balance of trade-offs with respect to the
balancing criteria set out in NCP §300.430(f)(l)(i)(B), such that it represents the maximum extent to
which permanence and treatment can be practicably utilized at this site. This determination was made by
evaluating trade-offs among alternatives with an emphasis on two of the five balancing criteria: long-term
effectiveness and permanence; and the reduction of toxicity, mobility, or volume through treatment. The
preference for source area treatment as a principal element was also considered. The selected remedy
provides the best balance of trade-offs among the alternatives because it utilizes in situ treatment of
contaminated groundwater, permanent in situ sequestration of contaminants, and does not result in any
off-site disposal.
If EPA, after consultation with RIDEM, determines that the selected remedy will not meet performance
standards, then EPA believes that the contingency remedy provides the next best balance of trade-offs
among the alternatives because it utilizes ex situ treatment of contaminated groundwater to achieve a
permanent reduction in the toxicity, mobility, and volume of contaminated groundwater at the Site.
5. The Selected and Contingency Remedies Satisfy the Preference for Treatment as a
Principal Element
The principal element of both the selected and contingency remedies is management of migration. The
selected remedy utilizes in situ groundwater treatment to intercept and treat contaminated groundwater
before it reaches residential receptors and Trout Brook. If implemented, the contingency remedy utilizes
various methods of ex situ treatment to treat groundwater prior to re-infiltration.
6. Five-Year Reviews of the Selected and Continency Remedies are Required
At the conclusion of the OU2 Site remedy implementation, hazardous contaminants will remain at the
Site. Therefore, as required by law, EPA will review the Site remedies to ensure that the remedial actions
continue to protect human health and the environment at least once every five years, as part of the EPA's
five-year reviews for the entire L&RR Site for as long as waste remains above levels that would allow for
unlimited use and unrestricted exposure. These five-year reviews will evaluate the components of the
OU2 Site remedy for as long as contaminated media (i.e., groundwater) remain in place above
groundwater cleanup levels.
N. DOCUMENTATION OF NO SIGNIFICANT CHANGES
EPA issued the L&RR OU2 Proposed Plan for remediation of the Site to the public for review and
comment on July 29, 2020. The Proposed Plan described the alternatives considered and EPA's preferred
alternative for the selected remedy and contingency remedy.
EPA reviewed all written and verbal comments submitted during the public comment period, which
began on July 29, 2020, and ended on August 28, 2020. Based upon a review of the submitted comments,
EPA determined that no significant changes to the selected remedy or contingency remedy, as originally
identified in the July 2020 Proposed Plan, were necessary.
SECTION N: DOCUMENTATION OF NO SIGNIFICANT CHANGES
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O. STATE ROLE
The Rhode Island Department of Environmental Management has reviewed the various alternatives and
has indicated its support for the selected remedy and contingency remedy. The State has also reviewed the
Remedial Investigation, Risk Assessments, and Feasibility Study to determine if the selected remedy and
contingency remedies are in compliance with applicable or relevant and appropriate state environmental
and facility siting laws and regulations. The State of Rhode Island concurs with the selected remedy for
the L&RR Superfund Site. A copy of the declaration of concurrence is attached as Appendix A of this
ROD.
SECTION O: STATE ROLE
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PART 3: THE RESPONSIVENESS SUMMARY
PUBLIC COMMENTS AND EPA RESPONSES
EPA published the notice of availability of the Proposed Plan and Administrative Record through a news
release on July 29, 2020 and released the Proposed Plan to the public on July 29, 2020 by posting a
publicly accessible link on EPA's website at www.epa.gov/superfund/lrr. In addition, postcard
notifications were mailed to residents and businesses located within a one-mile radius of the Site, and
notification letters were sent to potentially responsible parties that participated in previous settlements
related to the Site.
From July 29, 2020 through August 28, 2020, EPA held a thirty-day public comment period to accept
public comments on the alternatives presented in the Feasibility Study and Proposed Plan.
On August 12, 2020, EPA held a virtual public informational meeting, immediately followed by a virtual
Public Hearing, to describe EPA's Proposed Plan and to accept any oral comments. A transcript of this
hearing and the comments received at the hearing are included in the Responsiveness Summary.
One public comment was received during the Public Hearing, and one comment was received in writing
during the public comment period. Comments have been paraphrased below. The full text of the written
and oral comments received during the comment period has been included in the ROD Administrative
Record.
Comments Received at the July 29. 2020 Public Hearing
COMMENT 1:
During the July 29, 2020 Public Hearing, the North Smithfield Town Administrator expressed concern
about the timeline of the remedy due to the lack of other drinking water options for residents near the Site.
The commenter also wants to ensure that if EPA moves forward with Alternative 4 and it does not prove
effective within an appropriate time, that Alternative 3 will be pursued in a reasonable timeline.
EPA RESPONSE 1: EPA understands the need for a timely response to address migration of
contaminated groundwater, and the need to move forward swiftly in order to avoid potential
contamination of existing groundwater drinking wells downgradient of the Site. Following issuance
of this ROD, EPA will issue Special Notice letters inviting potentially responsible parties identified
for the Site to engage in settlement negotiations for the performance of the remedial actions described
in this ROD. Additionally, once available, EPA will review treatability study results for the selected
remedy (Alternative 4) to evaluate its ability to meet performance standards. If EPA determines that
the selected remedy is expected to meet performance standards, EPA will promptly move forward
with the selected remedy. If EPA determines that the selected remedy will not meet performance
standards, EPA will notify the public before promptly moving forward with the contingency remedy.
Comments Received in Writing during the Public Comment Period
COMMENT 2:
One town resident commented that he and other adults in his household were suffering from neurological
issues that he believes may be related to toluene that he believes may be leaching from the L&RR Site to
his residential well.
PART 3: THE RESPONSIVENESS SUMMARY
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The commenter recommended more well testing beyond what has been done already, and asked what
EPA is doing to ensure that development beyond a one-mile radius does not cause contamination to be
drawn off Site into areas that are not being monitored.
EPA RESPONSE 2:
Toluene is not a Contaminant of Concern at the L&RR Superfund Site. During the OU2 Remedial
Investigation, toluene was not detected in overburden groundwater samples; toluene was detected in
14 out of 40 bedrock groundwater samples with detections ranging from 0.9 ug/L to 4.8 ug/L, well
below ARARs including US EPA MCL of 1000 (ig/L, RIDEM Groundwater Quality Rule of 1000
(ig/L, and below the EPA risk-based screening level for drinking water which is 110 (ig/L.
Additionally, the address provided by the resident is southwest of the Site and looks to be associated
with the Tarkiln Brook watershed that flows into the Upper Slatersville Reservoir from the southeast.
The USGS Study for the Cumberland, North Smithfield, and Westerly public-supply well recharge
study included a model which supported the belief that groundwater flow in the vicinity of the L&RR
landfill is distinctly east towards Trout Brook, and Ridge Hill may function as a localized divide -
with groundwater to the east flowing toward Trout Brook and west towards the Brook and Upper
Slatersville Reservoir. Therefore, there is no monitoring to the southwest of the landfill as part of the
L&RR Superfund Site Monitoring Program. There are monitoring wells associated with the Western
Sand and Gravel Site (WS&G Site) that are located southwest of the L&RR Site surrounding the
WS&G Site. Review of site documents for the WS&G Site indicate that groundwater flow in the area
of that Site is distinctly to the northwest, and also away from the residence of the commenter.
Regarding the concern of the plume being drawn off-Site due to development beyond a one-mile
radius: Impacted groundwater exists only on a few parcels in the direct vicinity of the Site. The extent
of this contamination was determined through analysis of groundwater data from a network of wells
throughout the Site, including those both within and beyond the plume, and is continually updated to
reflect the most recent data. The extent of contaminated groundwater at the Site is well defined and
extends only several hundred feet downgradient of the landfill boundary.
Additionally, to mitigate further migration of impacted groundwater due to off-Site groundwater
usage, institutional controls (ICs) will be implemented as part of the remedy to restrict groundwater
use in all areas necessary to control exposure.
Regarding the need for expanded monitoring beyond what has been done: Wells associated with the
OU1 remedy continue to be sampled annually. The monitoring program for the OU2 remedy will also
include monitoring of wells installed as part of OU2 Remedial Investigation activities, monitoring of
new wells intended to enhance the Site-wide network, and monitoring of selected residential drinking
water wells downgradient of the plume. Locations are identified for monitoring wells based upon
continually updated information including recent and historic groundwater data, existing and potential
exposure pathways resulting from known or anticipated development, and groundwater flow
characteristics.
PART 3: THE RESPONSIVENESS SUMMARY
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1-11
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
BOSTON REGION
In the Matter of:
PUBLIC HEARING:
RE: PROPOSED REMEDY FOR L&RR SUPERFUND SITE
IN NORTH SMITHFIELD, RHODE ISLAND
Via Skype
Wednesday
August 12, 2 02 0
The above entitled matter came on for hearing,
pursuant to Notice at 8:15 p.m.
BEFORE:
MELISSA TAYLOR, EPA Section Chief
New Hampshire and Rhode Island Superfund Section
HOSHAIAH BARCZYNSKI, Project Manager
SARAH WHITE, Community Involvement Coordinator
EPA, Region 1
5 Post Office Square, Suite 100
Boston, MA 02109
PART 3: THE RESPONSIVENESS SUMMARY
APEX Reporting
(617) 269-2900
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INDEX
SPEAKERS:
Gary Ezovski
PAGE
7
APEX Reporting
(617) 269-2900
PART 3: THE RESPONSIVENESS SUMMARY Page | 52
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PROCEEDINGS
(7:53 p.m.)
MS. TAYLOR: Good evening. My name is Melissa
Taylor. I am the Chief of the New Hampshire and Rhode
Island Superfund Section in EPA's Region 1 office. I will
be the hearing officer for tonight's hearing on the proposed
remedy for the L&RR Superfund site located in North
Smithfield, Rhode Island.
The purpose of this hearing is to formally accept
oral comments on the proposed plan released to the public on
July 29, 2020. We will not be accepting written comments
during the hearing. You may submit written comments via
fax, e-mail or postal mail to Hoshaiah Barczynski. This
information will be on the how to submit comments slide
which will be provided at the closure of the hearing.
We will not be responding to comments today, but
will respond to them in writing after August 28, 2020, which
is the close of the comment period.
A public information meeting on the plan was held
immediately before the hearing via Skype and telephone.
During that meeting, information concerning the plan was
presented and EPA was available to respond to questions
about the site.
Now, let me describe the format for the hearing.
You just heard Hoshaiah Barczynski, EPA's project manager
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for the site, give a brief overview of the site, various
cleanup alternatives that were evaluated, and EPA's proposed
cleanup plan for the site. And for the record, that
proposal includes in situ treatment of groundwater
contaminants using a two stage reactive treatment zone, land
use restrictions called institutional controls or IC's that
prohibit use of contaminated groundwater until cleanup
levels are met, and also required evaluation of the vapor
intrusion pathway if any construction of buildings is
planned over contaminated groundwater plume in the future.
It also includes a contingency remedy consisting
of groundwater extraction and treatment and an on-site
treatment system that will be implemented if the ongoing
treatability study results show that the proposed remedy
will not be effective in obtaining the desired cleanup
levels of the site. It will include restoration of any
wetland, flood plain habitat altered by the remedial action,
long term groundwater surface water and residential well
monitoring, and periodic reviews, at least every five years,
to assess the protectiveness of the remedy.
The total estimated cost of this proposed remedy
is approximately 11.7 million.
Copies of the proposed plan have been made
available on EPA's L&RR website at
www.EPA.gov/Superfund/LRR, and the link is listed in the
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chat box. Hard copies remain available by request to Sarah
White, EPA's Community Involvement Coordinator.
Those of you on Skype wishing to comment should
indicate your desire to do so by entering I have a comment
in the Skype chat box. Sarah will call on those wishing to
make a comment in the order in which you signed up to speak.
When called on, please un-mute your Skype line,
state your name and address or your affiliation.
After Sarah has gone through the Skype oral
comments, we will take any comments from the phone line.
Please follow the same process for identifying yourself.
Please limit your oral comments to five minutes.
If the extent of your comments will take longer than five
minutes, I ask that you summarize your major points and
provide EPA with a copy of the full text of your comments.
The text, in its entirety, will become part of the hearing
record.
If you have any comments that you wish to add via
telephone at a later date, but before August 28th, EPA has
provided a dedicated voice mailbox you may reach at 617-918-
1910 .
After all comments have been heard, I will close
the formal hearing. If you wish to submit comments, you can
e-mail or fax them to Hoshaiah, or you can mail them to our
Boston office at the address in the proposed plan and on the
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how to submit comment slide which will be provided at the
closure of the hearing. If you have any questions on how to
submit comments after the hearing, please either call or e-
mail Hoshaiah or Sarah.
All oral comments that we receive tonight, and the
comments that we receive during the comment period, will be
addressed in the responsiveness summary and become part of
the administrative record for the site and will be included
with the decision on the remedy for the site.
We will now accept your oral comments. Sarah will
moderate the queue for the oral comments.
MS. WHITE: Thank you, Melissa. Just to reiterate
what Melissa said, if you would like to speak for the
record, please post I have a comment in the chat box.
Starting with those participating via Skype, I will call on
each person in the order received. Please remember to state
your name and affiliation. I will then ask those on the
phone line if they would like to provide comments. Please
remember to un-mute and then re-mute your line after you
have provided comments.
Thank you.
(Pause.)
MS. WHITE: All right. Thus far, no one has
indicated that they would like to comment -- okay. I did
get one person that I'm going to call on that would like to
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comment.
Gary Ezovski. Please un-mute your line to
comment.
MR. EZOVSKI: Yes. Thank you. I am the Town
Administrator. My address is 88 North Main Street in North
Smithfield as well.
Sarah, Hoshaiah, Melissa, I want to say thank you
on behalf of myself and the town for the work that EPA
continues to provide to mitigate the issues that emanate
from this landfill. Your work is impressive and appreciated
in so many ways.
And I thank you also for the meeting that you
arranged for us yesterday to be able to understand what it
was that was going to be presented tonight. It certainly
helped to anticipate the meeting and be ready.
But all of that just puts me back to the same
place I was back in 2018. And as much as we appreciate what
is happening, we also need to recognize the cumbersome
circumstance that you have in managing this process. It
obviously requires a lot of time to pass.
It's my understanding, from reading the documents,
that the first telltale signs of migration of the landfill
for these specific compounds was identified on or about
2012. And it is taken this long to be able to go through
the process, to get buy in by all of the PRP's and to get a
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plan together which still will take time to get in place to
ultimately protect the water resources, the drinking water
resources, for the down gradient residents.
So, my concern, I guess, that I want for the
record is simply to state again how, while we appreciate the
effort, there is concern about the time it takes to be able
to put things in place and the anticipation that, if you go
forward with option 4 and find that it isn't providing a
response in the appropriate time, that option 3 be pursued
in again, a reasonable time line.
It is also abstract, I know, and I'm not trying to
ask for absolute deadlines. I just have to emphasize that
we don't have options for these folks that are near by the
landfill in terms of public water supply. So, the timing of
these responses is of strong concern. And we just hope you
feel that message and it carries on into your work.
The bottom line, thank you. Please keep doing
what you're doing as quickly and efficiently as you possibly
can. Thank you.
MS. WHITE: Thank you, Gary. If anyone else would
like to make a comment, please again, indicate, again, in
the chat feature, I have a comment.
(Pause.)
MS. WHITE: Okay. Seeing no more requests in the
chat, I'm going to turn it over to the phone lines. If
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anyone would like to make a comment, please un-mute your
phone and I will call your number in the order that I see it
un-muted.
Again, please state your name and your affiliation
if you would like to comment.
(Pause.)
MS. WHITE: No one is indicating that they would
like to comment on the phone lines. I'm not seeing any
indication on the chat feature that people would like to
comment.
So, I'm going to turn the hearing back over to
Melissa. Thank you everyone.
MS. TAYLOR: Thank you, Sarah. And thank you to
everybody who participated this evening. Remember that the
public comment period for making comments closes on August
2 8 th.
And then, as you see here, we have a slide for your
information on how to submit comments for any additional
written or oral comments you may have. You can send your
comments via mail to Hoshaiah Barczynski, US EPA Region 1, 5
Post Office Square, mail code SEMD0701, Boston, Mass, 02109,
or to Hoshaiah's direct fax line at 617-918-0336, or e-mail
at barczynski.hoshaiah@EPA.gov. Lastly, you can leave an
oral comment on EPA's voice mailbox at 617-918-1910.
MS. WHITE: Melissa, I'm sorry to interrupt, but
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the fax number I heard you say is different than what is on
the screen. 918-0275.
MS. TAYLOR: I'm sorry. You are right. The fax -
- oh, you're right. Sorry. Yeah. The fax number 617-918-
0275. Apologies for that.
You may stop the recording, Rosa.
If you have not viewed the proposed plan already,
you can find it and other information regarding the L&RR
Superfund site at www.EPA.gov/Superfund/LRR.
Hoshaiah has also prepared a narrated version of the
presentation that is also posted on the L&RR website if you
didn't catch everything in her presentation tonight.
Again, if you have questions on how to make
comments, please contact Hoshaiah or Sarah via e-mail or
phone. If you don't feel like jotting own this information,
or missed anything on the slide, their contact information
is listed on the L&RR website and where to submit comments
is listed in the proposed plan.
Thank you for joining us this evening. This
concludes the public meeting and hearing. Have a nice
night. Thank you.
(Whereupon, the public hearing was concluded at
8:06 p.m.)
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Record of Decision April 2021
CERTIFICATE OF REPORTER AND TRANSCRIBER
This is to certify that the attached proceedings
in the Matter of:
RE: PROPOSED REMEDY FOR L&RR SUPERFUND SITE
IN NORTH SMITHFIELD, RHODE ISLAND
Place: Via Skype
Date: August 18, 2020
were held as herein appears, and that this is the true,
accurate and complete transcript prepared from the notes
and/or recordings taken of the above entitled proceeding.
Maryann Rooney
Reporter
Maryann Rooney
Transcriber
08/12/20
Date
09/22/20
Date
PART 3: THE RESPONSIVENESS SUMMARY
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APPENDICES
Appendix A: RIDEM Letter of Concurrence
Appendix B: Tables
Appendix C: Figures
Appendix D: ARARs Tables
Appendix E: Acronyms and Abbreviations
Appendix F: Treatability Study Specific Aims and Performance Goals Memorandum
(Remedy Contingency Criteria)
Appendix G Administrative Record Index and Guidance Documents
APPENDICES
Page | 62
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Operable Unit 2
Appendix A - Rhode Island Department of Environmental Management Letter of
Concurrence
Page | 63
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Landfill & Resource Recovery
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Record of Decision
April 2021
RHODE ISLAND
Department of Environmental Management
Division ofthe Director
235 Promenade Street, Room 425
Providence, Rhode Island 02908
April 12, 2021
Bryan Olson, Director
U.S. EPA Region 1- New England
Office of Site Remediation and Restoration
5 Post Office Square
Suite 100
Boston, MA 02109
RE: Record of Decision for OU2, Landfill and Resource Recovery, Inc. Superfund Site, Rl
Dear Mr. Olson,
The Office of Land Revitalization and Sustainable Materials Management has conducted a review ofthe Record
of Decision (ROD), dated February 2021, for the Operable Unit 2 ofthe Landfill and Resource Recovery, Inc.
Superfund Site (OU2) located in North Smithfield, Rhode Island. The selected remedial action the United States
Environmental Protection Agency (USEPA) has put forth addresses contaminated groundwater and other
environmental media within OU2.
The selected remedy consists of a two-stage reactive treatment zone, institutional controls, and monitoring. This
remedy is currently undergoing a treatability study to determine its effectiveness as a remedy at this site. If the
results of the treatability study determine this is not an effective remedy, then the contingency remedy of
groundwater extraction with ex situ treatment, institutional controls, and monitoring will be implemented.
The Department of Environmental Management (the Department) has worked with your Agency, other federal
and municipal agencies, and various stakeholders, from the early investigatory stages up through this current
important decision milestone. Based upon this Department's review of this ROD and the results of the remedial
investigation activities conducted to date, we offer our concurrence on this decision. This concurrence is based
upon all aspects ofthe aforementioned ROD being implemented during design, construction, and operation of
the remedy in a timely manner.
The Department wishes to emphasize the following aspects of the ROD:
• One component of the selected remedy encompasses and innovative approach of a two-stage reactive
zone to treat VOCs, 1,4 dioxane and PFAS at the site, with a contingent remedy of traditional
groundwater extraction and ex situ treatment. RIDEM will be involved in this evaluation process;
• We agree with the institutional controls to restrict groundwater use at the site and the additional
evaluation ofthe adjacent streams and ponds;
Telephone 401.222.4700 | www.dem.ri.gov | Rhode Island Relay 711
Appendix A - Rhode Island Department of Environmental Management Letter of Concurrence
Page |
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Landfill & Resource Recovery
Record of Decision
April 2021
Operable Unit 2
• We agree with the continued monitoring program including the adjacent residents for site related
contaminants, including PFAS; and
• It is recognized by the Department that the health and environmental concerns associated with the
emerging contaminant PFAS are dynamic. RIDEM encourages the EPA to be cognizant of any changes,
including, but not limited to, regulatory changes associated with this group of contaminants in order to
ensure that the remedy remains protective of human health and the environment.
The Department also would like to thank you and your staff for coming together and working with us and the
stakeholders to make the necessary enhancements to this ROD. We look forward to continued cooperation
between our agencies throughout this project and appreciate the opportunity to review and concur with this
important ROD.
Sincerely,
Janet Coit Director
cc: Terrence Gray, RIDEM
Leo Hellested, RIDEM
Matthew DeStefano, RIDEM
Paul Kulpa, RIDEM
Kathryn Sarsfield, RIDEM
Hoshaiah Barczynski, USEPA Region I
Telephone 401.222.4700 | www.dem.ri.gov | Rhode Island Relay 711
Appendix A - Rhode Island Department of Environmental Management Letter of Concurrence
Page
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April 2021
Appendix B - Tables
Table K-l: Comparative Analysis of Alternatives
Table L-l: Groundwater Cleanup Levels - Residential Potable Water Scenario
Table L-2: Selected Remedy Detailed Cost Estimate
Table L-3: Contingency Remedy Detailed Cost Estimate
Table G-l: Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration - Current Resident
Table G-2: Summary of Chemical of Concern and Medium-Specific Exposure Point
Concentration - Future Resident
Table G-3: Cancer Toxicity Data Summary
Table G-4: Non-Cancer Toxicity Data Summary
Table G-5: Risk Characterization Summary - Carcinogens - Current Resident -
Residential Groundwater
Table G-6: Risk Characterization Summary - Non-Carcinogens - Current Resident -
Residential Groundwater
Table G-7: Risk Characterization Summary - Carcinogens - Future Resident -
Overburden Groundwater
Table G-8: Risk Characterization Summary - Non-Carcinogens - Future Resident -
Overburden Groundwater
Table G-9: Risk Characterization Summary - Carcinogens - Future Resident -
Bedrock Groundwater
Table G-10: Risk Characterization Summary - Non-Carcinogens - Future Resident -
Bedrock Groundwater
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Table K-l - Comparative Analysis of Alternatives
Evaluation Criteria
Alternative 1:
No Action
Alternative 2:
Limited Action -
Institutional
Controls and
Monitoring
Alternative 3:
Groundwater
Extraction with
Ex Situ
Treatment and
Institutional
Controls
Alternative 4:
Two-Stage
Reactive
Treatment Zone
and Institutional
Controls
Overall Protection of Human Health and the Environment
Overall Protection of Human Health
Fails
Passes
Passes
Passes
Overall Protection of the Environment
NA1
NA'1'
NA'1'
NA1
Compliance with ARARs
Chemical-Specific ARARs
Fails
Fails
Passes
Passes
Location-Specific ARARs
NA
Passes
Passes
Passes
Action-Specific ARARs
NA
Passes
Passes
Passes
Other Criteria, Advisories, and Guidance
Uncertain
Uncertain
Passes
Passes
Long-Term Effectiveness and Permanence
Long-Term Effectiveness and Permanence
•
• •
• ••
• ••
Reduction of Toxicity, Mobility, or Volume through Treatment
Reduction of Toxicity, Mobility, or Volume
through Treatment
•
•
• ••
• ••
Short-Term Effectiveness
Short-Term Effectiveness
•
• •
• •
• •
Implementability
Implementability
• ••
• ••
• •
• ••
Cost
Capital
$0
$315,000
$7,580,000
$6,250,000
Total NPV
$430,000
$2,300,000
$14,600,000
$11,700,000
Overall Cost Rating
• ••
• ••
•
• •
Notes:
(1) The results of the SLERA and Refinement did not identify unacceptable risks to ecological receptors from exposure to
groundwater.
NA - Not applicable
• Low rating in comparison to other alternatives for specified criterion (less favorable outcome for criteria)
• • Mid-range rating in comparison to other alternatives for specified criterion
• • • High rating in comparison to other alternatives for specified criterion (most favorable outcome for criteria
Appendix B - Tables
Page | 67
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Table L-l: Groundwater Cleanup Levels - Residential Potable Water Scenario
Table L-l: Groundwater Cleanup Levels - Residential Potable Water Scenario
Carcinogenic Chemical of Concern
Cancer Classification
Site-Wide Cleanup Level
l-ig/L
Basis
1,1-Dichloroethane
c
2.8
ILCR = 10-6
1,2-Dichloroethane
B2
5
MCL
1,2-Dichloropropane
Li kely
5
MCL
1,4-Dichlorobenzene
Li kely
75
MCL
1,4-Dioxane
Li kely
0.46
ILCR = lO6
Benzene
A
5
MCL
Naphthalene
C
0.17
ILCR = lO6
Tetrachloroethene
Li kely
5
MCL
Trichloroethene
Carcinogenic to humans
5
MCL
Vinyl Chloride
A
2
MCL I1'
bis(2-Ethylhexyl)phthalate
B2
6
MCL
Perfluorooctanoic acid (PFOA)
Suggestive Evidence
0.070
RIDEM-GQR
Arsenic
A
10
MCL ID
Chromium, Hexavalent
Li kely
0.035
ILCR = 106
Non-Carcinogenic Chemical of Concern
Target Endpoint
Site-Wide Cleanup Level
M-g/L
Basis
1,1-Dichloroethane
Kidney
2.8
ILCR = lO6
1,2-Dichloroethane
Kidney/Nervous System
5
MCL
1,2-Dichloropropane
Developmental/Respiratory
5
MCL
1,4-Dichlorobenzene
Liver
75
MCL
1,4-Dioxane
Kidney/Liver/Nervous System/Respiratory
0.46
ILCR = 106
Benzene
Immune System
5
MCL
cis-l,2-Dichloroethene
Kidney
70
MCL
Naphthalene
Whole Body/Nervous System/Respiratory
0.17
ILCR = lO6
Tetrachloroethene
Nervous System
5
MCL
Trichloroethene
Developmental/Immune System
5
MCL
Vinyl Chloride
Liver
2
MCL
bis(2-Ethylhexyl)phthalate
Liver
6
MCL
Perfluorooctanoic acid (PFOA)
Developmental
0.070
RIDEM-GQR
Perfluorooctane sulfonic acid (PFOS)
Developmental
0.070
RIDEM-GQR
Total PFOA+ PFOS
Developmental
0.070
RIDEM-GQR
Antimony
Blood
6
MCL
Arsenic
Skin/Developmental/Cardiovascular/ Nervous
System/Respiratory
10
MCL
Chromium, Hexavalent
Respiratory
0.035
ILCR = lO6
Iron
Gastrointestinal
14000
HQ = 1
Manganese
Nervous System
300
Health Advisory
Key:
(1) The risk associated with the MCLs for arsenic and vinyl chloride fall outside (above) the Superfiind risk range; however, EPA has determined that MCLs
are protective values for drinking water.
Health Advisory - Health Advisory on Manganese (EPA-822-R-04-003; January 2004)
HI - Hazard Index
MCL - federal Maximum Contaminant Level (The Rhode Island MCLs are equal to the federal MCLs for the applicable Site COCs)
ILCR - Incremental Lifetime Cancer Risk; 10-6 = 1 in 1,000,000
NA - Not available or not applicable
RIDEM-GQR - Groundwater Quality Rules, RIDEM Office of Water Resources (250-RICR-150-05-3, effective 1/09/2019)
Cancer Classification:
A: Human carcinogen
B1: Probable human carcinogen - Indicates that limited human data are available
B2: Probable human carcinogen - indicates sufficient evidence in animals and inadequate or no evidence in humans
C: Possible human carcinogen
D: Not classifiable as a human carcinogen
E: Evidence of noncarcinogenicity
Appendix B - Tables
Page | 68
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April 2021
Table L-2: Selected Remedy Detailed Cost Estimate
Alternative 4: Two-Stage Reactive Treatment Zone, Institutional Controls, and Monitoring
COST SUMMARY
CAPITAL COSTS
Construction Activities
Pre-Design Investigation
Pilot Testing
Two-Stage Reactive Barrier
New Well Installation
Institutional Controls
SUBTOTAL - TWO-STAGE TREATMENT ZONE, ICs
Contingency (20%)
TOTAL TWO-STAGE TREATMENT ZONE + ICs
$
$
$
$
$
$
$
$
140,000
300,000
3,462,000
301,000
65,000
4,268,000
853,600
5,122,000
Professional/ Technical Services
Project Management
Remedial Design
Construction Management
Health and Safety
Legal
Permitting
TOTAL PROFESSIONAL/TECHNICAL SERVICES
$
$
$
$
$
$
$
256,100
409,800
307,400
76,900
50,000
25,000
1,126,000
TOTAL CAPITAL COSTS
$
6,250,000
ANNUAL OPERATION. MAINTENANCE. AND MONITORING COSTS
Monitoring (Yrs 1-10) SUBTOTAL:
Contingency (20%)
TOTAL PRESENT VALUE - MONITORING COSTS (10 Years, Years 1-10)
$
$
$
175,100
35,000
1,476,000
Monitoring (Yrs 11-30) SUBTOTAL:
Contingency (20%)
TOTAL PRESENT VALUE - MONITORING COSTS (20 Years, Years 11-30)
$
$
$
131,100
26,200
848,000
TOTAL PRESENT VALUE OM&M (PV 7%)
$
2,330,000
PERIODIC COSTS
Five Year Site Reviews
Persulfate Reinjections
Well Decommissioning
Update LTM Program
$
$
$
$
44,000
3,044,000
16,000
2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%)
$
3,110,000
TOTAL PRESENT VALUE (7%)
$
11,700,000
Total Present Value Range (-30 %) $ 8,190,000
Total Present Value Range (->50 %) $ 17,550,000
Appendix B - Tables
Page | 69
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Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Table L-2: Selected Remedy Detailed Cost Estimate (continued)
CAPITAL COSTS
QTY
UNIT
UNIT COST
TOTAL NOTES
Construction Activities
Pre-Design Investigation
HPT Investigation
1
LS
$ 73,000
$
73,000 Cascade Quote - 4 locations to 70 feet
Analytical Costs
16
EA
$ 408
$
7,000 1,4-dioxane, VOCs, PFAS
Oversight
1
LS
$ 25,000
$
25,000
Groundwater Model
1
LS
$ 35,000
$
35,000
SUBTOTAL:
$
140,000
Pilot Testing
Pilot Study
1
LS
$ 300,000
$
300,000
SUBTOTAL:
$
300,000
Two-Stage Reactive Barrier
Potassium Persulfate
210,164
lb
$ 1.50
$
315 300 Peroxy(-'hem cluote (scaled to 920 feet, additional
ammedments at bedrock interface)
Sodium Persulfate
76,038
lb
$ 1.41
$
107,300 PeroxyChem quote (scaled to 920 feet)
Pyrite Activator
21,016
lb
$ 1.00
$
22,000 10% of potassium persulfate
Amendment Shipping
1
LS
$ 5,000
$
5,000
DPT Injections
1
LS
$ 371,500
$
371,500 Cascade Quote (scaled to 920 feet)
ISCO Injections at MW-303 and MW-302
2,160
LF
$ 446
$
963,900 Calculated cost/ linear foot
Powdered Activated Carbon Injections
1
LS
$ 1,577,200
$
Regenesis Quote (750 feet, additional
I ,Ut l ,^UU . . . . . 1 • 1 r \
ammedments at bedrock interface)
Oversight Labor
40
day
$ 1,500
$
60,000 40 days of oversight
Wetland Restoration
1
LS
$ 40,000
$
40,000 Allowance for wetland restoration
SUBTOTAL:
$
3,462,000
New Well Installation
Bedrock Drilling and Geophysical Logging
3
EA
$31,600
$
94,800 previous project costs
Packer Sampling & Analysis
3
EA
$14,700
$
44,100 previous project costs
Bedrock Monitoring Well/System Installation
3
EA
$16,200
$
48,600 previous project costs
Overburden Monitoring Well Installation/Development 6
EA
$17,600
$
105,600 previous project costs
Survey
1
LS
$2,100
$
2,100 previous project costs
Residuals Management
1
LS
$5,400
$
5,400 previous project costs
SUBTOTAL:
$
301,000
Institutional Controls
Institutional Controls Plan
1
LS
$ 15,000
$
15,000
Legal Fees, Deed Restrictions, Property Surveys
2
EA
$ 25,000
$
50,000 2 properties adj. to landfill (Lots 23 and 24)
SUBTOTAL:
$
65,000
SUBTOTAL ¦
¦ TWO-STAGE TREATMENT ZONE, ICs
$
4,268,000
Contingency
20%
$
853,600
TOTAL TWO-STAGE TREATMENT ZONE + ICs
$
5,122,000
Professional/ Technical Services
Project Management
5%
$
256,100 per USACE and USEPA, 2000
Remedial Design
8%
$
409,800
Construction Management
6%
$
307,400
Health and Safety
1.5%
$
76,900
Legal
$
50,000 Access Agreements
Permitting
$
25,000
TOTAL PROFESSIONAL/ TECHNICAL SERVICES
$
1,126,000
TOTAL - CAPITAL COSTS S 6.250.000
Appendix B - Tables
Page | 70
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Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-2: Selected Remedy Detailed Cost Estimate (continued)
OPERATION, MAINTENANCE, AND MONITORING COSTS
QTY UNIT UNIT COST
TOTAL
NOTES
Performance Monitoring (Years 1-10)
see backup for monitoring program assumptions
PCSM Program
1
LS
$ 13,100 $
13,100
LTM Program
1
LS
$ 36,000 $
36,000
Performance Monitoring
2
LS
$ 44,000 $
88,000 2 events/year
Residential Monitoring
1
LS
$ 23,000 $
23,000
Reporting
1
LS
$ 15,000 $
15,000
SUBTOTAL:
$
175,100
Performance Monitoring (Years 11-30)
see backup for monitoring program assumption
PCSM Program
1
LS
$ 13,100 $
13,100
LTM Program
1
LS
$ 36,000 $
36,000
Performance Monitoring
1
LS
$ 44,000 $
44,000 1 event/year
Residential Monitoring
1
LS
$ 23,000 $
23,000
Reporting
1
LS
$ 15,000 $
15,000
SUBTOTAL:
$
131,100
Monitoring (Yrs 1-10) SUBTOTAL:
$
175,100
Contingency (20%)
$
35,000
Monitoring (Yrs 1-10) TOTAL: $
210,100
Monitoring (Yrs 11-30) SUBTOTAL:
$
131,100
Contingency (20%)
$
26,200
Monitoring (Yrs 10-20) TOTAL: $
157,300
101 AL PKbSbN I VALUb - MONIIOKINU COS IS (1 u Years. Years 1 -1 u)—S—1,476,000
IOIAL PRbSbNI VALUb-MONI IOKINU COS IS (20 Years. Years 11-30) S 848,000
TOTAL PRESENT VALUE OM&M (PV 7%)
S 2,330,000
Appendix B - Tables
Page | 71
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-2: Selected Remedy Detailed Cost Estimate (continued)
PERIODIC COSTS
YEAR
QTY
UNIT
UNIT COST
TOTAL
PRESENT
VALUE (7%)
NOTES
Persulfate Reinjections
Potassium Persulfate
3,6,9,14,19,25
6
LS
$ 315,300 :
E 1,892,000
$ 907,000
PeroxyChem quote
Sodium Persulfate
3,6,9,14,19,25
6
LS
$ 107,300 :
E 644,000
$ 309,000
PeroxyChem quote
Pyrite Activator
3,6,9,14,19,25
6
LS
$ 22,000 :
E 132,000
$ 64,000
10% of potassium persulfate
Amendment Shipping
3,6,9,14,19,25
6
LS
$ 5,000 :
E 30,000
$ 15,000
DPT Injections
3,6,9,14,19,25
6
LS
$ 371,500 :
E 2,229,000
$ 1,069,000
Cascade Quote
Oversight Labor
3,6,9,14,19,25
6
LS
$ 60,000 :
E 360,000
$ 173,000
40 days of oversight
Contingency
3,6,9,14,19,25
6
%
$ 176,220 i
E 1,057,400
$ 507,000
20% contingency
Five Year Site Reviews
5,10,15, 20, 25,30
6
LS
$ 20,000 :
E 120,000
$ 44,000
Well Decommissioning
30
1
LS
$ 120,000 :
E 120,000
$ 16,000
Update LTM Program
30
1
LS
$ 15,000 :
E 15,000
$ 2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%) S6.599.400 S3.110.000
Appendix B - Tables
Page | 72
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Table L-3: Contingency Remedy Detailed Cost Estimate
Alternative 3: Groundwater Extraction with Ex Situ Treatment, Institutional Controls, and Monitoring
COST SUMMARY
CAPITAL COSTS
Equipment Procurement $
1,422,400
Construction Activities
Pre-Design Investigation $
125,000
Bench and Pilot Testing $
370,000
Site Civil/Structural $
645,500
Mechanical $
747,200
Electrical/l&C $
897,000
Start Up and Commissioning $
59,000
Indirects and O&P $
618,300
New Monitoring Well Installation $
228,000
Institutional Controls $
65,000
SUBTOTAL - GROUNDWATER EXTRACTION AND TREATMENT, ICs $
5,177,400
Contingency (20%) $
1,035,500
TOTAL GROUNDWATER EXTRACTION AND TREATMENT + ICs $
6,213,000
Professional/Technical Services
Project Management $
310,700
Remedial Design $
497,100
Construction Management $
372,800
Health and Safety $
93,200
Permitting/Legal $
93,200
TOTAL PROFESSIONAL/ TECHNICAL SERVICES $
1,367,000
TOTAL CAPITAL COSTS $
7,580,000
ANNUAL OPERATION, MAINTENANCE, AND MONITORING COSTS
Performance Monitoring (Years 1-10) $
224,100
Contingency (20%) $
44,800
TOTAL PRESENT VALUE - MONITORING COSTS (10 Years, Years 1-10) $
1,888,700
Performance Monitoring (Years 11-30) $
156,100
Contingency (20%) $
31,200
TOTAL PRESENT VALUE - MONITORING COSTS (20 Years, Years 11-30) $
1,008,700
Groundwater Treatment - Operations and Maintenance $
253,000
Contingency (20%) $
50,600
TOTAL PV - GWTP O&M COSTS (30 Years, Year 1 through 30) $
3,767,400
General Site Maintenance $
13,500
Contingency (20%) $
2,700
TOTAL PV - SITE MAINTENANCE COSTS (30 Years, Year 1 through 30) $
201,100
TOTAL PRESENT VALUE OM&M (7%) $
6,870,000
PERIODIC COSTS
Five Year Site Reviews
$ 44,000
Groundwater Performance and Optimization Study
$ 23,000
Demobilization of On-site Treatment System
$ 33,000
Well Decommissioning
$ 16,000
Update Institutional Controls Plan
$ 2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%)
$ 118,000
TOTAL PRESENT VALUE (7% OM&M, 30 Years)
$ 14,600,000
Total Present Value Range (-30%) $ 10,220,000
Total Present Value Range (+50%) $ 21,900,000
Appendix B - Tables
Page | 73
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-3: Contingency Remedy Detailed Cost Estimate (continued)
CAPITAL COSTS
QTY
UNIT
UNIT COST
TOTAL
NOTES
Equipment Procurement
Extraction Well Pumps
4
EACH
$
2,296
$
9,184
Grundfos 25S05 quote
Equalization Tank (5,000 gal HDPE Tank)
1
EACH
$
15,000
$
15,000
HDPE Tank quotes
Equalization Pumps (90 gpm, centrifugal pumps)
2
EACH
$
6,500
$
13,000
Aeration Blowers (20 scfm)
2
EACH
$
5,000
$
10,000
Reaction Tank (1500 gal, HDPE Tank)
2
EACH
$
5,300
$
10,600
HDPE Tank quotes
Reaction Tank Mixer
2
EACH
$
5,660
$
11,320
2 HP Mixer Quote
Metals Removal (Inclined Plate Clarifier)
1
EACH
$
81,100
$
81,100
Vendor Quote - Parkson
Metals Removal (Continuous Backwash Sand Filter)
1
EACH
$
132,000
$
132,000
Vendor Quote - Dynasand
Extraction Well Pumps
1
EACH
$
5,300
$
5,300
HDPE Tank quotes
Neutralization Tank Mixer
1
EACH
$
5,660
$
5,660
2 HP Mixer Quote
Transfer Tank (3000 gal, HDPE Tank)
1
EACH
$
7,500
$
7,500
HDPE Tank quotes
Transfer Pumps (90 gpm, centrifugal pumps)
2
EACH
$
6,500
$
13,000
Advanced Oxidation Process (Hydrogen Peroxide/UV)
1
LS
$
650,000
$
650,000
Vendor Quote-Trojan
PFAS Treatment System (Two LGAC Adsorbers)
1
LS
$
102,000
$
102,000
Vendor Quote - Evoqua
Effluent Tank (10,000 gal FRP Tank)
1
EACH
$
46,450
$
46,450
Vendor Quote - ECS
Effluent Pumps (90 gpm, centrifugal pumps)
2
EACH
$
6,500
$
13,000
Backwash Pumps (400 gpm, centrifugal pumps)
2
EACH
$
10,000
$
20,000
Sludge Holding Tank (10,000 gal, FRP Tank)
1
EACH
$
46,450
$
46,450
Vendor Quote - ECS
Filter Press Feed Pumps
2
EACH
$
5,985
$
11,970
Vendor Quote - Micronics
Filter Press
1
LS
$
63,785
$
63,785
Vendor Quote - Micronics, 20 cubic foot press with 800mm x 800mm
Air Compressor
1
EACH
$
15,000
$
15,000
plates
Chemical Feed Tanks (500 gal, HDPE Tanks with HPDE Containment Basin)
3
EACH
$
8,000
$
24,000
Caustic, Acid, and Hydrogen Peroxide (other chemicals supplied in
totes)
Duplex Chemical Feed Systems
6
EACH
$
17,000
$
102,000
Caustic, Acid, Ferric Chloride, Polymer, Hydrogen Peroxide, and
Sodium Bisulfite
Building Sump Pumps (Submersible)
2
EACH
$
7,000
$
14,000
SUBTOTAL EQUIPMENT PROCUREMENT COST
$
1,422,400
Pre-Design Investigation
HPT Investigation
1
LS
$
73,000
$
73,000
Cascade Quote - 4 locations to 70 feet
Analytical Costs
16
EA
$
408
$
7,000
1,4-dioxane, VOCs, PFAS
Oversight
1
LS
$
10,000
$
10,000
Groundwater Model
1
LS
$
35,000
$
35,000
SUBTOTAL:
$
125,000
Bench and Pilot Testing
Treatability Testing
1
LS
$
20,000
$
20,000
Pump Test
1
LS
$
150,000
$
150,000
Pilot Study
1
LS
$
200,000
$
200,000
SUBTOTAL:
$
370,000
Site Civil/Structural
Mob/ Demobe
1
EACH
$
5,000
$
5,000
Allowance
Extraction Wells - Install and Develop
4
EACH
$
30,000
$
120,000
>6" Diameter PVC with SS Screens drilled via sonic
Infiltration Gallery - Site work and fencing
1
LS
$
50,000
$
50,000
Excavation-Trenching
2400
CY
$
4.68
$
11,232
RS Means 31 2316-13
Excavation - for new building
626
CY
$
17
$
10,852
RS Means 31 2316-16
Backfill & Compaction
3026
CY
$
23
$
69,705
RS Means 31 23 23-13-1900 and 31 23 23-13 0300
Underground Piping (Extraction Lines)
7600
LF
$
2.35
$
17,863
RS Means 2211 13-78
Underground Piping (Injection Line)
1900
LF
$
3.58
$
6,797
RS Means 2211 13-78
Underground Piping (Allowance for Utilities)
1
LS
$
10,000
$
10,000
Grading
2000
SF
$
4.21
$
8,420
RS Means 31 22 16-10; Finish grading around new building
Paving
1200
SF
$
5.38
$
6,452
RS Means 3212 16-14; Paving parking area adjacent to new building
Reinforced Concrete (in place; equipment pads)
67
CY
$
195
$
12,991
RS Means 03 31 13-70
Forms for equipment pads
1800
SF
$
25
$
45,059
RS Means 0311 13-40
Reinforced Concrete (in place; building slab)
133
CY
$
195
$
25,982
RS Means 03 31 13-70 1550 and 03 31 13-35 0520
Structural Steel
10
TON
$
3,500
$
35,000
Allowance for access platforms, pipe rack
Miscellaneous Metals
1
LS
$
15,000
$
15,000
Allowance
Pre-Engineered Bldg.
3600
SF
$
37
$
134,964
RS Means 13 34 19-50
Overhead Door
2
EACH
$
5,071
$
10,142
RS Means 08 33 23-10
Final Clean-up / Housekeeping
1
LS
$
10,000
$
10,000
Allowance to clean-up site
Wetland Restoration
1
LS
$
40,000
$
40,000
Allowance for wetland restoration
SUBTOTAL:
$
645,500
Appendix B - Tables
Page | 74
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-3: Contingency Remedy Detailed Cost Estimate (continued)
CAPITAL COSTS (CONTINUED)
QTY
UNIT
UNIT COST
TOTAL
NOTES
Mechanical
Process Piping and Valve Allowance for Materials and Installation
25%
$
355,600
percent of equipment costs
Bldg. HVAC
3600
SF
20
$
72,000
Bldg. Plumbing
3600
SF
24
$
86,400
Fire protection
3600
SF
6
$
19,800
Equipment installation
SUBTOTAL:
15%
$
$
213,360
747,200
percent of equipment costs
Electrical/l&C
New Electrical Service
1
LS
30,000
$
30,000
allowance based on similar projects
Motor Control Center (MCC)
1
EA
75,000
$
75,000
allowance based on similar projects
Emergency Generator
1
EA
40,000
$
40,000
allowance based on similar projects
Transformer
1
EA
15,000
$
15,000
allowance based on similar projects
Interior Facility Lighting
1
EA
20,000
$
20,000
allowance based on similar projects
Yard Lighting
1
EA
7,500
$
7,500
allowance based on similar projects
Grounding/Lightning Protection
1
EA
12,500
$
12,500
allowance based on similar projects
Building Power
1
EA
15,000
$
15,000
allowance based on similar projects
Main Control Panel
1
EA
60,000
$
60,000
allowance based on similar projects
Extraction Well Control Panel
EA
20,000
$
40,000
allowance based on similar projects
Control Systems Integration
1
EA
125,000
$
125,000
allowance based on similar projects
SCADA System Hardware/Software
1
EA
70,000
$
70,000
allowance based on similar projects
Instruments (analog - FIT)
10
EA
4,000
$
40,000
allowance based on similar projects
Instruments (analog - LIT, pH, Temp, PIT, FIT)
25
EA
1,500
$
37,500
allowance based on similar projects
Instruments (digital switches - LS, XS, SS, PS)
14
EA
500
$
7,000
allowance based on similar projects
Instruments (control valves)
15
EA
3,500
$
52,500
allowance based on similar projects
Instruments (non I/O, PI, Tl)
25
EA
700
$
17,500
allowance based on similar projects
Instrumentation Installation
89
EA
2,500
$
222,500
Wiring, calibration, and loop check
Miscellaneous
1
LS
10,000
$
10,000
Allowance for fire alarm system, security alarm system,
communications
SUBTOTAL:
$
897,000
Start Up and Commissioning
Hydrostatic pressure testing of piping
1
LS
25,000
$
25,000
Commisioning
1
LS
9,000
$
9,000
assumes 1 week
Start up
1
LS
24,400
$
24,400
assumes 3 days/week for first month, 1 day/week for months 2 and 3,
SUBTOTAL:
$
59,000
and start up analytical
Indirects and O&P
Indirect Project Costs
10%
$
229,000
% of civil, mechanical, and electrical
Contractors Overhead
10%
$
229,000
% of civil, mechanical, and electrical
Contractors Profit
7%
$
160,300
% of civil, mechanical, and electrical
SUBTOTAL:
$
618,300
New Monitoring Well Installation
Bedrock Drilling and Geophysical Logging
Packer Sampling & Analysis
3
3
EA
EA
31,600
14,700
$
$
94,800
44,100
previous project costs
previous project costs
Bedrock Monitoring Well/System Installation
3
EA
16,200
$
48,600
previous project costs
Overburden Monitoring Well Installation & Development
4
EA
8,800
$
35,200
previous project costs
Survey
1
LS
2,100
$
2,100
previous project costs
Residuals Management
1
LS
2,700
$
2,700
previous project costs
SUBTOTAL:
$
228,000
Institutional Controls
Institutional Controls Plan
1
LS
15,000
$
15,000
Legal Fees, Deed Restrictions, Property Surveys
2
EA
25,000
$
50,000
2 properties adj. to landfill (Lots 23 and 24)
SUBTOTAL:
$
65,000
SUBTOTAL CONSTRUCTION COST
$
3,755,000
SUBTOTAL - GROUNDWATER EXTRACTION AND TREATMENT, ICs
$
5,177,400
Contingency 20%
$
1,035,500
TOTAL GROUNDWATER EXTRACTION AND TREATMENT + ICs
$
6,213,000
Professional/ Technical Services
Project Management
5%
$
310,700
Remedial Design
8%
$
497,100
Construction Management
6%
$
372,800
Health and Safety
1.5%
$
93,200
Permitting/Legal
1.5%
$
93,200
TOTAL PROFESSIONAL)TECHNICAL SERVICES $ 1,367,000
TOTAL - CAPITAL COSTS $ 7,580,000
Appendix B - Tables
Page | 75
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-3: Contingency Remedy Detailed Cost Estimate (continued)
OPERATION, MAINTENANCE, AND MONITORING COSTS
QTY
UNIT UNIT COST
TOTAL NOTES
Performance Monitoring (Years 1-10)
see backup for monitoring program assumptions
PCSM Program
1
LS $
13,100
$
13,100
LTM Program
1
LS $
37,000
$
37,000 includes data validation and management
Performance Monitoring
2
LS $
43,000
$
86,000 2 events per year
Residential Monitoring
1
LS $
23,000
$
23,000 includes data validation and management
System Influent and Effluent Monitoring
1
LS $
50,000
$
50,000 monthly monitoring
Reporting
1
LS $
15,000
$
15,000
SUBTOTAL:
$
224,100
Performance Monitoring (Years 11-30)
see backup for monitoring program assumptions
PCSM Program
1
LS $
13,100
$
13,100
LTM Program
1
LS $
37,000
$
37,000 includes data validation and management
Performance Monitoring
1
LS $
43,000
$
43,000 annual
Residential Monitoring
1
LS $
23,000
$
23,000 includes data validation and management
System Influent and Effluent Monitoring
1
LS $
25,000
$
25,000 monthly monitoring
Reporting
1
LS $
15,000
$
15,000
SUBTOTAL:
$
156,100
Groundwater Treatment - Operations and Maintenance
Operations Labor
624
mh $
85
$
53,040 operator for 12 hours per week
Equipment Repair/Replacement
1
LS $
24,000
$
24,000 allowance, includes replacing the UV lamps every 5 years
Power
621,332
kWh $
0.11
$
68,347
Utilities
1
LS $
10,000
$
10,000 allowance for plant water, sewer etc.
Chemicals
1
LS $
17,000
$
... allowance for caustic, acid, ferric chloride, polymer, and
17,000 .. ...
Hydrogen Peroxide
1265
gal $
4.10
$
5,186 based on peroxide dose of 10 ppm
Liquid Phase Carbon Changeouts
12,000
lb $
2.50
$
30,000 assume each carbon vessel is changed out once per year
Sludge Disposal
173
CY $
200
$
34,667 30% dry filter cake to landfill
Laboratory Costs
1
LS $
10,000
$
10,000 analytical costs + lab supplies allowance
SUBTOTAL:
$
253,000
General Site Maintenance
Misc. Site Work
1
LS $
10,000
$
10,000 includes RIB maintenance
Snow plowing events
10
EA $
350
$
3,500
SUBTOTAL:
$
13,500
Monitoring (Yrs 1-10) SUBTOTAL:
$
224,100
Contingency (20%)
$
44,800
Monitoring (Yrs 1 -10) TOTAL:
$
268,900
Monitoring (Yrs 11-30) SUBTOTAL:
$
156,100
Contingency (20%)
$
31,200
Monitoring (Yrs 10-20) TOTAL:
$
187,300
Groundwater Treatment O&M SUBTOTAL:
$
253,000
Contingency (20%)
$
50,600
GWTP O&M TOTAL:
$
303,600
General Site Maintenance SUBTOTAL:
$
13,500
Contingency (20%)
$
2,700
Site Maintenance TOTAL:
$
16,200
TOTAL PRESENT VALUE - MONITORING COSTS (10 Years. Years
1-10)
S
1.888.700
TOTAL PRESENT VALUE - MONITORING COSTS (20 Years. Years
11-30)
s
1.008.700
TOTAL PV - GWTP O&M COSTS (30 Years. Year 1 through 30)
s
3.767.400
TOTAL PV - SITE MAINTENANCE COSTS (30
Years. ^
fear 1 through
30)
s
201.100
TOTAL PRESENT VALUE OM&M (7%) S 6.870.000
Appendix B - Tables
Page | 76
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table L-3: Contingency Remedy Detailed Cost Estimate (continued)
PERIODIC COSTS
YEAR
QTY
UNIT
UNIT COST
TOTAL
PRESENT NOTES
VALUE (7%)
Five Year Site Reviews
5,10,15, 20, 25,30
6
LS
$ 20,000
$ 120,000
$ 44,000
Groundwater Performance and Optimization Study
10 and 20
2
LS
$ 30,000
$ 60,000
$ 23,000
Demobilization of On-site Treatment System
30
1
LS
$ 250,000
$ 250,000
$ 33,000
Well Decommissioning
30
1
LS
$ 120,000
$ 120,000
$ 16,000
Update Institutional Controls Plan
30
1
LS
$ 15,000
$ 15,000
$ 2,000
TOTAL PRESENT VALUE PERIODIC COSTS (PV 7%) S565.000 S118.000
Appendix B - Tables
Page | 77
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Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-l: Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration - Current Resident
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Current
Medium: Groundwater
Exposure Medium: Residential Groundwater
Exposure Point
Chemical of
Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Units
Statistical
Measure<1!
Minimum
Maximum
1309 Pound Hill
Naphthalene
8.7E-01
8.7E-01
M-g/L
1/84
8.7E-01
M-g/L
Max
1431 Pound Hill
Chloroform
5.6E-01
6.3E+00
M-g/L
7/84
3.7E+00
M-g/L
95% UCL
Key:
(1) Statistics: Maximum Detected Value (Max); 95% UCL (95% UCL); Arithmetic Mean (Mean)
ug/L - microgram per liter
The table represents the current/future chemical of concern (COC) and exposure point concentration (EPC) for the COCs detected in residential groundwater wells (i.e., the concentration that will be
used to estimate the exposure and risk for the COC in surface water). The table includes the range of concentrations detected for the COCs, as well as the frequency of detection (i.e., the number of
times the chemical was detected in the samples collected at the site), the EPC, and how the EPC was derived. This table indicates that naphthalene is the only COC in the 1309 Pound Hill residential
well and chloroform is the only COC in the 1431 Pound Hill residential well. The 95% UCL on the arithmetic mean was used as the EPC for chloroform, while the maximum detected concentration
was used as the EPC for naphthalene. Note that the minimum and maximum detections and frequency of detection was determined for all residential wells sampled, while the EPC was calculated
specific to the individual residential well
Appendix B - Tables
Page | 78
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April 2021
Table G-2: Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration - Future Resident
Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration
Scenario Timeframe: Future
Medium: Groundwater
Exposure Medium: Groundwater
Exposure Point
Chemical of Concern
Concentration Detected
Units
Frequency of
Detection
Exposure Point
Concentration
Exposure Point
Concentration
Unit
Statistical
Measure !1)
Minimum
Maximum
Overburden
Groundwater
1,1-Dichloroethane
8.4E-01
1.0E+01
M-g/L
22/99
3.4E+00
Mg/L
95% UCL
1,2-Dichloroethane
2.5E-01
2.6E-01
M-g/L
2/99
2.6E-01
Mg/L
Max
1,2-Dichloropropane
9.3E-01
1.1E+00
M-g/L
2/99
1.1E+00
Mg/L
Max
1,4-Dichlorobenzene
4.5E-01
5.6E+00
M-g/L
26/98
1.7E+00
Mg/L
95% UCL
1,4-Dioxane
3.3E-01
4.8E+02
Mg/L
50/99
9.7E+01
Mg/L
95% UCL
Benzene
3.8E-01
2.3E+00
Mg/L
29/99
7.2E-01
Mg/L
95% UCL
cis-l,2-Dichloroethene 3
5.1E-01
7.2E+01
Mg/L
15/99
1.1E+01
Mg/L
95% UCL
Naphthalene
2.4E-01
2.1E+01
Mg/L
5/97
1.3E+00
Mg/L
95% UCL
Trichloroethene
2.3E-01
2.6E+00
Mg/L
16/99
6.0E-01
Mg/L
95% UCL
Vinyl chloride
2.0E-01
1.0E+01
Mg/L
16/99
1.8E+00
Mg/L
95% UCL
bis(2-Ethylhexyl)phthalate 3
6.5E-01
1.2E+01
Mg/L
3/15
3.0E+00
Mg/L
95% UCL
Perfluorooctanoic acid (PFOA)3
1.9E-03
3.1E-01
Mg/L
27/33
1.1E-01
Mg/L
95% UCL
Perfluorooctane sulfonic acid (PFOS)3,4
1.9E-03
1.0E-02
Mg/L
15/33
N/A
N/A
N/A
Antimony3
1.1E+01
1.1E+01
Mg/L
1/58
1.1E+01
Mg/L
Max
Arsenic
2.5E-01
2.0E+03
Mg/L
51/95
1.6E+02
Mg/L
95% UCL
Chromium, Hexavalent2
5.9E-01
2.0E+01
Mg/L
28/58
4.7E+00
Mg/L
95% UCL
Iron
6.5E+00
1.8E+05
Mg/L
35/38
3.7E+04
Mg/L
95% UCL
Manganese
2.0E+00
9.1E+03
Mg/L
27/38
3.5E+03
Mg/L
95% UCL
(continued on next page)
Appendix B - Tables
Page | 79
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April 2021
Table G-2: Summary of Chemical of Concern and Medium-Specific Exposure Point Concentration - Future Resident (continued)
Exposure Point
Chemical of Concern
Concentration Detected
Units
Frequency of
Exposure Point
Exposure Point
Concentration
Unit
Statistical
Minimum
Maximum
Detection
Concentration
Measure !1)
Bedrock
1,1-Dichloroethane
9.5E-01
8.4E+00
M-g/L
18/40
3.8E+00
Mg/L
95% UCL
Groundwater
1,2-Dichloroethane
5.3E-01
1.4E+00
M-g/L
5/40
6.7E-01
Mg/L
95% UCL
1,4-Dioxane
4.1E+00
7.3E+01
M-g/L
18/40
4.4E+01
Mg/L
95% UCL
Benzene
2.3E-01
5.5E-01
M-g/L
9/40
3.0E-01
Mg/L
95% UCL
Tetrachloroethene
5.4E-01
8.6E+00
Mg/L
4/40
1.5E+00
Mg/L
95% UCL
Trichloroethene
2.6E-01
4.9E+00
Mg/L
6/40
1.2E+00
Mg/L
95% UCL
Vinyl chloride
2.1E-01
1.6E+00
Mg/L
5/40
4.8E-01
Mg/L
95% UCL
Perfluorooctanoic acid (PFOA)3
2.0E-03
1.1E-01
Mg/L
10/17
5.7E-02
Mg/L
95% UCL
Perfluorooctane sulfonic acid (PFOS)3,4
2.6E-03
9.5E-03
Mg/L
6/17
N/A
N/A
N/A
Arsenic
6.1E-01
1.1E+02
Mg/L
28/40
2.5E+01
Mg/L
95% UCL
Chromium, Hexavalent2
7.0E-01
1.2E+01
Mg/L
24/40
2.4E+00
Mg/L
95% UCL
Key:
(1) Statistics: Maximum Detected Value (Max); 95% UCL (95% UCL); Arithmetic Mean (Mean)
Multiple results from each on-site monitoring well were treated as discrete samples.
(2) Samples were analyzed for total chromium. As no speciation has yet been performed, all chromium results were assumed to consist of 100% hexavalent chromium
(3) Though not determined to show an actionable risk in the baseline HHRA, this analyte was identified as a potential future risk due to ARAR exceedances
(4) PFOS did not exceed a screening level to become a COPC (and therefore did not have an EPC calculated). However, the ARAR criteria is for a combined sum of PFOA and
PFOS. Therefore, PFOS has been included in this table for completeness
ug/L - microgram per liter
N/A - Not Applicable
COPC - Chemical of Potential Concern
The table represents the future chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs detected in overburden and bedrock groundwater (i.e., the concentrations
that will be used to estimate the exposure and risk for each COC in overburden and bedrock groundwater). The table includes the range of concentrations detected for each COC, as well as the
frequency of detection (i.e., the number of times the chemical was detected in the samples collected), the EPC, and how the EPC was derived. This table indicates that the inorganic chemicals, arsenic,
iron, manganese, and hexavalent chromium, and the organic chemicals, 1,4-dichlorobenzene, 1,1-dichloroethane, 1,4-dioxane, PFOA, and benzene are the most frequently detected COCs in
overburden and bedrock groundwater. The 95% UCL concentration, identified assuming multiple results from each monitoring well were treated as discrete samples, was used as the EPC for each of
the COCs detected in groundwater, except for 1,2-dichloroethane, 1,2-dichloropropane, and antimony in overburden groundwater, for which the maximum detected concentration was used. Note that
the minimum and maximum detections and frequency of detection was determined for all overburden/bedrock results, while the EPC was calculated on a subset of wells within the core of the plume
Appendix B - Tables
Page | 80
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Operable Unit 2
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April 2021
Table G-3: Cancer Toxicity Data Summary
Cancer Toxicity Data Summary
Pathway: ingestion, Dermal
Chemical of
Concern
Oral Cancer
Slope Factor
Dermal Cancer
Slope Factor
Slope Factor
Units
Weight of
Evidence/Cancer
Guideline Description
Source
Date (1)
(MM/DD/YYYY)
1,1-Dichloroethane
5.7E-03
5.7E-03
(mg/kg-day)-1
C
CalEPA
12/13/19
1,2-Dichloroethane
9.1E-02
9.1E-02
(mg/kg-day)-1
B2
IRIS
12/13/19
1,2-Dichloropropane
3.7E-02
3.7E-02
(mg/kg-day)-1
Likely
PPRTV
12/13/19
1,4-Dichlorobenzene
5.4E-03
5.4E-03
(mg/kg-day)-1
Likely
CalEPA
12/13/19
1,4-Dioxane
1.0E-01
1.0E-01
(mg/kg-day)-1
Likely
IRIS
12/13/19
Benzene
5.5E-02
5.5E-02
(mg/kg-day)-1
A
IRIS
12/13/19
Chloroform
3.1E-02
3.1E-02
(mg/kg-day)-1
Likely
CalEPA
12/13/19
Naphthalene
N/A
N/A
(mg/kg-day)-1
C
IRIS
12/13/19
Tetrachloroethene
2.1E-03
2.1E-03
(mg/kg-day)-1
Likely
IRIS
12/13/19
Trichloroethene
4.6E-02
4.6E-02
(mg/kg-day)-1
Carcinogenic to humans
IRIS
12/13/19
Vinyl chloride
7.2E-01
7.2E-01
(mg/kg-day)-1
A
IRIS
12/13/19
Arsenic
1.5E+00
1.5E+00
(mg/kg-day)-1
A
IRIS
12/13/19
Chromium, Hexavalent
5.0E-01
2.0E+01
(mg/kg-day)-1
Likely
CalEPA
12/13/19
Iron
N/A
N/A
(mg/kg-day)"1
Inadequate Evidence
N/A
12/13/19
Manganese
N/A
N/A
(mg/kg-day)-1
D
IRIS
12/13/19
(continued on next page)
Appendix B - Tables
Page | 81
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Landfill & Resource Recovery
Operable Unit 2
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April 2021
Table G-3: Cancer Toxicity Data Summary (continued)
Pathway: Inhalation
Chemical of
Concern
Unit Risk
Units
Inhalation
Cancer Slope
Factor
Units
Weight of
Evidence/Cancer
Guideline Description
Source
Date
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-3: Cancer Toxicity Data Summary (continued)
This table provides the carcinogenic risk information which is relevant to the contaminants of concern in groundwater. At this time, slope factors are not available for the dermal route of exposure.
Thus, the dermal slope factors used in this assessment have been extrapolated from oral values. An adjustment factor is sometimes applied, and is dependent upon how well the chemical is absorbed
via the oral route. Adjustments are particularly important for chemicals with less than 50% absorption via the ingestion route. However, adjustment is not necessary for the chemicals evaluated at this
site, except for hexavalent chromium which has an adjustment factor of 0.025. For the remaining chemicals, the same oral slope factors as presented above were used as the dermal carcinogenic slope
factors for these contaminants. Thirteen of the COCs considered carcinogenic via the inhalation route were determined to be primary risk drivers for at least one exposure pathway evaluated at the
site.
Appendix B - Tables
Page | 83
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Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-4: Non-Cancer Toxicity Data Summary
Non-Cancer Toxicity Data Summary
Pathway: ingestion, Dermal
Chemical of Concern
Chronic/
Subchronic
Oral RfD
Value
Oral RfD
Units
Dermal
RfD
Dermal RfD
Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfD:
Target
Organ
Dates of RfD:
Target Organ'11
(MM/DD/YYYY)
1,1-Dichloroethane
Chronic
2.0E-01
mg/kg-day
2.0E-01
mg/kg-day
Kidney
3000
PPRTV
12/13/19
1,2-Dichloroethane
Chronic
6.0E-03
mg/kg-day
6.0E-03
mg/kg-day
Kidney
10000
PPRTV
12/13/19
1,2-Dichloropropane
Chronic
4.0E-02
mg/kg-day
4.0E-02
mg/kg-day
Developmental
30
PPRTV
12/13/19
1,4-Dichlorobenzene
Chronic
7.0E-02
mg/kg-day
7.0E-02
mg/kg-day
Liver
100
ATSDR
12/13/19
1,4-Dioxane
Chronic
3.0E-02
mg/kg-day
3.0E-02
mg/kg-day
Kidney/Liver
300
IRIS
12/13/19
Benzene
Chronic
4.0E-03
mg/kg-day
4.0E-03
mg/kg-day
Immune System
300
IRIS
12/13/19
Chloroform
Chronic
1.0E-02
mg/kg-day
1.0E-02
mg/kg-day
Liver
1000 / 1
IRIS
12/13/19
Naphthalene
Chronic
2.0E-02
mg/kg-day
2.0E-02
mg/kg-day
Whole Body
3000
IRIS
12/13/19
Tetrachloroethene
Chronic
6.0E-03
mg/kg-day
6.0E-03
mg/kg-day
Nervous System
1000
IRIS
12/13/19
Trichloroethene
Chronic
5.0E-04
mg/kg-day
5.0E-04
mg/kg-day
Developmental/ Immune System
10 to 1000
IRIS
12/13/19
Vinyl chloride
Chronic
3.0E-03
mg/kg-day
3.0E-03
mg/kg-day
Liver
30
IRIS
12/13/19
Arsenic
Chronic
3.0E-04
mg/kg-day
3.0E-04
mg/kg-day
Cardiovascular/ Skin
3
IRIS
12/13/19
Chromium, Hexavalent
Chronic
3.0E-03
mg/kg-day
7.5E-05
mg/kg-day
None
300
IRIS
12/13/19
Iron
Chronic
7.0E-01
mg/kg-day
7.0E-01
mg/kg-day
Gastrointestinal
2
PPRTV
12/13/19
Manganese
Chronic
2.4E-02
mg/kg-day
9.6E-04
mg/kg-day
Nervous System
1
IRIS
12/13/19
(continued on next page)
Appendix B - Tables
Page | 84
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Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-4: Non-Cancer Toxicity Data Summary (continued)
Pathway: Inhalation
Chemical of
Concern
Chronic/
Subchronic
Inhalation
RfC
Inhalation
RfC Units
Inhalation
RfD
Inhalation
RfD Units
Primary Target Organ
Combined
Uncertainty/
Modifying
Factors
Sources of
RfC: RfD:
Target
Organ
Dates
(MM/DD/YYYY)
1,1-Dichloroethane
Chronic
N/A
mg/m3
N/A
N/A
N/A
N/A
N/A
12/13/19
1,2-Dichloroethane
Chronic
7.0E-03
mg/m3
N/A
N/A
Nervous System
3000
PPRTV
12/13/19
1,2-Dichloropropane
Chronic
4.0E-03
mg/m3
N/A
N/A
Respiratory
300
IRIS
12/13/19
1,4-Dichlorobenzene
Chronic
8.0E-01
mg/m3
N/A
N/A
Liver
100
IRIS
12/13/19
1,4-Dioxane
Chronic
3.0E-02
mg/m3
N/A
N/A
Nervous System/ Respiratory
1000
IRIS
12/13/19
Benzene
Chronic
3.0E-02
mg/m3
N/A
N/A
Immune System
300
IRIS
12/13/19
Chloroform
Chronic
9.8E-02
mg/m3
N/A
N/A
Liver
100
ATSDR
12/13/19
Naphthalene
Chronic
3.0E-03
mg/m3
N/A
N/A
Nervous System/ Respiratory
3000
IRIS
12/13/19
Tetrachloroethene
Chronic
4.0E-02
mg/m3
N/A
N/A
Nervous System
1000
IRIS
12/13/19
Trichloroethene
Chronic
2.0E-03
mg/m3
N/A
N/A
Immune System/ Developmental
10 to 1000
IRIS
12/13/19
Vinyl chloride
Chronic
1.0E-01
mg/m3
N/A
N/A
Liver
30
IRIS
12/13/19
Arsenic
Chronic
1.5E-05
mg/m3
N/A
N/A
Developmental/ Cardiovascular/
Nervous System/ Respiratory
30
CalEPA
12/13/19
Chromium, Hexavalent
Chronic
1.0E-04
mg/m3
N/A
N/A
Respiratory
300
IRIS
12/13/19
Iron
Chronic
N/A
mg/m3
N/A
N/A
N/A
N/A
N/A
12/13/19
Manganese
Chronic
5.0E-05
mg/m3
N/A
N/A
Nervous System
1000
IRIS
12/13/19
Key:
(1) Date indicates when source was last reviewed.
N/A - No information available CalEPA - California Environmental Protection Agency, Office of Environmental
IRIS - Integrated Risk Information System, U.S. EPA Health Hazard Assessment
PPRTV - Provisional Peer Reviewed Toxicity Value developed by STSC ATSDR = Agency for Toxic Substances and Disease Registry
HEAST = Health Effects Assessment Summary Tables
This table provides non-carcinogenic risk information which is relevant to the contaminants of concern in groundwater. Fifteen of the COCs have oral toxicity data (or surrogate toxicity data)
indicating their potential for adverse non-carcinogenic health effects in humans. Chronic toxicity data available for the fifteen COCs for oral exposures have been used to develop chronic oral
reference doses (RfDs), provided in this table. The available chronic toxicity data indicate that benzene and trichloroethene affect the immune system, 1,4-dichlorobenzene, 1,4-dioxane, chloroform,
and vinyl chloride affect the liver, 1,1-dichloroethane, 1,2-dichloroethane, and 1,4-dioxane affect the kidney, 1,2-dichloroethane, 1,4-dioxane, naphthalene, tetrachloroethene, arsenic, and manganese
affect the central nervous system, 1,2-dichloropropane, trichloroethene, and arsenic are developmental toxicants, iron affects the gastrointestinal system, naphthalene affects the whole body, 1,2-
dichloropropane, 1,4-dioxane, naphthalene, arsenic, and hexavalent chromium affect the respiratory system, arsenic affects the cardiovascular system, and arsenic affects the skin. Dermal RfDs are not
available for any of the COCs. As was the case for the carcinogenic data, dermal RfDs can be extrapolated from oral RfDs by applying an adjustment factor as appropriate. Oral RfDs were adjusted
for COCs with less than 50% absorption via the ingestion route (hexavalent chromium and manganese) to derive dermal RfDs for these COCs. Inhalation reference concentrations (RfCs) are available
for thirteen COCs evaluated for the inhalation pathway.
Appendix B - Tables
Page | 85
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Operable Unit 2
Record of Decision
April 2021
Table G-5: Risk Characterization Summary - Carcinogens - Current Resident - Residential Groundwater
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External (Radiation)
Exposure
Routes Total
Groundwater
Residential
Groundwater
1431 Pound Hill
Chloroform
1E-06
4E-04
1E-07
--
4E-04
Groundwater Risk Total =
4E-04
Total Risk =
4E-04
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides risk estimates for the significant routes of exposure for the current young child and adult resident exposed to groundwater used as tap (household) water. These risk estimates are
based on a reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of a young child's and adult's exposure to
groundwater, as well as the toxicity of the COC (chloroform). The total risk from direct exposure to contaminated groundwater to a current resident is estimated to be 4 x 10-4. This risk level indicates
that if no clean-up action is taken, a current child/adult resident would have an increased probability of 4 in 10,000 of developing cancer as a result of site-related exposure to the COCs in
groundwater. Results presented use current toxicity values along with site-specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 86
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Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-6: Risk Characterization Summary - Non-Carcinogens - Current Resident - Residential Groundwater
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Current
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure Medium
Exposure Point
Chemical of
Concern
Primary
Target Organ
Non-Carcinogenic Hazard Quotient
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Residential
Groundwater
1309 Pound Hill
Naphthalene
Whole Body
2E-03
3E+00
1E-03
3E+00
Groundwater Hazard Index Total =
3E+00
Whole Body Hazard Index =
3E+00
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the current young child and adult resident
exposed to groundwater used as tap (household) water. The Risk Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for
adverse noncancer effects. The estimated target organ HI of 3 indicates that the potential for adverse effects could occur from exposure to contaminated groundwater containing naphthalene. Results
presented use current toxicity values along with site-specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 87
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Landfill & Resource Recovery
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Record of Decision
April 2021
Table G-7: Risk Characterization Summary - Carcinogens - Future Resident - Overburden Groundwater
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure Medium
Exposure Point
Chemical of
Concern
Carcinogenic Risk
Ingestion
Inhalation
Dermal
External (Radiation)
Exposure
Routes Total
Groundwater
Groundwater
Overburden
Groundwater
1.1-Dichloroethane
1.2-Dichloroethane
1,2-Dichloropropane
1,4-Dichlorobenzene
1,4-Dioxane
Benzene
Naphthalene
Trichloroethene
Vinyl chloride
Arsenic
Chromium, Hexavalent
3E-07
3E-07
5E-07
IE-07
IE-04
5E-07
N/A
5E-07
3E-05
3E-03
9E-05
3E-05
3E-05
2E-05
7E-05
N/A
3E-05
1E-04
2E-05
9E-05
N/A
N/A
2E-08
IE-08
5E-08
7E-08
4E-07
7E-08
N/A
7E-08
2E-06
2E-05
4E-05
3E-05
3E-05
2E-05
7E-05
IE-04
3E-05
IE-04
2E-05
IE-04
3E-03
IE-04
Groundwater Risk Total ^
4E-03
Total Risk =
4E-03
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides risk estimates for the significant routes of exposure for the future young child and adult resident exposed to groundwater used as tap (household) water. These risk estimates are
based on a reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of a young child's and adult's exposure to
groundwater, as well as the toxicity of the COCs (1,4-dichlorobenzene, 1,1-dichloroethane, 1,2-dichloroethane, 1,2-dichloropropane, 1,4-dioxane, benzene, naphthalene, trichloroethene, vinyl
chloride, arsenic, and hexavalent chromium). The total risk from direct exposure to contaminated groundwater to a future resident, in the event that groundwater is used as a potable source, is
estimated to be 4 x 10-3. The COCs contributing most to these risk levels are 1,4-dioxane, naphthalene, vinyl chloride, and hexavalent chromium in groundwater. This risk level indicates that if no
clean-up action is taken, a future child/adult resident would have an increased probability of 4 in 1,000 of developing cancer as a result of site-related exposure to the COCs in groundwater. Results
presented use current toxicity values along with site-specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 88
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-8: Risk Characterization Summary - Non-Carcinogens - Future Resident - Overburden Groundwater
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Exposure Point
Chemical of
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Concern
Ingestion
Inhalation
Dermal
Exposure
Routes Total
Groundwater
Groundwater
Overburden
Groundwater
1,2-Dichloropropane
Developmental
IE-03
3E+00
1E-04
3E+00
Naphthalene
Whole Body
3E-03
4E+00
2E-03
4E+00
Trichloroethene
Developmental/Immune System
6E-02
4E+00
9E-03
4E+00
Arsenic
Cardiovascular/Skin
3E+01
N/A
1E-01
3E+01
Iron
Gastrointestinal
3E+00
N/A
1E-02
3E+00
Manganese
Nervous System
7E+00
N/A
8E-01
8E+00
Groundwater Hazard Index Total =
5E+01
Immune System Hazard Index =
4E+00
Developmental Hazard Index =
7E+00
Skin Hazard Index =
3E+01
Whole Body Hazard Index =
4E+00
Cardiovascular Hazard Index =
3E+01
Gastrointestinal Hazard Index =
3E+00
Nervous System Hazard Index =
8E+00
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the future young child and adult resident
exposed to groundwater used as tap (household) water. The Risk Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for
adverse noncancer effects. The estimated target organ His between 3 and 30 indicate that the potential for adverse effects could occur from exposure to contaminated groundwater containing 1,2-
dichloropropane, naphthalene, trichloroethene, arsenic, iron, and manganese. Results presented use current toxicity values along with site-specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 89
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-9: Risk Characterization Summary - Carcinogens - Future Resident - Bedrock Groundwater
Risk Characterization Summary - Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Exposure Point
Chemical of
Carcinogenic Risk
Medium
Concern
Ingestion
Inhalation
Dermal
External (Radiation)
Exposure
Routes Total
Groundwater
Groundwater
Bedrock
Groundwater
1,1-Dichloroethane
3E-07
3E-05
2E-08
3E-05
1,2-Dichloroethane
8E-07
8E-05
4E-08
8E-05
1,4-Dioxane
6E-05
N/A
2E-07
6E-05
Benzene
2E-07
1E-05
3E-08
IE-05
Tetrachloroethene
4E-08
2E-06
2E-08
2E-06
Trichloroethene
1E-06
3E-05
2E-07
3E-05
Vinyl chloride
9E-06
3E-05
4E-07
4E-05
Arsenic
5E-04
N/A
3E-06
--
5E-04
Chromium, Hexavalent
5E-05
N/A
2E-05
7E-05
Groundwater Risk Total =
8E-04
Total Risk =
8E-04
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides risk estimates for the significant routes of exposure for the future young child and adult resident exposed to groundwater used as tap (household) water. These risk estimates are
based on a reasonable maximum exposure and were developed by taking into account various conservative assumptions about the frequency and duration of a young child's and adult's exposure to
groundwater, as well as the toxicity of the COCs (1,1 -dichloroethane, 1,2-dichloroethane, 1,4-dioxane, benzene, tetrachloroethene, trichloroethene, vinyl chloride, arsenic, and hexavalent chromium).
The total risk from direct exposure to contaminated groundwater to a future resident, in the event that groundwater is used as a potable source, is estimated to be 8 x 10-4. The COCs contributing most
to these risk levels are arsenic, 1,2-dichloroethane, 1,4-dioxane, and hexavalent chromium in groundwater. This risk level indicates that if no clean-up action is taken, a future child/adult resident
would have an increased probability of 8 in 10,000 of developing cancer as a result of site-related exposure to the COCs in groundwater. Results presented use current toxicity values along with site-
specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 90
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Table G-10: Risk Characterization Summary - Non-Carcinogens - Future Resident - Bedrock Groundwater
Risk Characterization Summary - Non-Carcinogens
Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Young Child/Adult
Medium
Exposure
Exposure
Chemical of
Primary Target Organ
Non-Carcinogenic Hazard Quotient
Medium
Point
Concern
Ingestion
Inhalation
Dermal
Exposure Routes
Total
Groundwater
Groundwater
Bedrock
Groundwater
Trichloroethene
Developmental/Immune System
1E-01
7E+00
2E-02
7E+00
Arsenic
Cardiovascular/Skin
4E+00
N/A
2E-02
4E+00
Groundwater Hazard Index Total =
1E+01
Immune System Hazard Index =
7E+00
Developmental Hazard Index =
7E+00
Skin Hazard Index =
4E+00
Cardiovascular Hazard Index =
4E+00
Key:
N/A - Toxicity criteria are not available to quantitatively address this route of exposure.
-- Route of exposure is not applicable to this medium.
This table provides hazard quotients (HQs) for each route of exposure and the hazard index (sum of the hazard quotients) for all routes of exposure for the future young child and adult resident
exposed to groundwater used as tap (household) water. The Risk Assessment Guidance for Superfund (RAGS) states that, generally, a hazard index (HI) of greater than 1 indicates the potential for
adverse noncancer effects. The estimated target organ His between 4 and 7 indicate that the potential for adverse effects could occur from exposure to contaminated groundwater containing
trichloroethene and arsenic. Results presented use current toxicity values along with site-specific exposure parameters from the baseline HHRA.
Appendix B - Tables
Page | 91
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Appendix C - Figures
Figure
1-1
Figure
1-2
Figure
1-3
Figure
1-4
Figure
1-5
Figure
1-6
Figure
1-7
Figure
1-8
Figure
1-9
Figure
1-10
Figure
1-11
Figure
1-12
Figure
l-13a
Figure
l-13b
Figure
1-14
Figure 2-1
Figure 4-1
Locus Map
Site Map
Site and Surrounding Area
Hydrogeological Investigation Locations & Investigation Sub-Areas
Cross Section D-D'
Cross Section E - E'
Cross Section F - F'
Shallow and Intermediate Overburden Groundwater Elevation Contours March 2017
Deep Overburden and Bedrock Groundwater Elevation Contours March 2017
Approximate Extents of Exceedances in Groundwater
Vertical Extents of Impacts Cross Section E - E'
Summary of Surface Water Impacts
Summary of Sediment Impacts (0-6 in)
Summary of Sediment Impacts (6-12 in)
Conceptual Site Model
PRG Exceedances
Conceptual Plan for Alternative 3: Groundwater Extraction, Ex Situ Treatment, and
Infiltration of Treated Groundwater
Figure 4-2 Conceptual Plan for Alternative 4: Two-Stage Reactive Treatment Zone
Appendix C - Figures
Page | 92
-------
» \W '¦ X ' Park ¦
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Landfill
1 inch = 2,000 feet
0 500 1,000
2,000
Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions.
Any reliance upon the map or data contained herein shall be at the users' sole risk. Data Sources: ESRI
-------
Trout Brook
?ilgonal/C
BH18-1
HgJegH
gT MW-301
MW-102A
®BHl6-4
BUS
BH16-3
I GP-6
MW-104A
Wt&M
BH16-5 |
Ml mm
Flare and Blower Building
MW-103A
Notes
1. Parcel boundaries interpretted from May 2012 Existing Site
Plan (Drawing C-01) and the Town of North Smithfield (November
2013) and may not reflect on-the-ground accuracy.
2. Data displayed in NAD83 Rl State Plane and NAVD88.
3. Orthophotography from USGS, April 2014.
4. Investigation locations based on surveys conducted by Louis
Federici & Associates, Inc. and DiPrete Engineering Co.
N
A
Figure 1-2
Site Plan
L&RR Superfund Site
OU 2 Remedial Investigation
/Feasibility Study
Legend
Monitoring Well
@ Overburden CMT
-Q- Piezometer
Residential Well
a Annual PCSM Surface V\foter
Sample Location
(J) Waterloo Profile Location
-0- Discrete Groundwater Location
(J) Bedrock CMT
0 Bedrock Borehole
R Gas Probe
Abandoned Monitoring Well
Geoprobe Groundwater (2006)
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
I Interpreted Parcel Boundaries
| Surface Water Detention Basins
¦ Roads
1 inch = 400 feet
100 200 400
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Figure 1-3
Site and Surrounding
Area
L&RR Superfund Site
OU 2 Remedial Investigation
/Feasibility Study
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
100-year floodplain
EZ3 500-year floodplain
Interpreted Parcel Boulfcf&flEI
Notes:
1. Parcel boundaries interpretted from May 2012 Existing Site Plan
(Drawing C-01) and the Town of North Smithfield (November 2013)
and may not reflect on-the-ground accuracy
2. Data displayed in NAD83 Rl State Plane and NAVD88.
3. Orthophotography from USGS, April 2014.
4. Extent of wetland features surveyed in July 2016 by DiPrete
Engineering. Wetlands east of Pound Hill Road and near the
Slatersville Reservoir are based upon the National Wetlands
Inventory.
5. FEMA Floodplains from National Flood Insurance Program Flood
Rate Map (FIRM) Panel 0152G, Providence County
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions. Any reliance upon the map or data contained herein shall be at the users' sole risk.
Data Sources: USGS, Town of North Smithfield, Rl
-------
Downgradient
of Wetland
Upgradient
of Landfill
Lot #11
BH16-1
Downgradient
of Landfill
BH 16-4
Lot #89
W"MWr102B
w
MW-102A
BH16-2
Near Receptor
Wetland
Landfill Area
Upgradient
of Wetland
MW-1Q4A
Transect 2 Lot#24 '
/ i'Z*£s
• mw-305 Transect 3
' /
DW-1431 BH16-5 QW-,1375^ ^
jr i Lot#7°
t MW-202
BH16-3
MW-103A
Transect 1
i i i
Upgradient
of Wetland
Notes:
1. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the
Town of North Smithfield (November 2013) and may not reflect on-the-ground accuracy
2. Data displayed in NAD83 Rl State Plane and NAVD88.
3. Orthophotography from USGS, April 2014.
4. Overburden Multi-Level System identifier to correspond with A/B/C - deep / intermediate /
shallow designation.
N
A
Figure 1-4
Hydrogeological Investigation
Locations & Investigation
Sub-Areas
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
Annual PCSM Surface V\foter
Sample Location
Legend
Monitoring Well
(J) Bedrock CMT
(J) Overburden CMT
0 Bedrock Borehole
Piezometer
Residential Well
~
(J) Waterloo Profile Location
Discrete Groundwater Location
Roads
Geological Cross-Sections
™ ™ 1 Transects
Interpreted Parcel Boundaries
Investigation Subareas
Downgradient of Landfill
Downgradient of Wetland
Landfill Area
Near Receptor
Upgradient of Landfill
Upgradient of Wetland
| Wetland
Cross-Section Profile
1 inch = 400 feet
0 100 200 400
I Feet
0
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
EHT
Litholoqy
/
Silty Fine Sand
Coarse to Fine Sand
Sand and Clay
Bedrock
Hydrology
Fine to Medium Sand
Sand and Gravel
Clay
Estimated Landfill
Waste Depth (Offset)
Well Construction
Surface Water/Wetland o°o0o°c
-o.o.ca
Groundwater Elevation
(March 2017)
Bedrock Geophysics
Likely
Transmissive Fracture
CMT Screen
Open Borehole
Well Screen
Notes
1. Monitoring wells, borings, and groundwater profile locations are approximate.
2. Vertical elevations along cross-section derived from Rhode Island 2011
state-wide LiDAR dataset obtained from RIGIS.
3. Geologic units were interpreted from E.C. Jordan and Wehran Engineering
borings and well installations during previous site investigation activities. Units and
contacts are interpretational and may vary from actual field conditions.
4. Lithology interpolated using "Lateral Blending" algorithm in RockWorks 17.
Lateral blending extends boring lithology data horizontally and randomizes
correlations at the middle zone between borings.
5. Private well data for wells along Pound Hill Road (DW-XXXX) based on well
logs on file at Rhode Island Department of Public Health.
6. Water table is inferred from depth to groundwater measurements in shallow
overburden wells recorded in the field by Woodard & Curran on March 6, 2017.
Overburden groundwater elevations near private wells along Pound Hill Road were
estimated based upon topography.
7. The location of Trout Brook and associated wetlands have been interpreted
from existing orthophotos. These limits likely vary with stage of the brook.
8. Refer to Figue 1-4 for the location of Cross-Section D-D'.
Orthophotography from Google Earth, 2018. Not to Scale.
Possibly
Transmissive Fracture
,® 160-
777.7
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-r-
600
Distance (Feet-RI State Plane)
-------
Litholoqy
¦
Hydrology
Silty Fine Sand
Coarse to Fine Sand
Bedrock
Fine to Medium Sand
Sand and Gravel
Groundwater Elevation
(March 2017)
Bedrock Geophysics
^ Likely
Transmissive Fracture
Possibly
Transmissive Fracture
Well Construction
CMT Screen
Open Borehole
Well Screen
Notes
1. Monitoring wells, borings, and groundwater profile locations are approximate.
2. Vertical elevations along cross-section derived from Rhode Island 2011 state-wide
LiDAR dataset obtained from RIGIS.
3. Geologic units were interpreted from E.C. Jordan and Wehran Engineering borings
and well installations during previous site investigation activities. Units and contacts
are interpretational and may vary from actual field conditions.
4. Lithology interpolated using "Lateral Blending" algorithm in RockWorks 17. Lateral
blending extends boring lithology data horizontally and randomizes correlations at the
middle zone between borings.
5. Water table is inferred from depth to groundwater measurements in shallow
overburden wells recorded in the field by Woodard & Curran on March 6, 2017.
6. The location of Trout Brook and associated wetlands have been interpreted from
existing orthophotos. These limits likely vary with stage of the brook.
7. Refer to Figure 1-4 for the location of Cross-Section E-E1.
300-
250-
200-
00
Q
>
<
150 —
100-
50-
-250
-200
-300
-150
CO
a
>
<
-100
-50
200
400
600
800
I
1,000
—i—
1,200
I T
1,400
1 T
1,600
"I 1 r
1,800
Orthophotography from Google Earth, 2018. Not to Scale.
Distance (Feet-RI State Plane)
X ts
S %
CO 3
® 1
Q> >
: CO
re > o
^ O N
-g ^
S < £
i
4
0
LU
5
oa
z
UJ
1
E
S
o
o
~ Z
etc
00
LU
LU
o
LU
°?
th
03
O
a:
o
3
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o
ill 52
b LU
w Q
§ s
Q
_l
LU
CC
LU
D.
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CO
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08
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a
LU
s
LU
cc
>
Q
ID
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CO
>-
gg
w
<
LU
JOB NO: 229620
FIGURE 1-6
-------
Litholoqy
Silty Fine Sand
Coarse to Fine Sand
Fine to Medium Sand
Bedrock
/ /
Hydrology
Sand and Gravel
Estimated Landfill
Waste Depth (Offset)
Well Construction
Surface Water/Wetland °o0o°oc
n r> n rl
Groundwater Elevation
(March 2017)
Bedrock Geophysics
Likely
Transmissive Fracture
Possibly
Transmissive Fracture
CMT Screen
Open Borehole
Well Screen
Notes
1. Monitoring wells, borings, and groundwater profile locations are approximate.
2. Vertical elevations along cross-section derived from Rhode Island 2011 state-wide
LiDAR dataset obtained from RIGIS.
3. Geologic units were interpreted from E.C. Jordan and Wehran Engineering borings
and well installations during previous site investigation activities. Units and contacts
are interpretational and may vary from actual field conditions.
4. Lithology interpolated using "Lateral Blending" algorithm in RockWorks 17. Lateral
blending extends boring lithology data horizontally and randomizes correlations at the
middle zone between borings.
5. Water table is inferred from depth to groundwater measurements in shallow
overburden wells recorded in the field by Woodard & Curran on March 6, 2017.
6. The location of Trout Brook and associated wetlands have been interpreted from
existing orthophotos. These limits likely vary with stage of the brook.
7. Refer to Figure 1-4 for the location of Cross-Section F-F1.
Orthophotography from Google Earth, 2018. Not to Scale.
300-1
250-
00
00
g 200-
<
o
To
>
0)
W 150-
100-
i.
0
CD
i
I * *
¦ • ••••••• t t
§
O
¦* -•
<
o
7 / NSwVU* NiVXdLi; N*
7 7
7 7 7 7
7/7 7
7 7 7 7 7 7
v - j • m • • • • I k • • m • •
/ / JL £
// / J/ /
?rs sfeSol s
iXX/iJ XiiXii.
i-300
-250
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JOB NO: 229620
FIGURE 1-7
-------
MW-308/BH1E
'installed *
October(2018
\ \ V
Lot #89 /X.
-e?mjiiLL
\
IMV^04aTO=
2491-21 ftW
d\ IV |
fjrt MW-104B
•249.59rfl>
M\AA303D
240.78 ft
£\ MW-303G
V 241.24 fl?
* "" ~ i
Notes:
1. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the Town of North
Smithfield (November 2013) and may not reflect on-the-ground accuracy.
2. Data displayed in NAD83 Rl State Plane and NAVD88.
3. Orthophotography from USGS, April 2014.
4. Piezometers at locations PZ-302 and PZ-303 are intended to gauge shallow groundwater elevations.
Piezometers at locations PZ-6 and PZ-7 include a shallow (S) piezometer installed below the stream bed and
a deep (D) piezometer two feet below the bottom of the shallow piezometer.
5. Groundwater elevation contours presented in feet above mean sea level (ft AMSL) inferred using water
level measurements obtained on March 6, 2017.
6. Groundwater elevations at new monitoring locations calculated based on measuring point elevations
surveyed April 5, 2017 by Diprete Engineering.
7. Groundwater elevations displayed (in ft AMSL) represent those utilized in contour generation.
N
A
Figure 1-8
Shallow and
Intermediate Overburden
Groundwater Elevation Contours
March 2017
L&RR Superfund Site
OU 2 Remedial Investigation
/Feasibility Study
Legend
Q Bedrock CMT
^ Bedrock Borehole
-^j^- Monitoring Well
¦ J?}: Overburden CMT
e Piezometer
Residential Well
Groundwater Elevation Contours
(ft AMSL)
Roads
™ ¦ ¦ Streams
Interpreted Parcel Boundaries
1 inch = 300 feet
0 75 150 300
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
BH18-1/MW-308
¦Installed October 2018
BH16-/I y
£40.94 ft
(MW-301B"
"240.72 ft
MW-302A BH16-2
Lot #23 * 2*41.30 ft-241'.37 ft
BH14i3K
-23^00.ftl
*MW-30*4A
b'237.97 ft
^MW-305AVBH16-5
240.31^240.57 ft
7*MWr305B
4 24d'3?ft^
2-W
Lot #90
Notes:
1. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the Town of North
Smithfield (November 2013) and may not reflect on-the-ground accuracy.
2. Data displayed in NAD83 Rl State Plane and NAVD88.
3. Orthophotography from USGS, April 2014.
D) piezometer two feet below the bottom of the shallow piezometer.
4. Groundwater elevation contours presented in feet above mean sea level (ft AMSL) inferred using water level
measurements obtained March 6, 2017.
5. Groundwater elevations at new monitoring locations calculated based on measuring point elevations surveyed
April 5, 2017 by Diprete Engineering.
6. Bedrock contours utilize groundwater elevation data from open boreholes at BH16-2, BH4-1, and BH16-5.
Multi-level systems had been installed at BH16-01, BH16-03, and BH16-04 at the time of water level
measurements. For these locations, the groundwater elevation from the highest yield zone used for contour
generation.
7. Groundwater elevations displayed (in ft AMSL) represent those utilized in contour generation.
N
A
Figure 1-9
Deep Overburden and Bedrock
Groundwater Elevation Contours
March 2017
L&RR Superfund Site
OU 2 Remedial Investigation
/Feasibility Study
Legend
@ Bedrock CMT
0 Bedrock Borehole
Monitoring Well
@ Overburden CMT
-Q- Piezometer
Residential Well
Groundwater Elevation Contours (ft
AMSL)
— Streams
Surveyed Extent of Wetland Features
(July 2016)
Approximate Extent of Wetland Features
Interpreted Parcel Boundaries
Roads
1 inch = 300 feet
0 75 150 300
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
BH16-1
BH16-4
MW-102A
BH14-1
MW-104A
BH16-3®
BH16-5
MW-103^
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the
Town of North Smithfield (November 2013) and may not reflect on-the-ground accuracy,
3. Data displayed in NAD83 Rl State Plane and NAVD88.
4. Orthophotography from USGS, April 2014.
5. Overburden Multi-Level System identifier to correspond with A/B/C - deep / intermediate /
shallow designation.
6. Extents of exceedances are approximate and based on samples collected during 2017
and 2018 Pre-ROD groundwater and OU 1 PCSM sampling (metals) and are therefore
limited to the sampled well network.
7. Exceedances determined based on comparison of analytical results to the Standards for
Nature and Extent Comparison as provided on the tables included in Section 4 of the Rl
Report.
8. Western boundaries are inferred to follow the toe of the landfill based upon review of
available historical information.
Compounds with Concentrations Exceeding Standards (shown)
Volatile Organic Compounds (VPCs) Metals
1,4-Dioxane (0.35 ug/L) Antimony (6 ug/L)
cis-1,2-Dichlorcethene (70 ug/L) Arsenic (10 ug/L)
Vinyl Chloride (2 ug/L) Iron (300 ug/L)
Tetrachloroethene (5 ug/L) Manganese (50 ug/L)
Per- & Polytluorosubtances (PFAS) Semi-Volatile Organic Compounds (SVOCs)
PFOA (40.1 ng/L)
Total PFOA + PFOS (40.1 ng/L)
bi s(2- h thy I hex y I )phthal ate (6 ug/L)
N
A
Figure 1-10
Approximate Extents of
Exceedances in Groundwater
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
@ Bedrock Multi-Level System
4) Bedrock Borehole
Monitoring Well
(4) Overburden Multi-Level System
Residential Well
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
Approximate Extent of
Exceedances in Groundwater
,-¦1
L» 1,4-Dioxane
. J
Other VOCs
¦I
- PFAS
J
Metals
: SVOCs
U.J
1 inch = 300 feet
0 75 150 300
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Litholoqy
Silty Fine Sand
Fine to Medium Sand
. *. *, Coarse to Fine Sand
• •
Sand and Gravel
hssfos*
Bedrock
H G
Hydrology
Groundwater Elevation
(March 2017)
Bedrock Geophysics
Likely
Transmissive Fracture
Possibly
Transmissive Fracture
Result Below Minimum
Laboratory Reporting Limit
Well Construction
_o,o o
CMT Screen
Open Borehole
Well Screen
Notes
1, Monitoring wells, borings, and groundwater profile locations are approximate.
2 Vertical elevations along cross-section derived from Rhode island 2011 state-wide
LIDAR dataset obtained from RIGIS.
3. Geologic units were interpreted from E.G. Jordan and Wehran Engineering borings
and well installations during previous site investigation activities. Units and contacts
are interpretational and may vary from actual field conditions,
4. Lithology interpolated using "Lateral Blending" algonthm in RockWorks 17. Lateral
blending extends boring lithology data horizontally and randomizes correlations at the
middle zone between borings.
5. Water table is inferred from depth to groundwater measurements in shallow
overburden wells recorded in the field by Woodard & Curran on March 6,2017.
6. The location of Trout Brook and associated wetlands have been interpreted from
existing orthophotos. These limits likely vary with stage of the brook.
7. Groundwater concentrations displayed are the average concentration of
1,4-dioxane and all other VOCs across Spring 2017 and Summer 2018 Pre-ROD
sampling events and April and October 2018 Residential drinking water sampling
events. The size of the chart reoresents the averaae total VOC concentration.
8. Referto Figure 1-4 for the location of Cross-Section E-E'.
300-1
TROUT
BROOK
WETLANDS
E
Orthophotography from Google Earth: 2018. Not to Scale.
i—300
2.93
5 -
1,4-Dioxane [|jg/L]
Other VOCs [|jg/L]
Total VOC Concentration (pg/L)
ND- 10
I • I I
250 —
10-50 50- 100
100-400
> 400
200-
150-
/ 7 / / /
7 77 7 / 7 7
y y y / / y /
7 7/7 .7 7 /
i. j, >. • -
/ 7 7 7
/ / / / / /W
111
7 / / y,/ / /
100H / / / / / / /
y y y y y y y
y y y y y y y
ILL
414.50
56.751 * - ¦ • ¦
• ••••••a
240 00 !*••••*••**•** / a. »*•*••• *
rv
1151.151-
-250
-200
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- y y y y y y y
:/ / / / / /
50
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7 7 7 / / 7 /
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.y y y y y y y ,
y y y y„y y
y y y y y y y ,
y
y y y y y y y ,
77 yy y y
P zzizzz
7 7 7 //////
yy/ y y y
y y y y y y y y y
y y y y y y y y y
7 7 y y y y
111
y y y y y y / "/
7 7 7 7/777
-150
/ / /
11111
7 7/ / 7 /fss^oH-
7 7 7 7 7 7 7 7
/ / / / /
32.701 , - . t n >
-7-—W / / 7 38.65
7 7 7 7 7 7 7
-100
I
zxz
o- >
y /
777
, / / 7
. / 7 °7 z / / % y 7 7 / / / / / /
1111 1
7 7 7. 7 7
7 7 / 7 7
y y y y y y y y
7 7 7 7 7 7 7 7 7
7 7 7 7 7 7 7 7 7
7 7 7 7 7/ 7 7;
/ T1 1 1 1 [79^/
7 7 7 7 7 7. 7 7...
60.80
T—
/
43.20
~7V
/
7 7 7 7 7
7/7 7 /
7 / / / .7 . .
7 7 7 7 7
7 7 7 7 7
-50
-0
7 7 7 7 7.....7.....7.....7..
200
400
600
800
1,000
1,200
1,400
-i I r
1,600
1,800
Distance (Feet-RI State Plane)
E
3
? %
o ™ B
^O-O
|||
« a i
i 12
o 5 CO
< oe>
'i
3
s
£
ca:
o
LU
£
oO
Z
LU
8
QZ
cue
3
LU
o
UJ «
t LU
CO Q
° I
^ 9
% yy
CO *
1r ^
1r s
-1 I
I—
1r
o
Q
3
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CO
=5
2
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<
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en
LU
>
— m
1 <
Q LU
LU L
2
LU
CC
JOB NO. 229620
JUNE 2020
FIGURE 1-11
-------
Lot #11
SW-10
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete
Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01)
and the Town of North Smithfield (November 2013) and may not reflect on-the-
ground accuracy.
3. Data displayed in NAD83 Rl State Plane and NAVD88.
4. Orthophotography from USGS, April 2014.
5. Results shown are from wetland and ecological sampling conducted in
June/July 2016 and May 2017, Pre-ROD surface water sampling conducted in
July/August 2018, and PCSM sampling conducted between 2013 and 2018.
6. Exceedances are based on sample results exceeding the Standards for Nature
INSET: Northern Extent of Trout Brook Pond (TB-16 and TB-17)
N
A
Figure 1-12
Summary of Surface
Water Impacts
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
SVOCs v / Metals
VOCs Pesticides
Concentration of specified
~ constituent detected above the
applicable standard
Concentration of specified
~ constituent not detected above the
applicable standard
¦ Sample not analyzed for specified
constituent
1 inch = 400 feet
100 200 400
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Lot #11
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete
Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01)
and the Town of North Smithfield (November 2013) and may not reflect on-the-
ground accuracy.
3. Data displayed in NAD83 Rl State Plane and NAVD88.
4. Orthophotography from USGS, April 2014.
5. Results shown are from wetland and ecological sampling conducted in
June/July 2016 and May 2017.
6. Exceedances are based on sample results exceeding the sediment-specific
ecological benchmarks presented in the SLERAand Refinement.
INSET: Northern Extent of Trout Brook Pond (TB-16 and TB-17)
N
A
Figure 1-13a
Summary of Sediment
Impacts (0-6 in)
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
SVOCs v ~ Metals
VOCs ' ^ Pesticides
Concentration of specified
~ constituent detected above the
applicable benchmark
Concentration of specified
~ constituent not detected above the
applicable benchmark
¦ Sample not analyzed for specified
constituent
1 inch = 400 feet
100 200 400
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Lot #11
UG-4
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete
Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01)
and the Town of North Smithfield (November 2013) and may not reflect on-the-
ground accuracy.
3. Data displayed in NAD83 Rl State Plane and NAVD88.
4. Orthophotography from USGS, April 2014.
5. Results shown are from wetland and ecological sampling conducted in
June/July 2016 and May 2017.
6. Exceedances are based on sample results exceeding the sediment-specific
ecological benchmarks presented in the SLERAand Refinement.
INSET: Northern Extent of Trout Brook Pond (TB-16 and TB-17)
" -
N
A
Figure 1-13b
Summary of Sediment
impacts (6-12 in)
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
SVOCs v s Metals
VOCs ' ^ Pesticides
Concentration of specified
~ constituent detected above the
applicable benchmark
Concentration of specified
~ constituent not detected above the
applicable benchmark
¦ Sample not analyzed for specified
constituent
1 inch = 400 feet
100 200 400
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Figure 1-14 Conceptual Site Model
L&RR Landfill Superfund Site
OU 2 Remedial Investigation/Feasibility Study
North Smithfield, Rhode Island
Receptor/Risk Drivers ¦
Primary Source
Release
Mechanism
Contaminated
Media
Exposure Routes
Recreational User
| Resident |
Current
1
Future
Trout Brook Area1 Tributary Area1
Direct disposal
Landfill Waste
Leaching to
Groundwater
Surface Water
(considers pore
water)
Ingestion
Dermal contact
Inhalation
Vapor intrusion'
(inhalation)
Incidental Ingestion
Dermal contact
Fish/Shellfish
Ingestion
~
Sediment
Incidental Ingestion
Dermal contact
Surface Water
Surface Water
Surface Water
Sediment
Sediment
Overburden &
Bedrock6
Groundwater
Overburden
Groundwater6
NOTES:
1. USEPA provided a memorandum, dated September 12, 2018, which provided concurrence on the conclusions of the September 2018 version of the SLERA and Refinement along with acknowledgement that a BERA was not required.
This memorandum also indicated there was no clear indication of ecological risk for which remedial action would be required. No Receptor/Risk Drivers are indicated in this CSM based on USEPA's concurrence in this memorandum.
2. Evaluated qualitatively in HHRA through comparison to vapor intrusion screening levels.
3. Recreational users of the Trout Brook, Tributaries and Trout Brook Pond Areas may encounter COPCs in surface water and shallow sediment driven by risks associated with arsenic and hexavalent chromium (if present).
4. Evaluated qualitatively in the HHRA through comparison to surface water quality standards.
5. Overburden groundwater COCs include:
VOCs: 1,4-dichlorobenzene, 1,1-DCA, 1,2-DCA, 1,2-dichloropropane, 1,4-dioxane, cis-1,2-DCE, benzene, naphthalene, TCE, vinyl chloride,
SVOCs: bis-2-ethylhexylphthalate
Metals: antimony, arsenic, chromium (hexavalent), iron, manganese
PFAS: PFOA (incl. total PFOA/PFOS)
6. Bedrock groundwater COCs include:
VOCs: 1,1-DCA, 1,2-DCA, 1,4-dioxane, 2-hexanone, benzene, TCE, PCE, vinyl chloride
Metals: arsenic, chromium (hexavalent)
PFAS: PFOA (incl. total PFOA and PFOS)
-------
Approximate Extent of
Development for
Proposed Solar Array
Overhead Electric Utility Corridor „
(National Grid) & p
Natural Gas Pipeline
(Kinder Morgan/Tennesse Gas)
Flare Building
Approximate Extent
of Existing Solar
Development
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete
Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01)
and the Town of North Smithfield (November 2013) and may not reflect on-the-
ground accuracy.
3. Data displayed in NAD83 Rl State Plane and NAVD88
4. Orthophotography from USGS, April 2014.
5. Results shown are from wetland and ecological sampling conducted in
June/July 2016 and May 2017.
N
A
Figure 1-15
Site and Remedial
Design Considerations
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
Monitoring Well
©
Overburden CMT
©
Bedrock CMT
¦e
Piezometer
Residential Well
h
Gas Probe
¦
Gas Well
Gas Collection Pipe
X — X Fence Line
Surface Water Detention Basins
Approximate location of Natural
Gas Pipeline
Approximate location of Electric
Transmission Lines
Wetlands
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
• Stream Channel
Interpreted Parcel Boundaries
Roads
0 100 200
400
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
BH16-1
BH16-4
MW-102B Jt\
Ipt*
7j MW-102A
BH16-2 MW-302
BH14-1
»CW-6A
>CW-6B
CW-6C
MW-104A
X BH16-3
BH16-5 ^
5 MW-305
i r
MW-103A
Notes:
1. Locations shown based upon survey conducted April 5, 2017 by Diprete Engineering.
2. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the
Town of North Smithfield (November 2013) and may not reflect on-the-ground accuracy.
3. Data displayed in NAD83 Rl State Plane and NAVD88.
4. Orthophotography from USGS, April 2014.
5. Overburden Multi-Level System identifier to correspond with A/B/C - deep / intermediate /
shallow designation.
6. Extents of exceedances are approximate and based on samples collected during 2017
and 2018 Pre-ROD groundwater and OU 1 PCSM sampling (metals) and are therefore
limited to the sampled well network. Results were compared to the Standards for Nature &
Extent Comparison presented on Table 4 of the Rl.
7. Exceedances determined based on comparison of analytical results to the Preliminary
Remediation Goals included in Table 2-4.
8. Western boundaries are inferred to follow the toe of the landfill based upon review of
available historical information.
N
A
Figure 2-1
Exceedances of
Preliminary Remediation Goals
in Groundwater
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
@ Bedrock Multi-Level System
0 Bedrock Borehole
Monitoring Well
(+) Overburden Multi-Level System
Residential Well
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
Approximate Extent of
Exceedances in Groundwater
¦ 1,4-Dioxane
J
Other VOCs
J
i PFAS
Metals
"! SVOCs
Sampling location with a
PRG exceedance
1 inch = 300 feet
0 75 150 300
I Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
BH18-1
Lot #11
BH16-4
'BH162
If! '
/ MW-102A
BH14-1
MW-104A
By 16-3
BH16-5
Proposed GWTP
Location
Lot #9A
MW-103A"
Notes:
1. Figure intended to be a conceptual representation of the proposed layout for Alternative 3.
2. Locations shown based upon survey conducted April 5, 2017 by Diprete Engineering.
3. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the
Town of North Smithfield (November 2013) and may not reflect on-the-ground accuracy.
4. Data displayed in NAD83 Rl State Plane and NAVD88.
5. Orthophotography from USGS, April 2014.
6. Overburden Multi-Level System identifier to correspond with A/B/C - deep / intermediate /
shallow designation.
7. Extents of exceedances are approximate and based on samples collected during 2017 and
2018 Pre-ROD groundwater and OU 1 PCSM sampling (metals) and are therefore limited to
the sampled well network.
8. Exceedances determined based on comparison of analytical results to the Standards for
Nature and Extent Comparison as provided on the tables included in Section 4 of the Rl
Report.
9. Western boundaries are inferred to follow the toe of the landfill based upon review of
available historical information.
Compounds with Concentrations Exceeding Standards (shown)
Volatile Organic Compounds (VPCs) Metals
1,4-Dioxane (0.35 ug/L) Antimony (6 ug/L)
cis-1,2-Dichlorcethene (70 ug/L) Arsenic (10 ug/L)
Vinyl Chloride (2 ug/L) Iron (300 ug/L)
Tetrachloroethene (5 ug/L) Manganese (50 ug/L)
Per- & Poiytluorosubtances (PFAS) Semi-Volatile Organic Compounds (SVOCs)
PFOA (40.1 ng/L)
Total PFOA + PFOS (40.1 ng/L)
bi s(2- h thy I hex y I )phthal ate (6 ug/L)
N
A
Figure 4-1
Conceptual Plan for Alternative 3
Groundwater Extraction,
Ex Situ Treatment, and Infiltration
of Treated Groundwater
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode Island
Legend
(J) Bedrock Multi-Level System
0 Bedrock Borehole
Monitoring Well
(~) Overburden Multi-Level System
Residential Well
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
Approximate Extent of
Exceedances in Groundwater
-¦1
¦ 1,4-Dioxane
Other VOCs
l_. J
-¦1
¦ PFAS
L. J
.-¦I
Metals
icU . iJ
SVOCs
L.j
Proposed Extraction Well Locations
¦ Proposed Groundwater Treatment
Plant Location
:::i Proposed Location of Infiltration
k ¦¦¦¦¦] Basins
Proposed Conveyance Piping
Approximate Area of Potential
Wetland Disturbance
1 inch = 300 feet
0 75 150 300
Feet
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
BH18-1
BH16;1
Stage 2: Activated Carbon
BH16-4
¦102 A
BH167l2j;
Stage 1: Potassium Persulfate
BH14-1
Targeted Potassium Persulfate
Injection Areas
MW-104A
'BH1S-3®
BH16-5
| yApproximate area of
y no/limite'd injection
ll^^^Baueitojproximitv to gasllinel
I
MW-103A
Notes:
1. Figure intended to be a conceptual representation of the proposed layout for Alternative 4.
2. Locations shown based upon survey conducted April 5, 2017 by Diprete Engineering.
3. Parcel boundaries interpreted from May 2012 Existing Site Plan (Drawing C-01) and the
Town of North Smithfield (November 2013) and may not reflect on-the-ground accuracy.
4. Data displayed in NAD83 Rl State Plane and NAVD88.
5. Orthophotography from USGS, April 2014.
6. Overburden Multi-Level System identifier to correspond with A/B/C - deep / intermediate /
shallow designation.
7. Extents of exceedances are approximate and based on samples collected during 2017 and
2018 Pre-ROD groundwater and OU 1 PCSM sampling (metals) and are therefore limited to
the sampled well network.
8. Exceedances determined based on comparison of analytical results to the Standards for
Nature and Extent Comparison as provided on the tables included in Section 4 of the Rl
Report.
9. Western boundaries are inferred to follow the toe of the landfill based upon review of
available historical information.
10. Each stage of the proposed permeable reactive treatment zone includes 2 rows of
injections off set approximately 10 feet in each direction (spacing to be confirmed during
expanded bench-testing and potential future pilot-testing).
11. Proposed targeted potassium persulfate injections to be installed in a grid pattern using a
7.5-foot radius of influence.
Compounds with Concentrations Exceeding Standards (shown)
Volatile Organic Compounds (VOCs) Metals
1,4-Dioxane (0.35 ug/L) A nlimony (6 ug/L)
cis-1,2-Dichloroethene (70 ug/L) Arsenic (10 ug/L)
Vinyl Chloride (2 ug/L) Iron (300 ug/L)
Tetrachloroethene (5 ug/L) Manganese (50 ug/L)
Per- & Polyfluorosubtances (PFAS) Semi-Volatile Organic Compounds (SVOCs)
PFOA (40.1 ng/L)
Total PFOA + PFOS (40.1 ng/L)
bi s(2- E thy I hex y I )phthal ate (6 ug/L)
N
A
Figure 4-2
Conceptual Plan for Alternative 4
Two-Stage Reactive
Treatment Zone
L&RR Superfund Site
OU 2 Remedial Investigation/
Feasibility Study
North Smithfield, Rhode island
Legend
Bedrock Multi-Level System
Bedrock Borehole
Monitoring Well
Overburden Multi-Level System
Residential Well
Surveyed Extent of Wetland
Features (July 2016)
Approximate Extent of Wetland
Features
Interpreted Parcel Boundaries
Approximate Extent of
Exceedances in Groundwater
-¦1
¦ 1,4-Dioxane
L.j
Other VOCs
¦ PFAS
Metals
W ¦ 90
r"l SVOCs
L.J
Proposed Two-Stage Permeable
Reactive Treatment Zone
Stage 1: Potassium Persulfate
Stage 2: Activated Carbon
Potassium Persulfate Targeted
Injection Areas
Approximate Area of Potential
Wetland Disturbance
1 inch = 300 feet
0 75 150 300
Feet
©
©
WOODARD
&CURRAN
Project #: 229620
Map Created: June 2020
Third Party GIS Disclaimer: This map is for
reference and graphical purposes only and
should not be relied upon by third parties for
any legal decisions. Any reliance upon the
map or data contained herein shall be at the
users' sole risk. Data Sources: USGS,
Town of North Smithfield, Rl
-------
Landfill & Resource Recovery
Operable Unit 2
Record of Decision
April 2021
Appendix D - ARARs Tables
Alternative 3: Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Alternative 3: Location-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Alternative 3: Action-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Alternative 4: Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Alternative 4: Location-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Alternative 4: Action-Specific Applicable or Relevant and Appropriate Requirements and To Be
Considered Criteria
Appendix D - ARARs Tables
Page | 111
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Groundwater
Safe Drinking Water Act (SDWA) -
National Primary Drinking Water
Regulations, Maximum Contaminant
Levels (MCLs) (40 CFR Part 141,
Subparts B and G)1
Relevant and
Appropriate
Establishes MCLs for a number of common
organic and inorganic contaminants applicable
to public drinking water supply systems. MCLs
are relevant and appropriate for Site
groundwater because groundwater in the
vicinity is used as a drinking water supply.
MCLs were considered in the development of cleanup
levels. Outside of the compliance boundary of the landfill,
cleanup levels will be met through groundwater extraction
and treatment. Institutional controls (ICs) will prevent
exposure to groundwater that exceeds these standards
until groundwater cleanup standards are achieved.
Groundwater
SDWA - National Primary Drinking
Water Regulations, MCLGs (40
CFR Part 141, Subpart F)
Relevant and
Appropriate
for non-zero
MCLGs only
Establishes Maximum Contaminant Level
Goals (MCLGs) for public drinking water
supply. MCLGs are health goals for drinking
water sources. Non-zero MCLGs are relevant
and appropriate.
Non-zero MCLGs were considered in development of
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through
groundwater extraction and treatment. ICs will prevent
exposure to groundwater that exceeds these standards
until groundwater cleanup standards are achieved.
Groundwater
Health Advisories (EPA Office of
Drinking Water)
To Be Considered
Health Advisories are estimates of risk due
to consumption of contaminated drinking
water; they consider non-carcinogenic
effects only. To be considered for
contaminants in groundwater that may be
used for drinking water.
These health advisories were considered in the
development of cleanup levels. Outside of the
compliance boundary of the landfill, cleanup levels will
be met through groundwater extraction and treatment.
ICs will prevent exposure to groundwater that exceeds
calculated risk- based standards developed using this
guidance until groundwater cleanup standards are
achieved.
Groundwater
USE PA Risk Reference Doses
(RfDs)
To Be Considered
Risk RfDs are estimates of daily exposure
levels that are unlikely to cause significant
adverse non-carcinogenic health effects over a
lifetime.
RfDs were used to characterize human health risks due to
non-carcinogens. Outside of the compliance boundary of
the landfill, cleanup levels will be met through
groundwater extraction and treatment. ICs will prevent
exposure to groundwater that exceeds calculated risk-
based standards developed using this guidance until
groundwater cleanup standards are achieved.
1 For any COCs with Rhode Island MCLs set forth in Section 1.6 of the Rhode Island Public Drinking Water Regulations (216-RICR-50-05-1) and Section 2.11 of the Rhode
Island Private Drinking Water Systems Regulations (216-RICR-50-05-2), the Rhode Island MCLs are the same as the SDWA federal MCLs.
Appendix D - ARARs Tables
Page | 112
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Groundwater
USEPA Carcinogenic Assessment
Group (CAG) Potency Factors
To Be Considered
Used to calculate the incremental cancer risk
from contaminant exposures.
These factors were used to calculate incremental cancer
risk from exposure to contaminants. Outside of the
compliance boundary of the landfill, cleanup levels will be
met through groundwater extraction and treatment. ICs
will prevent exposure to groundwater that exceeds
calculated risk-based standards developed using this
guidance until groundwater cleanup standards are
achieved.
Groundwater
Human Health Assessment Cancer
Slope Factors (CSFs)
To Be Considered
CSFs are estimates of the upper-bound
probability of an individual developing cancer as
a result of a lifetime exposure to a particular
concentration of a potential carcinogen.
These factors were used to compute the individual
incremental cancer risk resulting from exposure to
carcinogenic contaminants. Outside of the compliance
boundary of the landfill, cleanup levels will be met
through groundwater extraction and treatment. ICs will
prevent exposure to groundwater that exceeds
calculated risk- based standards developed using this
guidance until groundwater cleanup standards are
achieved.
Groundwater
Guidelines for Carcinogenic Risk
Assessment (RPA/630/P-03/001F)
To Be Considered
These guidelines provide guidance on
conducting risk assessmentsinvolving
carcinogens.
These guidelines were used to calculate potential
carcinogenic risks caused by exposure to contaminants.
Outside of the compliance boundary of the landfill,
cleanup levels will be met through groundwater
extraction and treatment. ICs will prevent exposure to
groundwater that exceeds calculated risk-based
standards developed using this guidance until
groundwater cleanup standards are achieved.
Groundwater
Supplemental Guidance for Assessing
Susceptibility from Early-Life Exposure
to Carcinogens (RPA/630/R-03/001F)
To Be Considered
This provides guidance on assessing risk to
children from carcinogens.
This guidance was used to evaluate potential
carcinogenic risks to children caused by exposure to
contaminants. Outside of the compliance boundary of
the landfill, cleanup levels will be met through
groundwater extraction and treatment. ICs will prevent
exposure to groundwater that exceeds calculated risk-
based standards developed using this guidance until
groundwater cleanup standards are achieved.
Appendix D - ARARs Tables
Page | 113
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Chemical-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Groundwater
Rhode Island Rules and
Regulations Pertaining to Water
Resources and Water Quality,
Groundwater Quality Rules (250
RICR-1450-05-3)
Applicable
Sets requirements to protect and restore
groundwater quality to drinking water uses.
Provides classification of groundwater
throughout the state. Sets groundwater
remediation standards for drinking water and
non-drinking water groundwater classes.
These standards were used to develop groundwater
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through
groundwater extraction and treatment. ICs will prevent
exposure to groundwater that exceeds these standards
until groundwater cleanup standards are achieved.
Groundwater
Rhode Island Rules and Regulations
for the Investigation and
Remediation of Hazardous Material
Releases (Remediation
Regulations) (250-RICR-140-30-1)
Applicable
These regulations set remediation standards
for contaminated media resulting from the
unpermitted release of hazardous material.
These standards were used to develop groundwater
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through
groundwater extraction and treatment. ICs will prevent
exposure to groundwater that exceeds these standards
until groundwater cleanup standards are achieved.
Appendix D - ARARs Tables
Page | 114
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Floodplains
Protection of
Floodplains: FEMA
Regulations (44
CFR Part 9)
Floodplains
Executive Order
(EO 11988 and
13690)
Relevant and
Appropriate
FEMA regulations that set forth the policy, procedure, and
responsibilities to implement and enforce Executive Order
11988 and 13690 (Floodplain Management). Requires the
avoidance of impacts associated with the occupancy and
modification of federally-designated 100-year and 500-
year floodplain and to avoid development within floodplain
wherever there is a practicable alternative, and to improve
resilience to current and future flood risks. An assessment
of impacts to 500-year floodplain is required for critical
actions - which includes siting waste facilities in a
floodplain. Requires public notice when proposing any
action in or affecting floodplain or wetlands.
There is no practicable alternative method to work in federal jurisdictional
floodplains while installing and sampling monitoring wells. All practicable
measures will be taken to minimize and mitigate any adverse impacts
within the regulated 500-year floodplain. After completion of the work,
there will be no significant net loss of flood storage capacity and no
significant net increase in flood stage or velocities. Floodplain habitat will
be restored, to the extent practicable.
Public comment was solicited as part of the Proposed Plan
concerning any proposed alteration to floodplain.
Wetlands
Protection of
Wetlands: FEMA
Regulations (44
CFR Part 9)
Wetlands
Executive Order
(EO 11990)
Relevant and
Appropriate
FEMA regulations that set forth the policy, procedure, and
responsibilities to implement and enforce Executive Order
11990 (Protection of Wetlands). Prohibits activities that
adversely affect a federally-regulated wetland unless
there is no practicable alternative and the proposed
action includes all practicable measures to minimize harm
to wetlands that may result from such use.
There is no practicable alternative method to work in federal jurisdictional
wetlands while installing and sampling monitoring wells. All practicable
measures will be taken to minimize and mitigate any adverse impacts.
Erosion and sedimentation control measures will be adopted during
installation and management activities to protect federal jurisdictional
wetlands.
Public comment was solicited as part of the Proposed Plan
concerning any proposed alteration to wetlands.
Appendix D - ARARs Tables
Page | 115
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Wetlands
Clean Water Act
Section 404 (33
U.S.C. § 1344);
Section
404(b)(1)
Guidelines for
discharge of
dredged or fill
material into
waters of the
U.S. (40 C.F.R.
Part 230, 231
and 33 C.F.R.
Parts 320- 323
and 332)
Applicable
For discharge of dredged or fill material into water bodies
or wetlands, there must be no practical alternative with
less adverse impact on aquatic ecosystem; discharge
cannot cause or contribute to violation of state water
quality standard or toxic effluent standard or jeopardize
threatened or endangered (T&E) species; discharge
cannot significantly degrade waters of U.S.; must take
practicable steps to minimize and mitigate adverse
impacts; must evaluate impacts on flood level, flood
velocity, and flood storage capacity. Sets standards for
restoration and mitigation required as a result of
unavoidable impacts to aquatic resources. EPA must
determine which alternative is the "Least Environmentally
Damaging Practicable Alternative" (LEDPA) to protect
wetland and aquatic resources.
Under this alternative installation and management of monitoring
wells/extraction, access ways, and treatment systems may possibly
impact federal jurisdictional wetlands. Activities affecting wetlands will be
conducted in accordance with these requirements including, but not
limited to, mitigation and/or restoration.
Public comment was solicited on EPA's LEDPA finding in the Proposed
Plan.
Other Natural
Resources
Archaeological and
Historical
Preservation Act of
1974 Public Law 93-
291
Applicable
When a Federal agency finds, or is notified, that its
activities in connection with a Federal construction project
may cause irreparable loss or destruction of significant
scientific, prehistoric, historical, or archeological data,
such agency shall notify DOI. Such agency may request
DOI to undertake the preservation of such data or it may
undertake such activities.
If during remedial design or remedial action it is determined that this
alternative may cause irreparable loss or destruction of significant
scientific, prehistoric, historical, or archeological data, DOI will be
notified and these requirements will be complied with.
Other Natural
Resources
National Historic
Preservation Act
(16 USC 470,36
CFR Part 800)
Applicable
A federal agency must take into account the project's
effect on properties included or eligible for inclusion in the
National Register of Historic Places
If the project affects any properties included or eligible for inclusion in
the National Register of Historic Places, these requirements will be
complied with.
Appendix D - ARARs Tables
Page | 116
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Floodplains
RIDEM Rules for Regulations of
Hazardous Waste Management -
Location Standards for
Hazardous Waste Facilities (250-
RICR-140-10-1, Section
1.10.2(18))
Applicable
Rhode Island is delegated to administer the federal
RCRA program through its state regulations. The
standards of 40 CFR 264.18(b) are incorporated by
reference. A facility located in 100-year floodplain
must be designed, constructed, operated and
maintained to prevent washout of any hazardous
waste by 100-year flood, unless demonstrate no
adverse effects on human health or the
environment will result from washout.
Standards for installing and sampling monitoring/extraction
wells, access ways, and treatment systems within the
regulated 100-year floodplain will be attained to prevent
washout of hazardous wastes by a 100-year flood.
Wetlands
Rules and Regulations for
Governing the Administration and
Enforcement of the Freshwater
Wetlands Act, RIDEM, (RIGL
Chapters 2-1-20.1, 42-17.1, and
42-17.6, as amended, 250-RICR-
150-15-1)
Applicable
Sets requirements to prevent the undesirable
drainage, excavation, filling, alteration,
encroachment, or any other form of disturbance or
destruction to a wetland.
Activities involving monitoring and extraction wells,
access ways and treatment systems will be conducted to
minimize the disturbance of state jurisdictional wetland.
Other Natural
Resources
Rhode Island Historic Preservation
Act - Rhode Island General Laws
42-45 et seq.
Applicable
Regulations that address the project's effect on
properties included or eligible for inclusion in the
State/National Registers of Historic Places.
If the project affects any properties included or eligible for
inclusion in the State/National Register of Historic Places,
these requirementswill be complied with.
Appendix D - ARARs Tables
Page | 117
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Discharges to
Surface
Waters/
Stormwater
Controls
Clean Water Act; National
Pollutant Discharge Elimination
System (NPDES); 40 C.F.R.
Parts 122 and 125
Applicable
Establishes the specifications for discharging
pollutants from any point source into the waters of
the U.S. Also, includes stormwater standards for
activities disturbing more than one acre.
If the implementation of Alternative 3 will impact more than
one acre of land, then the groundwater treatment system
will be constructed, operated, and maintained to comply
with applicable provisions of these regulations. Any water
generated from the treatment system and during installation
and management of monitoring/extraction wells will be
treated to meet substantive discharge standards if the water
is to be discharged to surface waters.
Hazardous
Waste - Air
Emissions
National Emission Standards
for Hazardous Air Pollutants
(40 CFR Part 61)
Applicable
These regulations apply to any stationary source of
substances designated as hazardous air pollutants
or that have serious health effects from ambient
exposure to the substance.
Remedial activities, including the groundwater treatment
system will be operated and maintained to comply with
applicable provisions of these regulations.
Hazardous
Waste - Air
Emissions
RCRA, Air Emission Standards
for 40 C.F.R. Part 264, Subpart
AA Process Vents
Applicable
RCRA emissions standards not delegated to the
State. Standards for process vents for systems
that treat RCRA wastes that have total organic
concentrations of 10 ppm or greater.
If the threshold limit is exceeded, the groundwater treatment
system will be operated and maintained to comply with
applicable provisions of these regulations. If air treatment of
VOCs is required, emission standards for any process vents,
if present, will be achieved.
Hazardous
Waste - Air
Emissions
RCRA, Air Emission Standards
for 40 C.F.R. Part 264, Subpart
BB Equipment Leaks
Applicable, ifVOC
emissions over 10
ppm or greater;
Relevant and
Appropriate, if less
than 10 ppm
RCRA emissions standards not delegated to the
State. Standards for air equipment leaks for
systems that treat RCRA wastes that have total
organic concentrations of at least 10% by weight.
If the threshold limit is exceeded, the groundwater treatment
system will be operated and maintained to comply with
applicable provisions of these regulations. Standards for
preventing air emission leaks from treatment systems for
VOCs will be achieved.
Surface Water
Quality/Sediment
Monitoring
Clean Water Act, National
Recommended Water Quality
Criteria (NRWQC) (33 U.S.C. §
1314, 40 CFR Part 131)
Relevant and
Appropriate
NRWQC are provided by USEPA for chemicals for
both the protection of human health and the
protection of aquatic life.
Will be used as performance standards to monitor the
impact of groundwater to surface water.
Appendix D - ARARs Tables
Page | 118
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Air Emissions
Clean Air Act (CAA),
Hazardous Air Pollutants;
National Emission Standards
for Hazardous Air Pollutants
(NESHAPS) (42 USC
§112(b)(1); 40 CFR Part 61)
Applicable
The regulations establish emissions standards for
hazardous air pollutants. Standards set for dust and
other release sources.
Remedial activities, including air discharges from treatment
system and installation and management of
monitoring/extraction wells, will be implemented in
accordance with these rules. No air emissions from
remedial activities will cause air quality standards to be
exceeded. Dust standards will be complied with during
construction and management of the treatment system and
monitoring/extraction wells.
Groundwater
Monitoring
Safe Drinking Water Act;
National Primary Drinking Water
Regulations, Maximum
Contaminant Levels (42 U.S.C. §
300f et seq.; 40 C.F.R. 141,
Subparts B and G)2
Relevant and
Appropriate
Establishes MCLs for a number of common organic
and inorganic contaminants applicable to drinking
water supply systems. MCLs are relevant and
appropriate for Site groundwater because
groundwater in the vicinity is used as a drinking
water supply.
Standards used as groundwater monitoring standards until
groundwater cleanup is achieved.
Groundwater
Monitoring
Safe Drinking Water Act;
National Primary Drinking Water
Regulations, Maximum
Contaminant Level Goals (42
U.S.C. § 300f et seq.; 40 C.F.R.
141, Subpart F)
Relevant and
Appropriate for
non-zero MCLGs
only
Establishes MCLGs for public drinking water
supply. MCLGs are health goals for drinking water
sources. MCLGs are relevant and appropriate.
Standards used as groundwater monitoring standards until
groundwater cleanup is achieved.
Groundwater
Monitoring
EPA Health Advisories
To Be Considered
Federal risk-based standards for groundwater
used as groundwater monitoring standards.
Risk-based standards developed using these
advisories will be used as groundwater monitoring
standards until groundwater cleanup is achieved.
investigation-
Derived Waste
Management of investigation-
derived waste (IDW) from
sampling of monitoring wells
USEPA (OSWER Publication
9345.3-03 FS, January 1992)
To Be Considered
Management of IDW must ensure protectiveness of
human health and the environment.
IDW produced from well installation and sampling will be
managed to comply with these requirements.
2 For the COCs, the Rhode Island MCLs set forth in Section 1.6 of the Rhode Island Public Drinking Water Regulations (216-RICR-50-05-1) and Section 2.11 of the Rhode
Island Private Drinking Water Systems Regulations (216-RICR-50-05-2) are the same as the SDWA federal MCLs.
Appendix D - ARARs Tables
Page | 119
-------
Landfill & Resource Recovery Record of Decision April 2021
Operable Unit 2
Alternative 3:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Groundwater
Remediation
Summary of Key Existing EPA
Comprehensive Environmental
Response Compensation and
Liability Act (CERCLA) Policies
for Groundwater Restoration
(OSWER Directive 9283.1-33,
June 26, 2009)
To Be Considered
Guidance on developing groundwater remedies at
CERCLA sites.
Groundwater remediation standards called for in this
guidance will be satisfied through the installation,
operation, and maintenance of the groundwater
extraction and treatment system. Institutional controls
(ICs) will be established that will prevent exposure to
contaminated groundwater until cleanup standards are
achieved.
Vapor Intrusion
Technical Guide for Assessing
and Mitigating the Vapor
Intrusion Pathway from
Subsurface Vapor Sources to
Indoor Air (OSWER Publication
9200.2-154, June 2015)
To Be Considered
USEPA guidance for addressing vapor intrusion
issues at CERCLA sites.
This guidance will be considered if future building
construction is planned. ICs will require future
construction to evaluate vapor intrusion risk.
Other Natural
Resources
Invasive Species (Executive
Order 13112)
To Be Considered
Federal agencies are directed to prevent the
introduction of invasive species and provide for their
control and to minimize the economic, ecological,
and human health impacts that invasive species
cause when requiring actions that impact the
environment.
If wetland or other restoration is required, invasive
species will not be introduced. Restoration will be
conducted to comply with this Executive Order.
Underground
Injection
Underground Injection Control
Program (40 CFR144,146,
147)
Applicable
Regulation of construction, operation, permitting,
and closure of injection wells used for emplacement
of subsurface fluids. These regulations are used to
prevent contamination of underground drinking water
resources.
Groundwater extraction and treatment will be
implemented and maintained in compliance with these
standards.
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MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management, Definitions
and Standards for Generators
(250-RICR-140-10-1, Sections
1.5 and 1.7)
Applicable
These rules include relevant definitions and outline
requirements for generators, including probations,
hazardous waste determination, generator
notification and identification, fees, generator
quantity determination, manifest, inspections, pre-
transport requirements and other applicable aspects
associated with the generation of hazardous waste
Hazardous waste generated during the implementation of
this alternative, if any, will be managed in accordance with
these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management,
Transporters (250-RICR-140-
10-1, Section 1.8)
Applicable
Outlines requirements for transporters of
hazardous waste.
Any transportation of hazardous waste on-site shall be
managed in accordance with the substantive
provisions of these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management, Issuance,
Renewal and Conditions of
Facility Permits (250-RICR-140-
10-1, Section 1.9)
Applicable
Outlines requirements for treatment, storage, and
disposal facilities.
Any treatment, storage or disposal of hazardous
waste shall be managed in accordance with the
substantive provisions of these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management,
Operational Requirements for
Treatment, Storage and
Disposal Facilities (250-RICR-
140-10-1, Section 1.10)
Applicable
Outlines requirements for treatment, storage, and
disposal facilities.
Any treatment, storage or disposal of hazardous
waste shall be managed in accordance with these
regulations.
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MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards (continued)
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management,
Requirements for Temporary
Transfer and Storage Facilities
(250-RICR-140-10-1, Section
1.11)
Applicable
Outlines requirements for temporary transfer and
storage facilities.
Hazardous waste generated during the
implementation of this alternative, if any, will be
managed in accordance with these regulations.
Underground
Injection and
Groundwater
Monitoring
Rules for the Discharge of
Non-Sanitary Wastewater and
Other Fluid to or Below the
Ground Surface (including
Underground Injection Control
Program Rules), RIDEM
Groundwater Discharge Rules
(RIGL, Chapters 42-35, 46-12,
46-13.1, 42-17.1, and 42-17.6,
250-RICR-150-05-4)
Applicable
Protection and preservation of groundwater
quality of the State of Rhode Island and
prevention of contamination of groundwater
resources from the discharge of non-sanitary
wastewater or other fluid to or below the ground
surface.
Groundwater extraction and treatment will be
implemented and maintained in compliance with these
standards. The discharge of non- sanitary wastewater
or other fluid and the associated groundwater
discharge system shall be located, designed,
constructed, installed, operated, monitored and closed
in a manner to prevent such contamination and to
protect public health and groundwater quality for
current or potential beneficial uses, including use as
an underground source of drinking water.
Groundwater
Monitoring
Rhode Island Rules and
Regulations Pertaining to
Water Resources and Water
Quality, Groundwater Quality
Rules (250 RICR-1450-05-3)
Applicable
Sets requirements to protect and restore
groundwater quality to drinking water uses.
Provides classification of groundwater throughout
the state. Sets groundwater remediation
standards for drinking water and non-drinking
water groundwater classes.
Standards used as groundwater monitoring standards
until groundwater cleanup is achieved.
Groundwater
Rhode Island Public Drinking
Water Regulations (216-RICR-
50-05-1, Section 1.4(B)(3) and
(C))
Relevant and
Appropriate
Establishes requirements for buffer zones around
new public water supply wells.
This regulation will be used to support implementation
of ICs to prevent exposure to contaminated
groundwater.
Stormwater
Stormwater Management,
Design and Installation Rules
(250-Rl CR-150-10-8)
Applicable
Provides standards for planning, designing, and
installing effective stormwater best management
practices to effectively manage impacts of
stormwater and prevent adverse impacts to water
quality, habitat and flood storage capacity.
The groundwater treatment system will be
constructed, operated, and maintained to comply with
the applicable provisions of these regulations.
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MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards (continued)
Surface Water
Quality/Sediment
Monitoring
Rhode Island Water Quality
Regulations (250 RICR-150-
05-1)
Relevant and
Appropriate
Provides water classification for surface waters in
the state and sets ambient water quality criteria
for toxic substances and governs water quality
impacts associated with site activities.
Will be used as performance standards to monitor
surface water and sediments during the remedial
action.
Air Emissions
Air Pollution Control Regulation
No. 7 - Emission of Air
Contaminants Detrimental to
Person or Property (250- RICR-
120-05-7)
Applicable
Prohibits emissions of contaminants that may be
injurious to humans, plant, or animal life or cause
damage to property or that reasonably interferes
with the enjoyment of life and property.
The groundwater treatment system will be constructed,
operated, and maintained to comply with the applicable
provisions of these regulations.
Air Emissions
Air Pollution Control Regulation
No. 9 - Air Pollution Control
Permits (250- RICR-120-05-9)
Applicable
Establishes a preconstruction permitting program
for stationary sources of air pollution and air
pollution control systems.
The groundwater treatment system will be constructed,
operated, and maintained to comply with the substantive
provisions of these regulations.
Air Emissions
Air Pollution Control Regulation
No. 15 - Control of Organic
Solvent Emissions (250-RI CR-
120-05-15)
Applicable
Establishes limits of emissions of volatile organic
compounds from stationary sources.
The groundwater treatment system will be constructed,
operated, and maintained to comply with the applicable
provisions of these regulations.
Air Emissions
Air Pollution Control
Regulation No. 17 - Odors
(250-RICR-120-05-17)
Applicable
Prohibits the release of air contaminants which
may create an objectional odor beyond the
source's property line.
The groundwater treatment system will be constructed,
operated, and maintained to comply with the applicable
provisions of these regulations.
Air Emissions
Air Pollution Control Regulation
No. 22-AirToxics (250-RI CR-
120-05-22)
Applicable
Establishes air emission limits for any stationary
source using or generating a listed toxic
substance.
The groundwater treatment system will be constructed,
operated, and maintained to comply with the applicable
provisions of these regulations.
Solid Waste
Rules and Regulations for Solid
Waste Management Facilities
(250-RICR-140-05-1, Section
1.6(B)(2))
Relevant and
Appropriate
Prohibits a solid waste management facility from
causing groundwater pollution beyond the
operational area of the facility.
The groundwater treatment system will be constructed,
operated, and maintained, and the groundwater will be
monitored, until the groundwater cleanup is achieved.
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MEDIA
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards (continued)
Solid Waste
Solid Waste Regulations No. 2
Solid Waste Landfills (250-
RICR-140-05-2, Sections
2.1.8(F)(1)(a) and (h) and
2.3.5(c)(2))
Relevant and
Appropriate
Establishes requirements for detection
monitoring and provides a buffer around
sanitary landfills with respect to public water
supply wells.
Groundwater monitoring will be conducted in accordance
with the substantive requirements of Sections
2.1.8(F)(1)(a) and (h) for the purpose of monitoring
environmental conditions outside the landfill. Section
2.3.5(c)(2) will be used to support implementation of ICs
to prevent exposure to contaminated groundwater.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Groundwater
Safe Drinking Water Act (SDWA) -
National Primary Drinking Water
Regulations, Maximum Contaminant
Levels (MCLs) (40 CFR Part 141,
Subparts B and G)3
Relevant and
Appropriate
Establishes MCLs for a number of common
organic and inorganic contaminants applicable
drinking water supply systems. MCLs are
relevant and appropriate for Site groundwater
because groundwater in the vicinity is used as
a drinking water supply.
MCLs were considered in the development of cleanup
levels. Outside of the compliance boundary of the landfill,
cleanup levels will be met through in-situ treatment.
Institutional controls (ICs) will prevent exposure to
groundwater that exceeds these standards until
groundwater cleanup standards are achieved.
Groundwater
SDWA - National Primary Drinking
Water Regulations, MCLGs (40 CFR
Part 141, Subpart F)
Relevant and Appropriate
for non-zero MCLGs only
Establishes Maximum Contaminant Level
Goals (MCLGs) for public drinking water
supply. MCLGs are health goals for drinking
water sources. Non-zero MCLGs are relevant
and appropriate.
Non-zero MCLGs were considered in development of
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through in-situ
treatment. ICs will prevent exposure to groundwater that
exceeds these standards until groundwater cleanup
standards are achieved.
Groundwater
Health Advisories (EPA Office of
Drinking Water)
To Be Considered
Health Advisories are estimates of risk due
to consumption of contaminated drinking
water; they consider non-carcinogenic
effects only. To be considered for
contaminants in groundwater that may be
used for drinking water.
These health advisories were considered in the
development of cleanup levels. Outside of the
compliance boundary of the landfill, cleanup levels will
be met through in- situ treatment. ICs will prevent
exposure to groundwater that exceeds calculated risk-
based standards developed using this guidance until
groundwater cleanup standards are achieved.
Groundwater
USEPA Risk Reference Doses
(RfDs)
To Be Considered
Risk RfDs are estimates of daily exposure
levels that are unlikely to cause significant
adverse non-carcinogenic health effects over a
lifetime.
RfDs were used to characterize human health risks due to
non-carcinogens. Outside of the compliance boundary of
the landfill, cleanup levels will be met through in- situ
treatment. ICs will prevent exposure to groundwater that
exceeds calculated risk-based standards developed using
this guidance until groundwater cleanup standards are
achieved.
3 For the COCs, the Rhode Island MCLs set forth in Section 1.6 of the Rhode Island Public Drinking Water Regulations (216-RICR-50-05-1) and Section 2.11 of the Rhode
Island Private Drinking Water Systems Regulations (216-RICR-50-05-2) are the same as the SDWA federal MCLs.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Groundwater
USEPA Carcinogenic Assessment
Group (CAG) Potency Factors
To Be Considered
Used to calculate the incremental cancer risk
from contaminant exposures.
These factors were used to calculate incremental cancer
risk from exposure to contaminants. Outside of the
compliance boundary of the landfill, cleanup levels will be
met through in-situ treatment. ICs will prevent exposure to
groundwater that exceeds calculated risk-based
standards developed using this guidance until
groundwater cleanup standards are achieved.
Groundwater
Human Health Assessment Cancer
Slope Factors (CSFs)
To Be Considered
CSFs are estimates of the upper-bound
probability of an individual developing cancer as
a result of a lifetime exposure to a particular
concentration of a potential carcinogen.
These factors were used to compute the individual
incremental cancer risk resulting from exposure to
carcinogenic contaminants. Outside of the compliance
boundary of the landfill, cleanup levels will be met
through in- situ treatment. ICs will prevent exposure to
groundwater that exceeds calculated risk-based
standards developed using this guidance until
groundwater cleanup standards are achieved.
Groundwater
Guidelines for Carcinogenic Risk
Assessment (RPA/630/P-03/001F)
To Be Considered
These guidelines provide guidance on
conducting risk assessmentsinvolving
carcinogens.
These guidelines were used to calculate potential
carcinogenic risks caused by exposure to contaminants.
Outside of the compliance boundary of the landfill,
cleanup levels will be met through in-situ treatment. ICs
will prevent exposure to groundwater that exceeds
calculated risk-based standards developed using this
guidance until groundwater cleanup standards are
achieved.
Groundwater
Supplemental Guidance for
Assessing Susceptibility from Early-
Life Exposure to Carcinogens
(RPA/630/R-03/001F)
To Be Considered
This provides guidance on assessing risk to
children from carcinogens.
This guidance was used to evaluate potential
carcinogenic risks to children caused by exposure to
contaminants. Outside of the compliance boundary of the
landfill, cleanup levels will be met through in-situ
treatment. ICs will prevent exposure to groundwater that
exceeds calculated risk-based standards developed
using this guidance until groundwater cleanup standards
are achieved.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Groundwater
Rhode Island Rules and
Regulations Pertaining to Water
Resources and Water Quality,
Groundwater Quality Rules (250
RICR-1450-05-3)
Applicable
Sets requirements to protect and restore
groundwater quality to drinking water uses.
Provides classification of groundwater
throughout the state. Sets groundwater
remediation standards for drinking water and
non-drinking water groundwater classes.
These standards were used to develop groundwater
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through in-situ
treatment. ICs will prevent exposure to groundwater that
exceeds these standards until groundwater cleanup
standards are achieved.
Groundwater
Rhode Island Rules and Regulations
for the Investigation and
Remediation of Hazardous Material
Releases (Remediation
Regulations) (250-RICR-140-30-1)
Applicable
These regulations set remediation standards
for contaminated media resulting from the
unpermitted release of hazardous material.
These standards were used to develop groundwater
cleanup levels. Outside of the compliance boundary of
the landfill, cleanup levels will be met through in-situ
treatment. ICs will prevent exposure to groundwater that
exceeds these standards until groundwater cleanup
standards are achieved.
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Location-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Floodplains
Protection of Floodplains: FEMA
Regulations (44 CFR Part 9)
Floodplains Executive Order (EO
11988 and 13690)
Relevant and
Appropriate
FEMA regulations that set forth the policy,
procedure and responsibilities to implement and
enforce Executive Order 11988 and 13690
(Floodplain Management). Requires the avoidance
of impacts associated with the occupancy and
modification of federally-designated 100-year and
500-year floodplain and to avoid development
within floodplain wherever there is a practicable
alternative, and to improve resilience to current and
future flood risks. An assessment of impacts to
500-year floodplain is required for critical actions -
which includes siting waste facilities in a floodplain.
Requires public notice when proposing any action
in or affecting floodplains or wetlands.
There is no practicable alternative method to work in federal
jurisdictional floodplains while installing and sampling
monitoring wells. All practicable measures will be taken to
minimize and mitigate any adverse impacts within the
regulated 500-year floodplain. After completion of the work,
there will be no significant net loss of flood storage capacity
and no significant net increase in flood stage or velocities.
Floodplain habitat will be restored, to the extent practicable.
Public comment was solicited as part of the Proposed
Plan concerning any proposed alteration to floodplain.
Wetlands
Protection of Wetlands: FEMA
Regulations (44 CFR Part 9)
Wetlands Executive Order (EO
11990)
Relevant and
Appropriate
FEMA regulations that set forth the policy,
procedure and responsibilities to implement and
enforce Executive Order 11990 (Protection of
Wetlands). Prohibits activities that adversely affect
a federally-regulated wetland unless there is no
practicable alternative and the proposed action
includes all practicable measures to minimize harm
to wetlands that may result from such use.
There is no practicable alternative method to work in federal
jurisdictional wetlands while installing and sampling
monitoring wells. All practicable measures will be taken to
minimize and mitigate any adverse impacts. Erosion and
sedimentation control measures will be adopted during
installation and management activities to protect federal
jurisdictional wetlands.
Public comment was solicited as part of the Proposed
Plan concerning any proposed alteration to wetlands.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Wetlands
Clean Water Act Section 404
(33 U.S.C.§ 1344); Section
404(b)(1) Guidelines for
discharge of dredged or fill
material into waters of the U.S.
(40 C.F.R. Part 230, 231 and 33
C.F.R. Parts 320- 323 and 332)
Applicable
For discharge of dredged or fill material into water
bodies or wetlands, there must be no practical
alternative with less adverse impact on aquatic
ecosystem; discharge cannot cause or contribute to
violation of state water quality standard or toxic
effluent standard or jeopardize threatened or
endangered (T&E) species; discharge cannot
significantly degrade waters of U.S.; must take
practicable steps to minimize and mitigate adverse
impacts; must evaluate impacts on flood level, flood
velocity, and flood storage capacity. Sets standards
for restoration and mitigation required as a result of
unavoidable impacts to aquatic resources. EPA must
determine which alternative is the "Least
Environmentally Damaging Practicable Alternative"
(LEDPA) to protect wetland and aquatic resources.
Under this alternative installation and management of
monitoring wells, access ways, and injection/re-injection of
remedial amendments may possibly impact federal
jurisdictional wetlands. Activities effecting wetlands will be
conducted in accordance with these requirements including,
but not limited to, mitigation and/or restoration.
Public comment was solicited on EPA's LEDPA finding in the
proposed Plan.
Other Natural
Resources
Archaeological and Historical
Preservation Act of 1974 Public Law
93-291
Applicable
When a Federal agency finds, or is notified, that its
activities in connection with a Federal construction
project may cause irreparable loss or destruction of
significant scientific, prehistoric, historical, or
archeological data, such agency shall notify DOI.
Such agency may request DOI to undertake the
preservation of such data or it may undertake such
activities.
If during remedial design or remedial action it is
determined that this alternative may cause irreparable
loss or destruction of significant scientific, prehistoric,
historical, or archeological data, DOI will be notified and
these requirements will be complied with.
Other Natural
Resources
National Historic Preservation
Act (16 USC 470,36 CFR Part
800)
Applicable
A federal agency must take into account the
project's effect on properties included or eligible
for inclusion in the National Register of Historic
Places
If the project affects any properties included or eligible for
inclusion in the National Register of Historic Places, these
requirements will be complied with.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Floodplains
RIDEM Rules for Regulations of
Hazardous Waste Management -
Location Standards for Hazardous
Waste Facilities (250- RICR-140-
10-1, Section 1.10.2(18))
Applicable
Rhode Island is delegated to administer the federal
RCRA program through its state regulations. The
standards of 40 CFR 264.18(b) are incorporated by
reference. A facility located in 100-year floodplain
must be designed, constructed, operated and
maintained to prevent washout of any hazardous
waste by 100-year flood, unless demonstrate no
adverse effects on human health or the environment
will result from washout.
Standards for installing and sampling monitoring wells,
access ways, and injection/re-injection of remedial
amendments within the regulated 100-year floodplain will
be attained to prevent washout of hazardous wastes by a
100-year flood.
Wetlands
Rules and Regulations for
Governing the Administration and
Enforcement of the Freshwater
Wetlands Act, RIDEM, (RIGL
Chapters 2-1-20.1, 42-17.1, and
42-17.6, as amended, 250-RICR-
150-15-1)
Applicable
Sets requirements to prevent the undesirable
drainage, excavation, filling, alteration,
encroachment, or any other form of disturbance or
destruction to a wetland.
Activities involving monitoring and extraction wells,
access ways and treatment systems will be conducted to
minimize the disturbance of state jurisdictional wetland.
Other Natural
Resources
Rhode Island Historic Preservation
Act - Rhode Island General Laws
42-45 et seq.
Applicable
Regulations that address the project's effect on
properties included or eligible for inclusion in the
State/National Registers of Historic Places.
If the project affects any properties included or eligible for
inclusion in the State/National Register of Historic Places,
these requirements will be complied with.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards
Underground
Injection
Underground Injection Control
Program (40 CFR144,146,147
Applicable
Regulation of construction, operation, permitting,
and closure of injection wells used for
emplacement of subsurface fluids. These
regulations are used to prevent contamination of
underground drinking water resources.
In situ treatment will be implemented and maintained in
compliance with these standards.
Surface Water
Quality/Sedime
nt Monitoring
Clean Water Act, National
Recommended Water Quality
Criteria (NRWQC) (33 U.S.C. §
1314, 40 CFR Part 131)
Relevant and
Appropriate
NRWQC are provided by USEPA for chemicals
for both the protection of human health and the
protection of aquatic life.
Will be used as performance standards to monitor the
impact of groundwater to surface water.
Chemical,
Physical,
and
Biological
Treatment
RCRA, Interim Status Treatment,
Storage, and Disposal Facility
Standards, Chemical, Physical
and Biological Treatment (40
CFR Part 265 Subpart Q)
Relevant and
Appropriate
Standards for operating chemical, physical and
biological treatment systems, including the
proper handling of reagents, system
maintenance, and closure procedures.
In situ treatment will be implemented and maintained in
compliance with these standards.
Groundwater
Monitoring
Safe Drinking Water Act; National
Primary Drinking Water
Regulations, Maximum
Contaminant Levels (42 U.S.C. §
300f et seq.; 40 C.F.R. 141,
Subparts B and G)4
Relevant and
Appropriate
Establishes MCLs for a number of common organic
and inorganic contaminants applicable to drinking
water supply systems. MCLs are relevant and
appropriate for Site groundwater because
groundwater in the vicinity is used as a drinking
water supply.
Standards used as groundwater monitoring standards until
groundwater cleanup is achieved through in situ treatment.
Groundwater
Monitoring
Safe Drinking Water Act; National
Primary Drinking Water
Regulations, Maximum
Contaminant Level Goals (42
U.S.C. § 300f et seq.; 40 C.F.R.
141, Subpart F)
Relevant and
Appropriate for
non-zero MCLGs
only
Establishes MCLGs for public drinking water
supply. MCLGs are health goals for drinking water
sources. MCLGs are relevant and appropriate.
Standards used as groundwater monitoring standards until
groundwater cleanup is achieved through in situ treatment.
4 For any COCs with Rhode Island MCLs set forth in Section 1.6 of the Rhode Island Public Drinking Water Regulations (216-RICR-50-05-1) and Section 2.11 of the Rhode
Island Private Drinking Water Systems Regulations (216-RICR-50-05-2), the Rhode Island MCLs are the same as the SDWA federal MCLs.
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MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
Federal Standards (continued)
Groundwater
Monitoring
EPA Health Advisories
To Be Considered
Federal risk-based standards for groundwater
used as groundwater monitoring standards.
Risk-based standards developed using these advisories
will be used as groundwater monitoring standards until
groundwater cleanup is achieved through in situ
treatment.
investigation-
Derived Waste
Management of investigation-
derived waste (IDW) from
sampling of monitoring wells
USEPA (OSWER Publication
9345.3-03 FS, January 1992)
To Be Considered
Management of IDW must ensure protectiveness
of human health and the environment.
IDW produced from well installation and sampling and in
situ treatment will be managed to comply with these
requirements.
Groundwater
Remediation
Summary of Key Existing EPA
Comprehensive Environmental
Response Compensation and
Liability Act (CERCLA) Policies for
Groundwater Restoration (OSWER
Directive 9283.1-33, June 26, 2009)
To Be Considered
Guidance on developing groundwater remedies at
CERCLA sites.
Groundwater remediation standards called for in this
guidance will be satisfied through in situ treatment.
Institutional controls (ICs) will be established that will
prevent exposure to contaminated groundwater until
cleanup standards are achieved.
Vapor Intrusion
Technical Guide for Assessing
and Mitigating the Vapor Intrusion
Pathway from Subsurface Vapor
Sources to Indoor Air (OSWER
Publication 9200.2-154, June
2015)
To Be Considered
USEPA guidance for addressing vapor intrusion
issues at CERCLA sites.
This guidance will be considered if future building
construction is planned. ICs will require future
construction to evaluate vapor intrusion risk.
Other Natural
Resources
Invasive Species (Executive Order
13112)
To Be Considered
Federal agencies are directed to prevent the
introduction of invasive species and provide for their
control and to minimize the economic, ecological, and
human health impacts that invasive species cause
when requiring actions that impact the environment.
If wetland or other restoration is required, invasive
species will not be introduced. Restoration will be
conducted to comply with this Executive Order.
Appendix D - ARARs Tables
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Alternative 4:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous Waste
Management Definitions and
Standards for Generators (250-
RICR-140-10-1, Sections 1.5 and
1.7)
Applicable
These rules include relevant definitions and outline
requirements for generators, including probations,
hazardous waste determination, generator
notification and identification, fees, generator
quantity determination, manifest, inspections, pre-
transport requirements and other applicable aspects
associated with the generation of hazardous waste.
Hazardous waste generated during the implementation of
this alternative, if any, will be managed in accordance with
these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous
Waste Management,
Transporters (250-RICR-140-
10-1, Section 1.8)
Applicable
Outlines requirements for transporters of hazardous
waste.
Any transportation of hazardous waste on-site shall be
managed in accordance with the substantive provisions of
these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous Waste
Management, Issuance, Renewal
and Conditions of Facility Permits
(250-RICR-140-10-1, Section 1.9)
Applicable
Outlines requirements for treatment, storage,
and disposal facilities.
Any treatment, storage or disposal of hazardous waste shall
be managed in accordance with the substantive provisions of
these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous Waste
Management, Operational
Requirements for Treatment,
Storage and Disposal Facilities
(250-RICR-140-10-1, Section
1.10)
Applicable
Outlines requirements for treatment, storage,
and disposal facilities.
Any treatment, storage or disposal of hazardous waste shall
be managed in accordance with these regulations.
Hazardous
Waste
Rhode Island Rules and
Regulations for Hazardous Waste
Management Requirements for
Temporary Transfer and Storage
Facilities (250-RICR-140-10-1,
Section 1.11)
Applicable
Outlines requirements for temporary transfer
and storage facilities.
Hazardous waste generated during the implementation of
this alternative, if any, will be managed in accordance with
these regulations.
Appendix D - ARARs Tables
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Alternative 4:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards (continued)
Underground
Injection and
Groundwater
Monitoring
Rules for the Discharge of Non-
Sanitary Wastewater and Other
Fluid to or Below the Ground
Surface (including Underground
Injection Control Program Rules),
RIDEM Groundwater Discharge
Rules (RIGL, Chapters 42-35,46-
12, 46-13.1, 42-17.1, and 42-17.6,
250-RICR-150-05-4)
Applicable
Protection and preservation of groundwater
quality of the State of Rhode Island and
prevention of contamination of groundwater
resources from the discharge of non-sanitary
wastewater or other fluid to or below the
ground surface.
In situ treatment will be implemented and maintained in
compliance with these standards. The discharge of non-
sanitary wastewater or other fluid and the associated
groundwater discharge system shall be located,
designed, constructed, installed, operated, monitored and
closed in a manner to prevent such contamination and to
protect public health and groundwater quality for current
or potential beneficial uses, including use as an
underground source of drinking water.
Groundwater
Monitoring
Rhode Island Rules and
Regulations Pertaining to Water
Resources and Water Quality,
Groundwater Quality Rules (250
RICR-1450-05-3)
Applicable
Sets requirements to protect and restore
groundwater quality to drinking water uses.
Provides classification of groundwater
throughout the state. Sets groundwater
remediation standards for drinking water and
non-drinking water groundwater classes.
Standards used as groundwater monitoring standards until
groundwater cleanup is achieved through in situ treatment.
Groundwater
Rhode Island Public Drinking
Water Regulations (216-RICR-50-
05-1, Sections 1.4(B)(3) and (C))
Relevant and
Appropriate
Establishes requirements for buffer zones
around new public water supply wells.
This regulation will be used to support implementation of
ICs to prevent exposure to contaminated groundwater.
Stormwater
Stormwater Management, Design
and Installation Rules (250-RICR-
150-10-8)
Applicable
Provides standards for planning, designing and
installing effective stormwater best
management practices to effectively manage
impacts of stormwater and prevent adverse
impacts to water quality, habitat and flood
storage capacity.
The groundwater treatment system will be constructed,
operated and maintained to comply with the applicable
provisions of these regulations.
Surface Water
Quality/Sediment
Monitoring
Rhode Island Water Quality
Regulations (250 RICR-150-05-1)
Relevant and
Appropriate
Provides water classification for surface waters
in the state and sets ambient water quality
criteria for toxic substances and governs water
quality impacts associated with site activities.
Will be used as performance standards to monitor
surface water and sediments during the remedial action.
Appendix D - ARARs Tables
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Alternative 4:
Action-Specific Applicable or Relevant and Appropriate Requirements and To Be Considered Criteria
MEDIUM
REQUIREMENT
STATUS
REQUIREMENT SYNOPSIS
ACTION TO BE TAKEN TO ATTAIN REQUIREMENT
State Standards (continued)
Solid
Waste
Rules and Regulations for Solid
Waste Management Facilities
(250-RICR-140-05-1, Section
1.6(B)(2))
Relevant and
Appropriate
Prohibits a solid waste management facility from
causing groundwater pollution beyond the
operational area of the facility.
The groundwater treatment system will be constructed,
operated and maintained, and the groundwater will be
monitored, until the groundwater cleanup is achieved.
Solid
Waste
Solid Waste Regulations No. 2
Solid Waste Landfills (250-
RICR-140-05-2, Sections
2.1.8(F)(1)(a) and (h) and
2.3.5(c)(2))
Relevant and
Appropriate
Establishes requirements for detection monitoring
and provides a buffer around sanitary landfills with
respect to public water supply wells.
Groundwater monitoring will be conducted in accordance
with the substantive requirements of Sections 2.1.8(F)(1)(a)
and (h) of these regulations for the purpose of monitoring
environmental conditions outside the landfill. Section
2.3.5(c)(2) will be used to support implementation of ICs to
prevent exposure to contaminated groundwater.
Appendix D - ARARs Tables
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Appendix E - Acronyms and Abbreviations
AC activated carbon
ADAF age-dependent adjustment factors
ADD average daily dose
AO advanced oxidation
AMSL above mean sea level
AOC Administrative Order on Consent
ARAR Applicable or Relevant and Appropriate Requirement
AVS acid volatile sulfides
BERA Baseline Ecological Risk Assessment
bgs below ground surface
BHHRA Baseline Human Health Risk Assessment
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS Comprehensive Environmental Response, Compensation, and Liability Information System
C.F.R. Code of Federal Regulations
cm/sec centimeters per second
COC contaminant of concern / chemical of concern
COPC contaminant of potential concern
COPEC contaminant of potential ecological concern
CSM conceptual site model
CSF cancer slope factor
CTE central tendency exposure
CVOC chlorinated volatile organic compound
CWA Clean Water Act
DCE cis 1,2-dichloroethene
DPT direct-push technology
ELUR Environmental Land Use Restriction
EPA United States Environmental Protection Agency
EPC exposure point concentration
ESD Explanation of Significant Differences
FEMA Federal Emergency Management Agency
FS Feasibility Study
GAC granular activated carbon
GQR Groundwater Quality Rules
GW groundwater
HHRA Human Health Risk Assessment
HI hazard index
HPFM heat pulse flow meter
HQ hazard quotient
ICs institutional controls
ILCR incremental lifetime cancer risk
IUR inhalation unit risk
IDW investigation-derived waste
ISCO in-situ chemical oxidation
LADD lifetime average daily dose
LTM long-term monitoring
MCL Maximum Contaminant Level
Appendix E - Acronyms and Abbreviations
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MEK
methyl ethyl ketone
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPL
National Priorities List
NRWQC
National Recommended Water Quality Criteria
O&M
operations and maintenance
OSWER
Office of Solid Waste and Emergency Response
OU
Operable Unit
PCE
tetrachloroethene
PCSM
post-closure site monitoring
PDI
pre-design investigation(s)
PFAS
per- and polyfluorinated alkyl substances
PFCA
perfluorinated carboxylic acids
PFOA
perfluorooctanoic acid
PFOS
perfluorooctane sulfonate
PFSA
perfluorinated sulfonates
PPE
Personal Protective Equipment
ppm
part per million
PRG
preliminary remediation goal
PRP
potentially responsible party
RAGS
EPA Risk Assessment Guidance for Superfund
RAO
remedial action objective
RCRA
Resource Conservation and Recovery Act
RfC
reference concentration
RfD
reference dose
RI
Remedial Investigation
RIDEM
Rhode Island Department of Environmental Management
RME
reasonable maximum exposure
ROD
Record of Decision
SEM
simultaneously extracted metals
SEMD
Superfund and Emergency Management Division
SLERA
Screening Level Ecological Risk Assessment
SVOC
semi-volatile organic compound
TBC
To-Be-Considered
TCE
trichloroethene
TOC
total organic carbon
UCL
upper concentration limit
U.S.C.
United States Code
USEPA
United States Environmental Protection Agency
USGS
U.S. Geological Survey
VISL
EPA Vapor Intrusion Screening Level
VOC
volatile organic compound
WMA
waste management area
WS&G
Western Sand and Gravel Superfund Site
Appendix E - Acronyms and Abbreviations
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Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
(Remedy Contingency Criteria)
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WOODARD
&CURRAN
COMMITMENT & INTEGRITY
DRIVE RESULTS
MEMORANDUM
33 Broad Street | One Weybosset I
Floor 7
Providence. Rhode Island 02903
TO: Hoshaiah Barczynski (USEPA)
CC: Kathryn Sarsfield (RIDEM)
FROM: Mike Apfelbaum and Alan Benevides
DATE: July 20, 2020
RE: Treatability Study Specific Aims and Performance Goals
Addendum to the Treatability Study Work Plan
L&RR Superfund Site OU 2, North Smithfield, Rl
T 800.426.4262
T 401.273.1007
C /in-l 07Q Q~\Q7
A Revised Treatability Study Work Plan (TSWP) was submitted on February 12, 2020 that presented the
scope of a bench-scale treatability study to evaluate potential treatment technologies for 1,4-dioxane and
per- and polyfluoroalkyl substances (PFAS) in groundwater at the Landfill & Resource Recovery (L&RR)
Superfund Site (Site). Treatability activities are being performed by the L&RR PRP Group as part of the
Remedial Investigation/Feasibility Study (RI/FS) for Operable Unit 2 (OU 2) in accordance with the
Subpart C.II.H. Treatability and Pilot Studies to the Administrative Settlement Agreement and Order on
Consent executed on August 17, 2015. This memorandum is intended to serve as an addendum to the
TSWP, by outlining how treatability data and results will be evaluated to demonstrate proof of concept for
the proposed remedial technologies. Based on a request from the U.S. Environmental Protection Agency
(USEPA) to receive updates on interim test results and participate in working discussions regarding test
procedures, this memorandum also includes a projected schedule (Table 1) developed based on various
treatability study components, and preliminary recommendations for discussions with USEPA
representatives.
Treatability Study Basis and Two-Stage Treatment Zone Remedial Alternative Overview
The basis for this treatability study involves a focused bench-scale evaluation of the treatment
technologies for Remedial Alternative 4 (Two-Stage Reactive Treatment Zone, Institutional Controls,
and Monitoring), which is the preferred alternative presented in the FS Report. The two technologies
used as the basis for this alternative (and the treatability study) are in situ chemical oxidation
(ISCO) using potassium persulfate (KP) and activated carbon (AC) to be injected into the
subsurface in a barrier configuration for treatment of groundwater impacted by volatile organic
compounds(VOCs)1, 1,4-dioxane (primary constituent), and PFAS. The staged configuration of the
proposed barrier utilizes an ISCO-KP array (Stage 1) for primary treatment of target VOCs, 1,4-
dioxane, and select PFAS (primarily the perfluoroalkyl carboxylic acids [PFCAs] subgroup), followed
by the downgradient AC barrier (Stage 2) to
1 The susceptibility of other VOCs present in Site groundwater (benzene, 1,4-dichlorobenzene, 1,1-dichloroethane,
1,2-dichloroethane, cis-1,2-dichloroethene, 1,2-dichloropropane, naphthalene, tetrachloroethene, trichloroethene,
and vinyl chloride) to destruction via ISCO processes and sorption (using AC) is well understood and not proposed
for specific evaluation during the treatability study. The treatability study is focused exclusively on treatment of 1,4-
dioxane and PFAS. Concentrations of VOCs will be measured during the pre-test baseline analytical program to
understand occurrence and concentration for comparison with prior results.
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
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sequester remaining VOCs and PFAS that are not treated via ISCO, notably the perfiuorosuifonic acids
(PFSAs) subgroup of PFAS.
Treatability studies involving the ISCO-KP and AC remedial technologies are currently being
administered at Brown University (Brown), under the direction of Dr. Kurt Pennell. This laboratory based
study will be evaluated relative to the performance goals presented in this memorandum and more
importantly, will be used to recommend and guide the design and implementation of field-scale pilot
studies, if the treatability study results are favorable, as part of pre-design investigation (PDI) activities
following Record of Decision (ROD) issuance. It is also important to note that a subset of treatability
activities have already been completed while others remain in progress, concurrent with finalization of
the FS Report. The treatability program is anticipated to require an additional six months to complete.
Based on this duration and overall test complexity, USEPA previously agreed for treatability activities to
proceed in parallel with the FS to support selection of the two-stage treatment zone remedial alternative
and its incorporation into the Draft Proposed Plan.
Specific Aims of the Treatability Study
Treatability studies involving ISCO and AC are sub-divided into a multi-phase evaluation program
intended to elicit technology performance results and incorporate test data into future pre-design and
design submittals. The two phases of the treatability studies include:
• Phase 1 is a series of batch reactor studies to understand site-specific dosing and reaction
chemistry for the KP oxidant.
• Phase 2 is a series of column tests with multiple KP-AC amendment formulations and Site soil
to simulate the flow of groundwater and testing of key parameters to assess treatment efficacy.
The columns will be operated "in series" with a "lead" KP column followed by a "lag" AC column to simulate
the conceptual two-stage barrier design, configured with the upgradient ISCO-KP barrier (Stage 1) to
intercept and treat 1,4-dioxane, VOCs, and select PFAS (primarily PFCAs) in groundwater, followed by
the downgradient AC barrier (Stage 2) to sequester remaining VOCs and PFAS that are not treated via
ISCO, notably the PFSAs.
The ISCO and AC treatability study will be used to evaluate the effectiveness of these amendments
towards treating 1,4-dioxane and PFAS in groundwater, in support of optimization of future pre-design
activities that notably will involve moving forward with field pilot-testing. Specific aims include:
• Determining effective KP oxidant dosages using Site media that consider important factors such
as contaminant concentration, groundwater temperature and pH, buffering capacity of soils, and
soil and groundwater oxidant demand.
• Selecting the optimal iron activator and dose for KP and evaluating the rate of activation and
residence time in the presence of Site media. Testing involves evaluation of three iron activators:
pyrite, ferrihydrite, and mackinawite. Observations from KP activation and residence will also be
used to preliminarily assess the degree to which additional injections may be required to sustain
on-going oxidation and sorption processes under field conditions during pilot-testing. This
information will also be evaluated from an overall scalability standpoint, that considers
amendment costs and logistical factors during remedy implementation.
• Quantifying contaminant degradation rates following KP oxidation based on interim and end-of-
test chemical analysis and measured column detention times.
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
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Measuring the sorption capacity of the AC provided for testing followed by directly measuring
the retention capacity of AC on soil at the conclusion of the column studies as an indicator of
persistence in the Site subsurface.
Evaluating the potential for reduced hydraulic conductivities and porosity of overburden deposits
that could affect groundwater velocities and flow trajectories in the vicinity of the KP and AC
barrier zones during full-scale implementation. Mechanisms potentially affecting hydraulic
conductivity and porosity include: (i) use of a solid-phase iron activator which may be subject to
dissolution and re-precipitation over time, potentially occupying pore space; and (ii) potential
occupation of pore space in overburden deposits with injectable AC.
Identifying contaminants that are recalcitrant to ISCO (specifically PFSAs) and AC treatment, as
well as transformation of longer-chained PFAS to shorter-chained PFAS following KP oxidation
that are potentially less effectively treated. Test outcomes regarding these potential effects will
be used to optimize future pre-design activities.
Measuring the potential for low pH effects, sulfate migration, and metals mobilization, and their
effect on both short- and long-term groundwater geochemistry. These results will also be used
to plan and mitigate conditions during the design and implementation of the remedial alternative.
In addition to the test methods and procedures outlined in the TSWP, the study maintains a holistic
approach that considers measures to expand various test steps and pursue alternative tests and analyses
intended to strengthen the overall viability of this remedial alternative. Results obtained during the study
will be evaluated and discussed with Brown to determine if supporting analyses and/or modifications to
in-test procedures are required. These supplementary activities, if recommended, will be discussed with
USEPA and the Rhode Island Department of Environmental Management (RIDEM) during the proposed
status check-ins as outlined in Table 1.
Performance Goals for the Treatability Study
The ISCO and AC treatability study will be used to demonstrate the potential for the two-stage reactive
barrier remedy alternative to effectively reduce concentrations of 1,4-dioxane and PFAS via oxidation
and sorption processes, respectively, during the 6-month study period. A converging lines of evidence
approach will be used to evaluate observations, interim test data, and analytical results. Specific
performance goals involving the aims of the ISCO and AC treatability study include:
1. Determine if concentrations of 1,4-dioxane and oxidizable PFAS compounds can be
treated using KP treatment. Pre-test baseline concentrations will be compared with
interim test analyses of 1,4-dioxane and PFAS on an approximate four pore volume
basis, followed by end of test data. Quantified mass reduction estimates will also be
verified using a control column (no KP or iron activator) to evaluate extraneous
contaminant losses for the duration of the study. Contaminant reduction specific
performance goals include the following criteria:
> If at least 80% of 1,4-dioxane and oxidizable PFAS concentrations are
reduced or levels are below preliminary remediation goals (PRGs), within the
estimated 60-day column study, then the ISCO remedy component will be
considered effective. Further optimization of the treatment may be evaluated
in the future to further reduce concentrations.
> If concentrations were not reduced by 80%, but demonstrate reductions
greater than 60%, the results will be considered "positive" towards supporting
overall proof of concept objectives. Steps to optimize the KP technology for
>
WOODARD
&CURRAN
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
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re-evaluation during future treatability studies will be presented in pre-design
investigation work plans as part of the RD phase.
Evaluate if un-oxidizable PFAS fractions (specifically PFSAs) and/or incompletely
oxidized non-target PFAS compounds2 remain following KP treatment and assess
sorption potential in the presence of the AC amendment columns. Pre-test baseline
concentrations and incremental pore volume samples will be used to determine which
amendment (PlumeStop™ or S-PAC) provides the optimal sorption properties.
Quantified sorption estimates will also be verified using a control column with no AC to
evaluate potential changes in contaminant concentrations as Site groundwater is
pumped through the columns.
> If COC concentrations are reduced by at least 80% or are below PRGs within
the estimated 60-day column study, then the AC remedy component will be
considered effective. Further optimization of the treatment may be evaluated
in the future to further reduce concentrations.
> If concentrations were not reduced by 80%, but demonstrate reductions
greater than 60%, the results will be considered "positive" towards supporting
overall proof of concept objectives. Steps to optimize the AC technology for
re-evaluation during future treatability studies will be presented in pre-design
investigation work plans as part of the RD phase.
3. Assess KP, iron activator, and AC amendment stability and longevity using columns to
simulate short-term persistence and provide information on scale-up potential for the
individual reactive zones. These amendments will be assessed under variable
residence times associated with corresponding flow rates in the shallow and deep
aquifer zones for the respective columns. Similar to the above performance indicators,
persistent or incomplete treatment of 1,4-dioxane and PFAS in accordance with the
above criteria, may require refinement of supplemental column studies performed as
part of future pre-design activities. Information used to evaluate stability and longevity
for these amendments will include:
KP Amendment and Iron Activator
> Demonstrating that KP remains "activated" by iron throughout the duration of
the test based on Oxidation-Reduction Potential (ORP) and pH test data that
yield strongly oxidizing ORP levels (greater than 225 mV measured by a
platinum electrode) and sustained low pH levels (less than 4.0 pH standard
units).
> Comparing end of test KP residuals using sulfate to assess the amount of KP
expected to be exhausted based on known KP solubility and the number of
pore volumes flushed through the columns.
>
WOODARD
&CURRAN
2 A total oxidizable precursor (TOP) assay will be performed on column influent and effluent groundwater to assess
for the presence of oxidizable precursors that can undergo transformation to PFAS using heat and activated
persulfate based on the methods presented in Houtz and Sedlak (2012).
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
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> Measuring the retention of iron remaining in the column based on the
measurement of iron leaving the column compared to the amount of iron
anticipated to be exhausted based on the solubility of the iron activator3 and
the number of pore volumes flushed through the columns.
AC Amendments
> The sorption capacity of the PlumeStop™ and the S-PAC will be assessed at
&CURRAN "ie ^ comparing retained PFAS with expected retention
capacities predicted by the sorption isotherm experiments (Phase 1). Modeled
versus actual sorption capacities greater than 80% will be considered
effective, while concentrations not reduced by 80%, but greater than 60% will
be considered "positive" towards supporting overall proof of concept.
4. To assess potential changes in hydraulic conductivity and porosity:
> The differential pressure between the inlet and outlet of the columns will be
measured with a differential pressure transducer. The differential pressure
transducer will be used to monitor for changes in pressure, which, combined
with the flow rate through the columns, will be used to estimate permeability.
> A conservative sodium bromide tracer mixed with Site groundwater will be
pumped through each of the column test configurations at the start of the test
and again at the end. Bromide will be measured using an ion-selective
electrode. The resulting time and electrode response data will be used to
construct tracer breakthrough curves. Bromide ion concentrations will be fit
using a one-dimensional transport model to obtain the pore volume.
If less than a 30% difference is calculated between the baseline and end of test pore
volume estimates, then any changes involving inferred porosity and hydraulic
conductivity will be considered negligible that will also be considered within a factor of
safety for pre-design activities (i.e. field-scale pilot study). The 30% criteria was
selected based on the range of variability resulting from the set-up of the columns and
potential changes in grain size sorting effects that may occur as the number of pore
volumes introduced to the columns increases during the column tests.
5. Identify potential secondary impacts to groundwater quality that may result from
incomplete treatment, undesirable contaminant transformations, and accumulation of
treatment residuals and assess if these impacts are short-lived and transient. These
potential adverse impacts may include sustained low pH conditions from KP oxidation
that overwhelms the buffering capacity of the soils, accumulation of shorter-chain
PFAS compounds (supported by TOP assays), potential for iron mobilization, and
excess sulfate residuals. Potential secondary impacts will be evaluated on an individual
basis to recommend potential mitigation/minimization measures to be considered
during future pilot studies performed during pre-design investigations as part of the RD
phase.
3 Quantification of residual iron levels may be challenging due to catalytic processes involving soluble (Fe2+) and
insoluble (Fe3+) states.
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A comparison of test results and outcomes with these performance goals will be included in the treatability
study summary report.
Treatability Study Schedule
Refer to Table 1 (Treatability Study Summary and Schedule) for a summary of the two primary study
phases. Since the study was initiated following approval of the TSWP, a subset of the Phase 1 batch
WOODARD reactor studies has been completed by Brown in advance of this addendum. This table includes a
synopsis of key test results and preliminary interpretations from completed tests. The status of on-going
test components is included with a preliminary schedule based on Brown's input and current laboratory
access restrictions.
As a follow-up to USEPA's request for involvement during the treatability study, Table 1 includes a column
with proposed status check-in opportunities with USEPA representatives to review interim test results
and participate in working discussions. The proposed future status check-ins are at specific intervals
considering the duration of study procedures, Brown's current laboratory accessibility, and the availability
of interim test results.
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
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Treatability Study Summary and Schedule
L&RR Superfund Site OU 2 Remedial Investigation/Feasibility Study
North Smithfield, Rhode Island
Test Overview / Purpose
Status
Anticipated
Start
Anticipated
Completion
Results Synopsis
Notes/Other
Tentative Check-in with
USEPA & RIDEM
Phase 1 - Batch Reactor Studies
Baseline / Pre-Study Analytical Testing
Establish baseline analytical results for
1,4-dioxane and PFAS.
Complete
Generally consistent with results from pre-ROD
sampling events
Brown University carboy results
approximately 30% lower than low-flow field
sample results
Interim Batch Reactor Check-
In = Early June
{Discussed during the June
4th meeting with EPA and
RIDEM )
Soil Oxidant Demand (SOD)
Quantify the oxidant that can react with
Site soil. Measured by exposing soils to
varying amounts of persulfate until the
persulfate no longer reacts with the soils.
Complete
SOD evaluated using KP at concentrations of 0.5,
1, and 2 grams (g). SOD in upper zone was
<0.884 g/kg of soil and <0.334 g/kg for lower
zone soils. Results < 1 g/kg, notably below
PeroxyChem's default SOD assumption of 1 g
persulfate perkg of Site soil.
Chemical Oxidant Demand (COD)
Quantify the oxidant that can react with
Site aroundwater.
Complete
COD ranged from 0.100 (upper) to 0.035 g/L
(lower).
Buffering Capacity
Measure the ability of Site soils to
neutralize acidity by calculating the
cation exchange capacity (CEC) of soil.
Complete
Lime buffering capacity (LBC) ranged from 194
ppm CaC03 in lowerzone soils to 227 ppm
CaC03 in upperzone soils.
CEC ranged from 4.13 meg/1 OOg in lower unit
soils to 4.60 meg/1 OOg in upper unit soils.
Addition of buffering agent to moderate pH
in future tests may be needed based on the
results of the activation testing described
below.
Activation of Potassium Persulfate (KP)
using Iron
Measure the amount and type of iron
source necessary to activate the KP.
In progress
Week of April 20th
Week of August 10th
Initial testing of the three activators (pyrite,
Mackinawite1, and ferrihydrite) with
deionized (Dl) water performed. Testing
currently underway using the three
activators with Site groundwater. Future
testing will be expanded to include a mixture
of Site soil and groundwater.
Pre-Column Study Check-in =
Late July (Results and next
steps for iron activation of KP;
scheduled for July 22)
Sorption Isotherms
Evaluate the adsorption capacity of
PlumcStop and S-PAC on a mass
basis using multiple concentrations of
PFOAand PFOS.
In progress
Week of April 6th
Week of August 10th
Initial isotherm tests performed using Dl
water. Testing to begin using Site
groundwater, supplemented by COC
spiking, as necessary.
Phase 2 - Column Studies
Shallow (Run#1)
Evaluate 1,4-Dioxane and PFAS
oxidation (KP + selected iron activator)
and residuals/secondary treatment using
two AC amendments. Columns run in
series. Retention capacity of AC also
measured.
Pending
Phase 1
Early August
Early October
(-60 days2)
Start of columns to occur as remaining KP
activation batch tests are completed. Initial
column tests will involve iron activators that
have been subject to each phase of
activation (i.e., Dl water, Site groundwater,
and Site soil and groundwater).
Interim Column Study Check-
In #1 = Mid-September
Control
KP + [Fe] + PlumeStop
KP + [Fe] +S-PAC
Deep (Run#1)
see above
Pending
Phase 1
Late October
Late December
(-60 days2)
Interim Column Study Check-
In #2 = Early December
Control
KP + [Fe] + PlumeStop
KP + [Fe] +S-PAC
Shallow & Deep Duplicate Runs3
Preferred amendment configuration from
initial runs, re-performed to assess run
#1 results.
Pending
Phase 1
Mid-January
Mid-March
(-60 days2)
Interim Column Study Check-
In #3 = Late January
Notes:
1. Supplier of commercially available ferrous sulfide reagent has requested that their product be referred to as "Mackinawite".
2. Brown Univertity's current capabilities include columns and pumps to run three tests at a time (i.e., Control, KP-PlumeStop™, and KP-S-PAC)for one aquifer zone.
It is assumed that the Phase 2 - Column Studies will begin with the shallow zone. Column testing takes approximately 60-days based on groundwater detention
times. At the conclusion of the first suite of column tests, labware will be cleaned prior to adding amendments and Site soil and starting the next series of tests.
Appendix F - Treatability Study Specific Aims and Performance Goals Memorandum
P a g c | 145
-------
Appendix G - Administrative Record Index and Guidance Documents
Appendix G - Administrative Record Index and Guidance Documents
-------
Landfill & Resource Recovery, Inc. (L&RR)
NPL Site Administrative Record
Record of Decision (ROD)
Index
ROD Dated: April 2021
Released: April 2021
Prepared by
EPA New England
Superfund & Emergency Management Division
Appendix G - Administrative Record Index and Guidance Documents
-------
Introduction to the Collection
This is the administrative record for the Landfill & Resource Recovery, Inc. (L&RR) Superfund Site, North
Smithfield, Rhode Island, Operable Unit 2 (OU2) Record of Decision (ROD), dated April 2021. The file
contains site-specific documents and a list of guidance documents used by EPA staff in selecting a response
action at the site.
This record replaces the administrative record file for the OU 2 ROD Proposed Plan dated July 2020. This
record includes, by reference, administrative records for the OU1 ROD, issued September 1988; and the OU1
Explanation of Significant Differences (ESD), issued March 1991. Documents listed as bibliographic sources in
individual reports might not be listed separately in the index.
The administrative record file is available for review at:
Online: https://go.usa.gov/xfQbz
Additional information about the site is also available at www.epa.gov/superfund/lrr.
The EPA is temporarily suspending its Regional Records Centers for public visitors to reduce the risk of
transmitting COVID-19. In addition, many site information repositories are closed and information in these
repositories, including the administrative record file, has not been updated.
The EPA continues to carefully and continuously monitor information from the Centers for Disease Control and
Prevention (CDC), local area health departments, and our Federal partners so that we can respond rapidly as
conditions change regarding COVID-19.
For assistance with access or for questions, contact (note that because of government COVID-19 restrictions
EPA's Offices may not be open to the public during the comment period):
SEMS Records & Information Center
U.S. EPA Region 1 - New England
5 Post Office Square, Suite 100 (mail code: 02-3)
Boston, MA 02109-3912
(617)918-1440 (phone)
R1 ,Records-SEMS@epa. gov (email)
An administrative record is required by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the Superfund Amendments and
Reauthorization Act (SARA).
Questions about this administrative record should be directed to the EPA New England site manager, Hoshaiah
Barczynski (617) 918-1275, barczynski.hoshaiah@epa.gov.
Appendix G - Administrative Record Index and Guidance Documents
-------
AR 66499
Record of Decision (ROD), Operable Unit 2
April 2021
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
657100
RECORD OF DECISION (ROD)
4/15/2021
175
R01: (US EPA
REGION 1)
053-REMEDIAL70531-Remedy
Characterization/05.04-
RECORDOF DECISION (ROD)
ov/src/document/01/6
57100
653736
RESPONSIVENESS SUMMARY
4/15/2021
13
R01: (US EPA
REGION 1)
RPT
053-REMEDIALy0531-Remedy
Characterization/05.03-
RESPONSIVENESS SUMMARIES
UCTL
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53736
653737
LETTER REGARDING CONCURRENCE
WITH RECORD OF DECISION (ROD)
4/12/2021
2
R01: Coit, Janet (Rl
DEPTOF
ENVIRONMENTAL
MGMT)
R01: Olson, Bryan
(US EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/05.01-
CORRESPONDENCE (ROD)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
53737
650458
PUBLIC HEARING TRANSCRIPT FOR
08/12/2020 MEETING
9/22/2020
11
(APEX REPORTING)
MTG
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL
1
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ov/src/document/01/6
50458
650460
EMAIL REGARDING PUBLIC COMMENT
ON THE PROPOSED PLAN (WELLTESTING
RESULT ANDTOLUENE INTOXICATION
INFORMATION ATTACHED)
8/26/2020
4
Richer. Jason
(NORTH SMITHFIELD
(Rl) RESIDENT)
Barczynski, Hoshaiah
(US EPA REGION 1)
EML
053-REMEDIALy0531-Remedy
Characterization/05.03-
RESPONSIVENESS SUMMARIES
UCTL
1
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ov/src/document/01/6
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100014361
EPA PROPOSED PLAN PUBLIC MEETING
PRESENTATION
8/12/2020
26
(US EPA REGION 1)
PUB
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00014361
649272
2020 POST-CLOSURE SITE MONITORING
REPORT
8/1/2020
384
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
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49272
647591
NEWS RELEASE: EPA PROPOSES
GROUNDWATER CLEANUP PLAN FOR
LANDFILL AND RESOURCE RECOVERY,
INC. SUPERFUND SITE IN N. SMITHFIELD,
Rl
7/29/2020
3
(US EPA REGION 1)
PUB
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL
1
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Appendix G - Administrative Record Index and Guidance Documents
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Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
647589
MEMO REGARDING PROPOSED PLAN
PUBLIC COMMENT PERIOD - VIRTUAL
PUBLIC PARTICIPATION MEASURES
7/20/2020
2
Meeks, Sarah (US
EPA REGION 1)
MEMO
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.01-
CORRESPONDENCE
(COMMUNITY RELATIONS)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47589
647559
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
04/01/2020-06/30/2019
7/13/2020
3
Benevides, Alan
(WOODWARD &
CURRAN)
Barczynski, Hoshaiah
(US EPA REGION 1),
Sarsfield, Kathryn
(RIDEM)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
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647545
PROPOSED PLAN
7/1/2020
33
(US EPA REGION 1)
RPT
053-REMEDIALy0531-Remedy
Characterization/04.09-
PROPOSED PLANS FOR
SELECTED REMEDIAL ACTION
UCTL
1
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47545
647596
FEASIBILITY STUDY (FS), REVISED
6/12/2020
416
(WOODARD &
CURRAN)
(L&RR PERFORMING
PRPGROUP
REPRESENTATIVES)
RPT
053-REMEDIALy0531-Remedy
Characterization/04.06-
FEASIBILITYSTUDY REPORTS
UCTL
1
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ov/src/document/01/6
47596
647808
EMAIL REGARDING APPLICABLE OR
RELEVANT AND APPROPRIATE
REQUIREMENTS (ARAR) (EMAIL HISTORY
ATTACHED)
5/28/2020
4
Sarsfield, Kathryn
(RIDEM)
Barczynski, Hoshaiah
(US EPA REGION 1)
EML
053-REMEDIALy0531-Remedy
Characterization/04.05-ARARS
(FS)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47808
100002469
For Regional Superfund Site Teams:
CERCLA Interim Guidance on Public
Engagement During COVID-19
4/28/2020
2
Rll: (U.S. EPA)
LAWS
058-PROGRAM
SUPPORT/0583-Regulatory
Development/B8.4-Directives
and Policy Guidance
Documents
UCTL
11
https://semspub.epa.r
ov/src/document/11/1
00002469
100002476
Memorandum on Virtual Public Hearings
and Meetings
4/16/2020
2
Rll: (Office of
General Counsel)
LAWS
058-PROGRAM
SUPPORT/0583-Regulatory
Development/B8.4-Directives
and Policy Guidance
Documents
UCTL
11
https://semspub.epa.r
ov/src/document/11/1
00002476
647558
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
01/01/2020-03/31/2019
4/7/2020
3
Benevides, Alan
(WOODWARD &
CURRAN)
Barczynski, Hoshaiah
(US EPA REGION 1),
Sarsfield, Kathryn
(RIDEM)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
https://semspub.epa.r
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47558
646140
REMEDIAL INVESTIGATION (Rl) REPORT
4/1/2020
11143
(WOODARD &
CURRAN)
(THE L&RR SITE
GROUP)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.06-
REMEDIAL INVESTIGATION
REPORTS
UCTL
1
https://semspub.epa.r
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Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
647568
REVISED TREATABILITY STUDY WORK
PLAN, SEQUENTIAL TREATMENT USING
IN SITU CHEMICAL OXIDATION AND
SEQUESTRATION
2/1/2020
153
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47568
647557
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
10/01/2019- 12/31/2019
1/7/2020
3
Benevides, Alan
(WOODWARD &
CURRAN)
Barczynski, Hoshaiah
(US EPA REGION 1),
Sarsfield, Kathryn
(RIDEM)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
https://semspub.epa.r
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47557
642582
NEWS RELEASE: EPA COMPLETES REVIEW
OF L&RR SUPERFUND SITE IN N.
SMITHFIELD, Rl
12/20/2019
2
(US EPA REGION 1)
PUB
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
42582
647556
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
07/01/2019-09/30/2019
11/6/2019
2
Benevides, Alan
(WOODWARD &
CURRAN)
Barczynski, Hoshaiah
(US EPA REGION 1),
Sarsfield, Kathryn
(RIDEM)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
https://semspub.epa.r
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47556
647567
HUMAN HEALTH RISK ASSESSMENT
11/1/2019
449
(WOODARD &
CURRAN)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.09-
HEALTH ASSESSMENTS
UCTL
1
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47567
100012177
FIFTH FIVE-YEAR REVIEW REPORT
9/6/2019
50
(US EPA REGION 1)
RPT
053-REMEDIAL, 053-
REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00012177
647566
2019 POST-CLOSURE SITE MONITORING
REPORT
8/1/2019
331
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
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647555
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
04/01/2019-06/30/2019
7/26/2019
3
Benevides, Alan
(WOODWARD &
CURRAN)
Brown, James (US
EPA REGION 1),
Kulpa, Paul (RIDEM),
Barczynski, Hoshaiah
(US EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
https://semspub.epa.r
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47555
647554
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
01/01/2019-03/31/2019
4/22/2019
3
Benevides, Alan
(WOODWARD &
CURRAN)
Brown, James (US
EPA REGION 1),
Kulpa, Paul (RIDEM),
Barczynski, Hoshaiah
(US EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
1
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Appendix G - Administrative Record Index and Guidance Documents
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Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
647562
FLYER FOR DROP-IN INFORMATION
SESSIONS 03/20/2019 AND 03/25/2019
3/20/2019
1
(US EPA REGION 1)
MTG /
Meeting
Documen
t
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.04-PUBLIC
MEETINGS/HEARINGS
UCTL
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632576
NEWS RELEASE: EPA BEGINS REVIEWS OF
THREE RHODE ISLAND SUPERFUND SITE
CLEANUPS THIS YEAR
2/21/2019
2
(US EPA REGION 1)
PUB
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL
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https://semspub.epa.r
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647553
QUARTERLY PROGRESS REPORT,
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION,
10/01/2018- 12/31/2018
1/8/2019
4
Benevides, Alan
(WOODWARD &
CURRAN)
Brown, James (US
EPA REGION 1),
Kulpa, Paul (RIDEM),
Barczynski, Hoshaiah
(US EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/04.07-WORK
PLANS & PROGRESS REPORTS
(FS)
UCTL
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647560
FINAL WATER QUALITY REGULATION
12/20/2018
46
Coit, Janet (Rl DEPT
OF
ENVIRONMENTAL
MGMT)
LAWS
056-SITE SUPPORT/0563-
State/T ribal
Involvement/09.10-STATE
TECHNICAL AND HISTORICAL
RECORDS
UCTL
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631406
LETTER REGARDING QUARTERLY REPORT
FOR REMEDIAL INVESTIGATION /
FEASIBILITY STUDY (RI/FS)
IMPLEMENTATION, 07/01/2018 -
09/30/2018
10/24/2018
4
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0533-Remedial
Act ion/07.06-WORK PLANS &
PROGRESS REPORTS (RA)
UCTL
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100010284
EPA'S MEMO ON ECOLOGICAL RISK
DETERMINATIONS FOR L&RR OU 2
9/12/2018
2
Hoskins, Bart (US
EPA REGION 1)
Krasko, Anna (US
EPA REGION 1)
MEMO
053-REMEDIALy0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE
RISK ASSESSMENTS
UCTL
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https://semspub.epa.r
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100010285
INTERIM FINAL SCREENING LEVEL
ECOLOGICAL RISK ASSESSMENT (SLERA)
AND REFINEMENT
9/7/2018
6232
(WOODARD &
CURRAN)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.10-
ENDANGERMENT/BASELINE
RISK ASSESSMENTS
UCTL
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https://semspub.epa.r
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00010285
100010165
2018 POST-CLOSURE SITE MONITORING
(PCSM) REPORT
8/1/2018
294
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
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Appendix G - Administrative Record Index and Guidance Documents
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Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
100009905
QUARTERLY PROGRESS REPORT FOR
OPERABLE UNIT (OU) 2 REMEDIAL
INVESTIGATION / FEASIBILITY STUDY
(RI/FS) IMPLEMENTATION, REPORTING
PERIOD 04/01/2018 TO 06/30/2018
7/13/2018
4
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0533-Remedial
Act ion/07.06-WORK PLANS &
PROGRESS REPORTS (RA)
UCTL
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100009785
RESPONSES TO COMMENTS REGARDING
WORK PLAN FOR ADDITIONAL SAMPLING
OF PFAS ADDENDUM
6/22/2018
6
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIALy0533-Remedial
Action/07.01-
CORRESPONDENCE (RA)
UCTL
1
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100009702
REVISED REMEDIAL
INVESTIGATION/FEASIBILITY STUDY
(RI/FS) WORK PLAN REGARDING 2018
PRE-ROD SAMPLING
6/7/2018
19
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
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00009702
100009352
WORK PLAN FOR ADDITIONAL
NORTHERN BOREHOLE/MONITORING
WELLS, OPERABLE UNIT (OU) 2,
REMEDIAL 1 INVESTIGATION/FEASIBILITY
STUDY (RI/FS)
5/14/2018
5
Benevides, Alan
(WOODWARD &
CURRAN),
Apfelbaum, Mike
(WOODARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
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00009352
100009353
WORK PLAN FOR ADDITIONAL SAMPLING
OF PER- AND POLYFLUOROALKYL
SUBSTANCES (PFAS)
5/14/2018
10
Benevides, Alan
(WOODWARD &
CURRAN),
Apfelbaum, Mike
(WOODARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
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https://semspub.epa.r
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00009353
100009012
QUARTERLY PROGRESS REPORT FOR
OPERABLE UNIT (OU) 2 REMEDIAL
INVESTIGATION/FEASIBILITY STUDY
(RI/FS) IMPLEMENTATION, REPORTING
PERIOD 01/01/2018 TO 03/31/2018
4/13/2018
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00009012
100003702
PER- AND POLYFLUOROALKYL
SUBSTANCES (PFAS) ANALYICAL RESULTS,
OPERABLE UNIT (OU) 2, REMEDIAL
INVESTIGATION/FEASIBLILTY STUDY
(RI/FS)
3/29/2018
76
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/03.02-
SAMPLING & ANALYSIS DATA
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00003702
100002462
LETTER REGARDING
RECOMMENDATIONS FOR 2018 PRE-
RECORD OF DECISION (ROD) SAMPLING
3/13/2018
12
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00002462
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
100002112
EMAIL REGARDING CONCERNS OF
IMPACT OF CONTAMINATED
GROUNDWATER ON RESIDENTIAL WELLS
2/16/2018
1
Ezovski, Gary
(NORTH SMITHFIELD
(Rl), TOWN OF)
Krasko, Anna (US
EPA REGION 1)
EML
053-REMEDIALy0533-Remedial
Action/07.01-
CORRESPONDENCE (RA)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00002112
100001622
SAMPLING AND ANALYSIS PLAN FOR PER-
AND POLYFLUOROALKYLSUBSTANCES
(PFAS)
1/17/2018
48
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
WP
053-REMEDIALy0533-Remedial
Action/07.02-SAMPLING &
ANALYSIS DATA (RA)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00001622
100001522
QUARTERLY STATUS REPORT QS7
1/10/2018
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0533-Remedial
Act ion/07.06-WORK PLANS &
PROGRESS REPORTS (RA)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00001522
100000652
LETTER REGARDING COMMENT
RESPONSE NO. 2 TO TREATABILITY STUDY
WORK PLAN
11/2/2017
3
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00000652
623313
QUARTERLY PROGRESS REPORT FOR
REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS) IMPLEMENTATIONS
10/19/2017
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
23313
100001501
PFAS GROUNDWATER QUALITY
STANDARD
10/18/2017
7
Coit, Janet (Rl DEPT
OF
ENVIRONMENTAL
MGMT)
LAWS
053-REMEDIALy0533-Remedial
Action/07.01-
CORRESPONDENCE (RA)
UCTL
1
https://semspub.epa.r
ov/src/document/01/1
00001501
622917
REVISED TREATABILITY STUDY WORK
PLAN (10/02/2017 TRANSMITTAL EMAIL
ATTACHED)
9/26/2017
1
Benevides, Alan
(WOODWARD &
CURRAN),
Apfelbaum, Mike
(WOODARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
22917
605883
2017 POST CLOSURE SITE MONITORING
REPORT - 05/01/2016 TO 04/30/2017
8/1/2017
303
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
05883
605828
QUARTERLY SUMMARY REPORT -
04/01/2017-06/30/2017
7/18/2017
6
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
05828
599059
LETTER REGARDING SPRING 2017
SAMPLING RECOMMENDATIONS
COMMENT RESPONSES
6/2/2017
11
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
ADD
053-REMEDIALy0531-Remedy
Characterization/03.02-
SAMPLING & ANALYSIS DATA
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
99059
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
597444
FOURTH QUARTERLY PROGRESS REPORT
FOR REMEDIAL
INVESTIGATION/FEASABILITY (RI/FS)
IMPLEMENTATIONS
4/12/2017
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
97444
597453
MEMO REGARDING
RECOMMENDATIONS FOR SPRING
WETLAND SAMPLING EVENT
3/10/2017
8
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
ADD
053-REMEDIALy0531-Remedy
Characterization/03.02-
SAMPLING & ANALYSIS DATA
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
97453
597448
RECOMMENDATIONS FOR PRE-ROD
GROUNDWATER SAMPLING COMMENT
RESPONSES (WITH ATTACHMENTS)
3/3/2017
32
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
97448
595069
QUARTERLY SUMMARY REPORT -
11/01/2016-12/31/2016
1/11/2017
8
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
95069
595045
QUARTERLY STATUS REPORT# 2 FOR
REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS) IMPLEMENTATION -
07/01/2016 TO 10/31/2016
11/18/2016
9
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
95045
592094
INTERIM FINAL SAMPLING AND ANALYSIS
PLAN (SAP), QUALITY ASSURANCE
PROJECT PLAN (QAPP) AND FIELD
SAMPLING PLAN (FSP)
10/11/2016
1411
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.02-
SAMPLING & ANALYSIS DATA
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
92094
592093
2016 ANNUAL POST CLOSURE SITE
MONITORING REPORT - MAY 2015
THROUGH APRIL 2016
10/1/2016
308
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
92093
587395
QUARTERLY PROGRESS REPORT FOR
REMEDIAL INVESTIGATION/FEASABILITY
(RI/FS) IMPLEMENTATIONS
7/19/2016
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1),
Kulpa, Paul (RIDEM)
RPT
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
87395
587350
INTERIM FINAL REMEDIAL
INVESTIGATION AND FEASIBILITY STUDY
(RI/FS) WORK PLAN
5/23/2016
124
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
87350
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
587351
LETTER PROVIDING RESPONSE TO EPA
AND RIDEM COMMENTS REGARDING
INTERIM FINAL REMEDIAL
INVESTIGATION AND FEASIBILITY STUDY
(RI/FS) WORK PLAN
5/23/2016
206
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
87351
587353
INTERIM FINAL SAMPLING AND ANALYSIS
PLAN (SAP), QUALITY ASSURANCE
PROJECT PLAN (QAPP) AND FIELD
SAMPLING PLAN (FSP)
5/23/2016
1363
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.02-
SAMPLING & ANALYSIS DATA
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
87353
587352
LETTER REGARDING EPA'S APPROVAL OF
INTERIM FINAL REMEDIAL
INVESTIGATION AND FEASIBILITY STUDY
(RI/FS) WORK PLAN (WP) (REVIEW OF
COMMENTS ATTACHED)
4/8/2016
14
Krasko, Anna (US
EPA REGION 1)
Benevides, Alan
(WOODWARD &
CURRAN)
CORR
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
87352
583583
INTERIM FINAL SITE MANAGEMENT PLAN
(SMP)
2/25/2016
29
(WOODARD &
CURRAN)
WP
056-SITE SUPPORT/0561-
Administrative Support/17.06-
SITE MANAGEMENT PLANS &
REVIEWS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83583
583584
INTERIM FINAL SAMPLING AND ANALYSIS
PLAN (SAP)
2/25/2016
1359
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83584
583587
INTERIM FINAL REMEDIAL
INVESTIGATION AND FEASIBILITY STUDY
(RI/FS) WORK PLAN (WP)
2/25/2016
124
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83587
583588
DRAFT REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY (RI/FS) WORK PLAN
(WP) - COMMENT RESPONSE ON
ADMINISTRATIVE SETTLEMENT AND
ORDER ON CONSENT
2/25/2016
34
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIALy0531-Remedy
Characterization/03.01-
CORRESPONDENCE (Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83588
583589
INTERIM FINAL HEALTH AND SAFETY
PLAN (HSP)
2/25/2016
187
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83589
583599
INTERIM FINAL COMMUNITY RELATIONS
SUPPORT PLAN (CRSP)
2/25/2016
12
(WOODARD &
CURRAN)
WP
053-REMEDIALy0531-Remedy
Characterization/03.07-WORK
PLANS & PROGRESS REPORTS
(Rl)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
83599
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
647569
ANALYTICAL REPORT, LAB NUMBER:
L1525461
10/16/2015
59
(ALPHA ANALYTICAL
LABS)
(WOODARD&
CURRAN)
ADD
053-REMEDIALy0531-Remedy
Characterization/04.02-
SAMPLING & ANALYSIS DATA
(FS)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47569
581173
NEWS RELEASE: AGREEMENT ENSURES
GROUNDWATER STUDY AT NORTH
SMITHFIELD, Rl SUPERFUNDSITE
8/19/2015
2
(US EPA REGION 1)
PUB
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.03-NEWS
CUPPINGS/PRESS RELEASES
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
81173
581886
ADMINISTRATIVE SETTLEMENT,
AGREEMENT AND ORDER ON CONSENT
(AOC) FOR OPRABLE UNIT (OU) 02,
REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS) - US EPA REGION 1 CERCLA
DOCKET NO.01-2015-0066
8/10/2015
115
(US EPA REGION 1)
LGL
052-ENFORCEMENT/0522-
Negotiations/10.07-EPA
ADMINISTRATIVE ORDERS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
81886
647565
2015 POST-CLOSURE SITE MONITORING
REPORT
7/1/2015
301
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47565
574353
LETTER REGARDING STATE TRUSTEE
NOTIFICATION OF IMPENDING
NEGOTIATIONS WITH POTENTIALLY
RESPONSIBLE PARTIES (PRP) FOR
REMEDIAL INVESTIGATION/FEASIBILITY
STUDY (RI/FS)
4/8/2015
2
Barmakian, Nancy
(US EPA REGION 1)
Gray, Terry (RHODE
ISLAND
DEPARTMENT OF
ENVIRONMENTAL
MANAGEMENT)
LTR
053-REMEDIALy0531-Remedy
Characterization/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
74353
574354
LETTER REGARDING NATIONAL OCEANIC
AND ATMOSPHERIC ADMINISTRATION
TRUSTEE NOTIFICATION OF IMPENDING
NEGOTIATIONS WITH POTENTIALLY
RESPONSIBLE PARTIES (PRP) FOR
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS)
4/8/2015
2
Krasko, Anna (US
EPA REGION 1)
Finkelstein, Kenneth
(US NATIONAL
OCEANIC AND
ATMOSPHERIC
ADMINISTRATION)
LTR
053-REMEDIALy0531-Remedy
Characterization/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
74354
574355
LETTER REGARDING US FISH AND
WILDLIFE TRUSTEE NOTIFICATION OF
IMPENDING NEGOTIATIONS WITH
POTENTIALLY RESPONSIBLE PARTIES
(PRP) FOR REMEDIAL INVESTIGATION /
FEASIBILITY STUDY (RI/FS)
4/8/2015
2
Krasko, Anna (US
EPA REGION 1)
Munney, Kenneth
(US DOI/US FISH &
WILDLIFE SERVICE)
LTR
053-REMEDIALy0531-Remedy
Characterization/16.01-
CORRESPONDENCE(NATURAL
RESOURCE TRUSTEE)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
74355
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
572038
LETTER REGARDING
RECOMMENDATIONS FOR NEXT STEPS
WORK PLAN - RETRACTION LOT 23
ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) INVESTIGATION
12/22/2014
1
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72038
572037
LETTER REGARDING SUMMARY OF
EXISTING INFORMATION REGARDING
LOT 15 ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) INVESTIGATION
12/9/2014
26
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72037
572009
ANALYTICAL REPORT
11/5/2014
41
(TEST AMERICA)
(WOODARD&
CURRAN INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72009
572039
LETTER SUMMARIZING FIELD
INVESTIGATION ACTIVITIES INVOLVING
POTENTIAL DELINEATION OF
ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) (10/18/2013
ANALYTICAL REPORT ATTACHED)
11/4/2014
194
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72039
565428
FOURTH FIVE-YEAR REVIEW REPORT
9/25/2014
44
(US EPA REGION 1)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65428
572963
LETTER REGARDING
RECOMMENDATIONS FOR NEXT STEPS
LOT 23 ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) INVESTIGATION
9/16/2014
7
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72963
572964
LETTER REGARDING SUMMARY OF
FINDINGS LOT 23 ENVIRONMENTAL
LAND USAGE RESTRICTIONS (ELUR)
INVESTIGATION (WITHOUT
ATTACHMENTS)
7/2/2014
11
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72964
647564
POST-CLOSURE SITE MONITORING
REPORT
7/1/2014
305
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47564
565899
TRANSMITTAL LETTER PROVIDING CD
REGARDING ANNUAL MONITORING
REPORTS ISSUED 2010-2013 [CD NOT
ATTACHED)
5/8/2014
2
Krasko, Anna (US
EPA REGION 1)
Hamilton, Paulette
(NORTH SMITHFIELD
(Rl), TOWN OF)
LTR
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.01-
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65899
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
CORRESPONDENCE
(COMMUNITY RELATIONS)
572011
ANALYTICAL REPORT, DIOXANE VOLATILE
ORGANIC COMPOUNDS (VOC)
4/30/2014
35
(TEST AMERICA)
(WOODARD &
CURRAN INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72011
572070
PROJECT SUM MARY: TIER 1 PLUS DATA
VALIDATION
4/30/2014
3
Switalski, Gloria
(DATA CHECK INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72070
572004
LABORATORY REPORT, 1,4 DIOXANE IN
WATER
4/29/2014
13
(US EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72004
572063
REVISION 1 LEVEL 2 FINAL REPORT FOR
GROUNDWATER
4/29/2014
23
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72063
572065
EPA LABORATORY VOLATILE ORGANIC
ANALYSIS (VOA) IN WATER
4/29/2014
23
(US EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72065
572008
GROUNDWATER DATA ANALYSIS
4/28/2014
199
(TEST AMERICA)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72008
572007
REVISION 1, UDS LEVEL 2 FINAL REPORT
FOR GROUNDWATER METALS
4/16/2014
58
(TEST AMERICA)
(WOODARD&
CURRAN INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72007
572001
ANNUAL DATA VALIDATION SUMMARY,
TEST AMERICA LABORATORIES
4/14/2014
6
Switalski, Gloria
(DATA CHECK INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72001
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
572061
LEVEL 2 FINAL REPORT FOR
GROUNDWATER GENERAL CHEMISTRY
4/9/2014
26
(TEST AMERICA)
(WOODARD &
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72061
572005
UDS LEVEL 2 FINAL REPORT FOR
GROUNDWATER METALS
4/1/2014
26
(TEST AMERICA)
(WOODARD&
CURRAN INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72005
572060
LEVEL 2 FINAL REPORT FOR SURFACE
WATER METALS
4/1/2014
18
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72060
572002
LEVEL 2 REPORT FOR GROUNDWATER
3/31/2014
59
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72002
572031
EPA LABORATORY REPORT REGARDING
VOLATILE ORGANIC ANALYSIS (VOA) IN
WATER
3/31/2014
21
Boudreau, Dan (US
EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72031
572034
EPA LABORATORY DATA ANALYSIS, 1,4
DIOXANE IN WATER
3/31/2014
12
Boudreau, Dan (US
EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72034
572062
LEVEL 2 FINAL REPORT FOR SURFACE
WATER, VOLATILE ORGANIC
COMPOUNDS (VOC)
3/31/2014
33
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72062
572033
EPA LABORATORY VOLATILE ORGANIC
ANALYSIS (VOA) DATA
3/27/2014
1
(US EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72033
572036
EPA LABORATORY DIOXANE DATA
3/27/2014
1
(US EPA REGION 1)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72036
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
572046
SAMPLING AND ANALYSIS PLAN, LOT 23
ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) INVESTIGATION
3/7/2014
65
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.05-WORK
PLANS & PROGRESS REPORTS
(POST REMEDIAL)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72046
572041
TRANSMITTAL LETTER REGARDING
FOLLOW-UPTO RECOMMENDED NEXT
STEPS ON LETTER 11/26/2013 FOR
DELINEATION OF ENVIRONMENTAL LAND
USAGE RESTRICTIONS (ELUR)
INVESTIGATION
12/5/2013
2
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72041
647588
LETTER REGARDING RECOMMENDED
NEXT STEPS FOR ENVIRONMENTAL LAND
USAGE RESTRICTIONS (ELUR)
INVESTIGATION (LAB REPORT OMITTED)
11/26/2013
11
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47588
554641
2013 ANNUAL POST CLOSURE SITE
MONITORING REPORT, PERFORMING
SETTLING DEFENDANTS - MAY 2012
THROUGH APRIL 2013 (11/08/2013
TRANSMITTAL LETTER ATTACHED)
11/1/2013
342
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54641
572003
REVISION 1, LOT 81 (N GRID) ANALYTICAL
RESULTS
10/18/2013
69
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72003
572006
LOT 23 (CARON) ANALYTICAL RESULTS
10/18/2013
139
(TEST AMERICA)
(WOODARD&
CURRAN INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72006
572044
LEVEL 2 FINAL REPORT FOR
GROUNDWATER
10/18/2013
147
(TEST AMERICA)
(WOODARD&
CURRAN)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72044
572045
TABLE 2: WATERLOO ANALYTICAL DATA,
SAMPLE 7/29/2013 - 08/01/2013
8/1/2013
13
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72045
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
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Control
Region
URL
572069
TABLE 1: HYDRAULIC GEOCHEMISTRY
DATA
7/29/2013
2
(LOUIS FEDERICI
ASSOCIATES)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72069
572042
RESPONSE TO AGENCY'S COMMENTS
REGARDING RECOMMENDED NEXT
STEPS ENVIRONMENTAL LAND USAGE
RESTRICTIONS (ELUR) INVESTIGATION
DATED 11/26/2013 AND UPDATED
12/5/2013
2/25/2013
5
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72042
572059
LETTER REGARDING REVISED APPROACH
FROM PREVIOUS VERSION SUBMITTED
ON 08/23/2012 WHICH INCORPORATES
COMMENTS RECEIVED FROM EPA AND
RIDEM ON NOVEMBER 26, 2012
12/3/2012
12
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72059
572054
LETTER REGARDING RIDEM (RIDEM)
COMMENTS ON APPROACH FOR LOTS 15
AND 23 DRAFTED BY WOODARD AND
CURRAN ON 08/23/2012
11/20/2012
3
Jablonski, Gary
(RIDEM)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72054
572057
LETTER REGARDING REVISED APPROACH
FROM PREVIOUS VERSION SUBMITTED
ON 08/17/2011, WHICH INCORPORATES
COMMENTS RECEIVED FROM NOBIS AND
EPA ON 12/6/2011
8/23/2012
12
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72057
572058
LETTER REGARDING UPDATED
INFORMATION ON LANDFILL GAS ISSUE
IDENTIFIED IN THIRD FIVE-YEAR REVIEW
8/17/2012
3
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72058
554640
2012 ANNUAL POST CLOSURE SITE
MONITORING REPORT, PERFORMING
SETTLING DEFENDANTS - MAY 2011
THROUGH APRIL 2012
8/1/2012
338
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54640
577629
LETTER REGARDING APPROACH FOR
DELINEATING EXTENT OF
ENVIRONMENTAL LAND USAGE
RESTRICTIONS ON LOT 15 (KING
PROPERTY) AND 23 (CARON PROPERTY)
11/29/2011
3
Austin, Shelley
(RIDEM)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77629
Appenc
ix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
554639
2011 ANNUAL POST CLOSURE SITE
MONITORING REPORT, PERFORMING
SETTLING DEFENDANTS - MAY 2010
THROUGH APRIL 2011 (09/28/2011
TRANSMITTAL LETTER ATTACHED)
9/1/2011
272
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54639
572056
LETTER REGARDING REVISED APPROACH
FROM PREVIOUS VERSION SUBMITTED
ON 03/04/2010 TO DETERMINE NEED
FOR AND, IF NECESSARY, EXTENTS OF
ENVIRONMENTAL LAND USE
RESTRICTIONS (ELUR) ON LOTS 15 AND
23
8/17/2011
166
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72056
471119
2010 ANNUAL POST CLOSURE SITE
MONITORING REPORT, PERFORMING
SETTLING DEFENDANTS - MAY 2009
THROUGH APRIL 2010
8/1/2010
520
(WOODARD &
CURRAN)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
71119
572048
LETTER PROVIDING RESPONSE TO
COMMENTS REGARDING APPROACH FOR
LOTS 15 AND 23
7/2/2010
3
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72048
572055
LETTER REGARDING REVISED APPROACH
FROM PREVIOUS VERSION SUBMITTED
ON 12/21/2009 TO DELINEATE EXTENT
OF ENVIRONMENTAL LAND USE
RESTRICTIONS (ELUR) ON LOTS 15 AND
23
3/4/2010
3
Benevides, Alan
(WOODWARD &
CURRAN)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72055
572053
LETTER REGARDING L&RR (L&RR )
GROUP'S APPROACH TO DELINEATE
EXTENT OF ENVIRONMENTAL LAND USE
RESTRICTIONS (ELUR) ON LOTS 15 AND
23 (12/22/2009 TRANSMITTAL LETTER
ATTACHED)
12/21/2009
4
Benevides, Alan
(WOODWARD &
CURRAN)
Mcburney, John P
(DE MAXIMIS INC.)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72053
457538
THIRD FIVE-YEAR REVIEW REPORT
9/2/2009
84
(US EPA REGION 1-
OFFICE OF SITE
REMEDIATION &
RESTORATION)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
57538
565873
2009 ANNUAL POST CLOSURE SITE
MONITORING REPORT, 05/2008 -
04/2009 (08/06/2009 TRANSMITTAL
LETTER ATTACHED)
8/1/2009
239
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65873
Appenc
ix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
565872
2008 ANNUAL POST CLOSURE SITE
MONITORING REPORT, 09/2007 -
08/2008 (09/19/2008 TRANSMITTAL
LETTER ATTACHED)
9/1/2008
219
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65872
565896
ANALYTICAL DATA REPORT (11/26/2007
AND 11/14/2007 TRANSMITTAL LETTERS
ATTACHED)
10/30/2007
9
(PREMIER
LABORATORY LLC)
(RIDEM)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65896
565876
2007 ANNUAL POST CLOSURE SITE
MONITORING REPORT (08/14/2007
TRANSMITTAL LETTER ATTACHED)
8/1/2007
206
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65876
577630
LETTER REGARDING PROPOSED SENTINEL
WELLS
1/23/2007
2
Destefano, Matthew
D (RIDEM)
Jasinski, Michael (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77630
572968
LETTERS REGARDING SENTINEL WELL
ACTIVITIES
1/12/2007
3
Fuerst, David (O & M
INC), Mcburney, Jack
(O & M INC)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72968
565870
POST CLOSURE SITE MONITORING
REPORT, 07/2006 - 12/2006 (01/10/2007
TRANSMITTAL LETTER ATTACHED)
1/1/2007
204
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65870
572969
LETTER IN RESPONSE TO EPA REGARDING
RESULTS FOR GROUNDWATER
GEOPROBE SAMPLING RESULTS, DATED
ON 06/12/2006
10/5/2006
9
Fuerst, David (O & M
INC)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72969
577625
LETTER REGARDING REVIEW OF RESULTS
FOR GROUNDWATER GEOPROBE
SAMPLING RESULTS - 06/12/2006
(COMMENTS ATTACHED)
8/7/2006
3
Krasko, Anna (US
EPA REGION 1)
Mcburney, John P
(DE MAXIMIS INC.)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77625
577626
LETTER REGARIDNG GROUNDWATER
GEOPROBE SAMPLING POINTS
(COMMENTS ATTACHED)
7/31/2006
3
Ducharme, Shelley
(RIDEM)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77626
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
577628
REVISED RESPONSE TO 06/15/2006
LETTER OF POST-CLOSURE SITE
MONITORING REPORT, DATEDJULY
THROUGH DEMCEMBER 2005
7/26/2006
2
Fuerst, David (O & M
INC)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77628
577627
RESPONSE TO 06/15/2006 LETTER OF
POST-CLOSURE SITE MONITORING
REPORT, DATEDJULYTHROUGH
DEMCEMBER 2005
7/19/2006
4
Fuerst, David (O & M
INC)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77627
572066
ANALYTICAL DATA REPORT, RESIDENTIAL
WELLS
7/12/2006
34
(PREMIER
LABORATORY LLC)
(RIDEM)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72066
565869
POST CLOSURE SITE MONITORING
REPORT, 01/2006 - 06/2006 (07/14/2006
TRANSMITTAL LETTER ATTACHED)
7/1/2006
245
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65869
572052
FIELD SAMPLING PLAN FOR RESIDENTIAL
DRINKING WATER WELL SAMPLING
6/26/2006
3
Destefano, Sarah R
(RIDEM), Ducharme,
Shelley (RIDEM)
WP
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72052
565884
RESULTS FOR GROUNDWATER
GEOPROBE SAMPLING POINTS
(TRANSMITTAL LETTER ATTACHED)
6/12/2006
12
(O & M INC)
(US EPA)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65884
259321
POST-CLOSURE SITE MONITORING
REPORT-JULYTHROUGH DECEMBER
2005 (03/06/2005 TRANSMITTAL IS
ATTACHED)
3/1/2006
301
(O & M INC)
(L&RR PERFORMING
PRPGROUP
REPRESENTATIVES)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
59321
572946
LETTER REGARDING INSTALLATION OF
SENTINEL WELLS
11/29/2005
2
Fuerst, David (O & M
INC)
(NARRAGANSETT
ELECTRIC CO)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72946
565877
REVISED TECHNICAL MEMO FOR
INSTALLATION OF GROUNDWATER
GEOPROBE SAMPLING POINTS
(TRANSMITTAL LETTER ATTACHED)
10/3/2005
34
(O & M INC)
(US EPA)
MEMO
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65877
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
565885
LETTER REGARDING NORTH SMITHFIELD
PUBLIC WATER SUPPLY WELL AT TIFFT
ROAD (05/16/2000 LETTER AND
07/11/2000 WATER AUTHORITY
MEETING MINUTES ATTACHED)
2/25/2005
8
Cournoyer, James
(SLATERSVILLE (Rl)
RESIDENT)
Krasko, Anna (US
EPA REGION 1)
LTR
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.01-
CORRESPONDENCE
(COMMUNITY RELATIONS)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65885
554636
APPROVAL OF SOURCE WELL LOCATION -
TIFFT ROAD REPLACEMENT WELL
(03/30/2005 TRANSMITTAL AND
04/01/2005 FAX COVER SHEET
ATTACHED)
1/6/2005
5
Aschman, Doris P
(STATE OF RHODE
ISLAND)
Lowe, Robert
(TOWN OF NORTH
SMITHFIELD-TOWN
PLANNER)
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
45636
204878
SECOND FIVE-YEAR REVIEW REPORT
9/28/2004
71
(US EPA REGION 1)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
04878
572064
WELL COMPLETION REPORT,
RESIDENTIAL WELL LOG
8/18/2004
1
(RIDEM)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72064
572068
WELL COMPLETION REPORT,
RESIDENTIAL WELL LOGS - (08/16/1996,
09/03/1998 AND 08/18/2004)
8/18/2004
4
(RIDEM)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72068
259320
POST-CLOSURE SITE MONITORING
REPORT - JANUARY THROUGH JUNE 2004
(09/10/04 TRANSMITTAL AND 09/14/04
RIDEM COMMENT ARE ATTACHED)
8/1/2004
297
(O & M INC)
(L&RR PERFORMING
PRPGROUP
REPRESENTATIVES)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
59320
565883
LETTER REGARDING HOLLISTON SAND
AND GRAVELTEST WELL EXPLORATION
WITH WELL COMPLITION LOG, 2004
(06/13/2006 TRANSMITTAL EMAIL AND
06/09/2006 FAX COVER ATTACHED)
6/15/2004
13
Morino, Theodore J
(MAHER DRILLING &
PUMP SERVICES)
Baillargeon, Paul P
(METCALF & EDDY)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65883
582526
POST-CLOSURE SITE MONITORING
REPORT - 07/2003 TO 12/2003
(02/25/2004TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
2/1/2004
208
(O & M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82526
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
554635
DELINEATION OF AREAS CONTRIBUTING
RECHARGE TO SELECTED PUBLIC-SUPPLY
WELLS IN GLACIAL VALLEY-FILL AND
WETLAND SETTINGS (TRANSMITTAL
LETTERS ATTACHED)
1/1/2004
68
(US DEPTOF
INTERIOR), (US
GEOLOGICAL
SURVEY)
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54635
565871
POST CLOSURE SITE MONITORING
REPORT, 01/2003 - 06/2003 (10/31/2003
TRANSMITTAL LETTER ATTACHED)
10/1/2003
222
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65871
582527
POST-CLOSURE SITE MONITORING
REPORT - 09/2002 TO 12/2002
(04/21/2003 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
4/1/2003
253
(O & M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82527
577610
RESPONSE TO REQUEST FOR MEETING
WITH EPA STAFF ON ISSUES OF
REPLACING TIF FT ROAD WELL AND
POTENTIAL IMPACT OF SITE
9/27/2002
1
Mendoza, Robert E
(US EPA REGION 1)
Yazbak, Edward F
(NORTH SMITHFIELD
(Rl), TOWN OF)
LTR
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77610
572979
POST CLOSURE SITE MONITORING
REPORT (09/04/2002 TRANSMITTAL
LETTER ATTACHED)
9/1/2002
263
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72979
572980
POST CLOSURE SITE MONITORING
REPORT (05/17/2002 TRANSMITTAL
LETTER ATTACHED)
5/1/2002
283
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72980
577608
LETTER REGARDING INDECK
GROUNDWATER MODEL AND PROBLEMS
GENERATED FROM SELECTIVE USE OF
MODEL RESULTS AND
MISINTERPRETATIONS
4/30/2002
2
Ingari, Joseph C
(HYDROSOURCE
ASSOCIATES INC)
Krasko, Anna (US
EPA REGION 1)
LTR
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77608
572974
RESPONSE TO EPA COMMENTS ON
DECEMBER, 2001 POST CLOSURE SITE
MONITORING REPORT
3/29/2002
73
Mcburney, Jack (O &
M INC)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72974
565881
MEMO REGARDING CLARIFICATION
STATEMENT FOR FIVE-YEAR REVIEW
PREPARED SEPTEMBER 1999
12/18/2001
1
Krasko, Anna (US
EPA REGION 1)
Duwart, Roger F (US
EPA REGION 1)
MEMO
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65881
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
572973
POST CLOSURE SITE MONITORING
REPORT (12/31/2001 TRANSMITTAL
LETTER ATTACHED)
12/1/2001
278
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72973
572976
RESPONSE TO EPA COMMENTS ON JUNE,
2001 POST CLOSURE SITE MONITORING
REPORT
10/4/2001
35
Helgason, Thor (DE
MAXIMIS INC)
Krasko, Anna (US
EPA REGION 1)
CORR
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72976
572975
POST CLOSURE SITE MONITORING
REPORT (06/27/2001 TRANSMITTAL
LETTER ATTACHED)
6/1/2001
245
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72975
572955
LETTER REGARDING TIF FT ROAD WELL
AND IMPACT OF INCREASED PUMPING
RATES, INDECK GROUNDWATER MODEL
5/29/2001
1
Destefano, Matthew
D (RIDEM)
Andrews, Daniel J
(NORTH SMITHFIELD
(Rl), TOWN OF)
LTR
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72955
572990
POST CLOSURE SITE MONITORING
REPORT (12/11/2000 TRANSMITTAL
LETTER ATTACHED)
12/1/2000
339
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72990
554633
SIMULATIONS DUPLICATING
GROUNDWATER MODELING
CONTAINING IN GZA MODFLOW REPORT
(05/01/2000 AND 05/16/2000
TRANSMITTAL LETTERS ATTACHED)
4/28/2000
22
(METCALF & EDDY
INC)
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54633
565889
SURFACE WATER QUALITY DATA
(05/31/2000 FAX TRANSMITTAL
ATTACHED)
4/11/2000
22
(STS CHICAGO)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65889
565895
APRIL 200 SURFACE WATER DATA
(07/20/2000 TRANSMITTAL LETTER AND
06/13/200 DATA PACKAGE REVIEWS
ATTACHED)
4/1/2000
67
(DE MAXIMIS INC)
ADD
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65895
565887
EPA SURFACE WATER QUALITY DATA
SUMMARY FOR JANUARY 2000
SAMPLING (02/22/2000 and 02/17/2000
MEMOS ATTACHED)
2/25/2000
48
(US EPA REGION 1)
MEMO
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65887
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
565892
LETTER CONFIRMING DISCUSSIONS
BETWEEN EPA AND L&RR PERFORMING
PARTIES REGARDING SURFACE WATER
QUALITY TESTING
2/4/2000
1
Muench, Gretchen
(US EPA REGION 1)
Cherney, Colburn T
(ROPES & GRAY)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65892
572989
POST CLOSURE SITE MONITORING
REPORT (02/08/2000 TRANSMITTAL
LETTER ATTACHED)
2/1/2000
227
(O & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72989
565894
LETTER IN RESPONSE TO EPA AND RIDEM
(Rl DEM) AND L&RR PERFORMING
PARTIES REGARDING SURFACE WATER
SAMPLING
1/24/2000
3
Helgason, Thor (DE
MAXIMIS INC.)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65894
565893
LETTER REGARDING POSITION OF L&RR
PERFORMING PARTIES REGARDING OILY
STAINING
1/18/2000
2
Cherney, Colburn T
(ROPES & GRAY)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65893
577399
INTERVENOR, TOWN OF NORTH
SMITHFIELD'S MEMONRANDUM OF LAW
PERTAINING TO CERTAIN ZONING AND
LAND USE ISSUES (10/14/1999
TRANSMITTAL LETTER ATTACHED)
10/18/1999
14
(RHODE ISLAND
ENERGY FACILITY
SITTING BOARD)
MEMO
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77399
577606
TRANSMITTAL LETTER FOR SUMMARY
RESULTS OF GROUNDWATER SAMPLING
DATA THROUGH MARCH 1999
9/24/1999
1
Krasko, Anna (US
EPA REGION 1)
Cournoyer, George
(SLATERSVILLE (Rl)
RESIDENT)
LTR
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77606
565882
LETTER REGARDING RIDEM (RIDEM)
REVIEW OF FIVE-YEAR REVIEW DATED
ON 09/1999
9/17/1999
1
Grandchamp, Laurie
(RIDEM)
Krasko, Anna (US
EPA REGION 1)
LTR
053-REMEDIAL/0534-Post
Construction/08.01-
CORRESPONDENCE (POST
REMEDIAL ACTION)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
65882
34977
FIRST FIVE-YEAR REVIEW REPORT
9/10/1999
30
(US EPA REGION 1)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/3
4977
554632
GROUNDWATER FLOW MODEL,
PROPOSED INDECK - NORTH SMITHFIELD,
LLC POWER PLANT [MARGINALIA]
8/1/1999
40
(GZA GEO
ENVIRONMENTAL
INC)
(INDECK- NORTH
SMITHFIELD LLC)
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54632
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
582517
POST-CLOSURE SITE MONITORING
REPORT, 02/1999 TO 05/1999
(06/22/1999 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
6/1/1999
239
(O & M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82517
577603
FOLLOW-UP LETTER TO TELEPHONE
CONVERSATION ON 05/10/1999
REGARDING RESIDENT CONCERN WITH
REGARDS TO FUTURE POTENTIAL
DEVELOPMENT PLANS NEAR
SLATERSVILLE RESERVOIR
5/12/1999
2
Krasko, Anna (US
EPA REGION 1)
Zisiades, George
(NORTH SMITHFIELD
(Rl) RESIDENT)
LTR
056-SITE SUPPORT/0561-
Administrative Support/17.01-
CORRESPONDENCE (SITE
MANAGEMENT)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77603
582518
POST-CLOSURE SITE MONITORING
REPORT, 10/1998 TO 01/1999
(02/18/1999 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
2/1/1999
266
(O & M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82518
582519
POST-CLOSURE SITE MONITORING
REPORT, 06/1998 TO 09/1998
(11/02/1998TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
11/1/1998
204
(O & M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82519
554631
BRIEF SUMMARY OF SITE
HYDROGEOLOGICAL AND ANALYTICAL
INFORMATION
10/7/1998
115
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54631
572959
POST CLOSURE SITE MONITORING
REPORT - FEBRUARY TO MAY 1998
(06/12/1998TRANSMITTAL LETTER
ATTACHED)
6/1/1998
151
(0 & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72959
572961
POST CLOSURE SITE MONITORING
REPORT - OCTOBER 1997 TO JANUARY
1998 (02/06/1998TRANSMITTAL LETTER
ATTACHED)
2/1/1998
184
(0 & M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72961
582525
SUBSIDENCE REPAIR REPORT
(11/141/997 TRANSMITTAL LETTER AND
11/07/1997 MONTHLY PROGRESS
REPORT ATTACHED)
11/1/1997
81
(DE MAXIMIS INC)
RPT
053-REMEDIALy0533-Remedial
Action/07.05-REMEDIAL
ACTION DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82525
259361
CONSENT DECREE WITH SETTLEMENT
AGREEMENT - CA NO 97-0078T
10/3/1997
382
(US DISTRICT
COURT/DISTRICT OF
Rl)
LGL
052-ENFORCEMENT/0522-
Negotiations/10.08-EPA
CONSENT DECREES
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
59361
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
582516
POST-CLOSURE SITE MONITORING
REPORT, 05/1997 TO 07/1997
(10/21/1997 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
10/1/1997
368
(O&M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82516
444734
FINAL INTERIM REMEDIAL ACTION (RA)
REPORT, OPERABLE UNIT (OU) 1
(TRANSMITTAL MEMO ATTACHED)
9/4/1997
28
(DE MAXIMIS INC)
(US EPA REGION 1)
MEMO
053-REMEDIALy0533-Remedial
Action/07.05-REMEDIAL
ACTION DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
44734
582515
POST-CLOSURE SITE MONITORING
REPORT, 01/1997 TO 04/1997
(05/16/1997 TRANSMITTAL LETTER
ATTACHED) [MARGINALIA]
5/1/1997
146
(O&M INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.03-LONG-
TERM RESPONSE REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
82515
551269
FINAL AS-BUILT DRAWINGS - SYNTHETIC
COVER / SLOPE STABILIZATION
REMEDIAL DESIGN (RD) CONSTRUCTION
DRAWINGS, REVISION 5
3/25/1997
35
(SMITH)
(THE L&RR SITE
GROUP)
FIG
053-REMEDIALy0532-Remedial
Design/06.04-REMEDIAL
DESIGN REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
51269
271398
EXPLANATION OF SIGNIFICANT
DIFFERENCES (ESD)
9/16/1996
8
(US EPA REGION 1)
RPT
053-REMEDIALy0531-Remedy
Characterization/05.04-
RECORDOF DECISION (ROD)
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
71398
572957
POST CLOSURE SITE MONITORING
REPORT-APRILTO JUNE 1996
9/1/1996
253
(O&M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72957
647563
POST-CLOSURE OPERATION AND
MAINTENANCE (O&M) PLAN
9/1/1996
244
(DE MAXIMIS INC)
WP
053-REMEDIAL/0534-Post
Construction/08.05-WORK
PLANS & PROGRESS REPORTS
(POST REMEDIAL)
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47563
572962
POST CLOSURE SITE MONITORING
REPORT-JANUARY TO MARCH 1996
(06/11/1996 REVISIONS ATTACHED)
5/1/1996
284
(O&M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72962
577634
POST CLOSURE SITE MONITORING
REPORT - OCTOBER TO DECEMBER 1995
2/1/1996
246
(O&M INC)
(L&RR SITE GROUP)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77634
577633
POST CLOSURE SITE MONITORING
REPORT-JULYTOSEPTEMBER 1995
(11/06/1995 TRANSMITTAL LETTER AND
02/08/1996 MEMO ATTACHED)
10/1/1995
348
(DE MAXIMIS INC)
RPT
053-REMEDIAL/0534-Post
Construction/08.04-LONG
TERM RESPONSE
MONITORING
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
77633
Appendix G - Administrative Record Index and Guidance Documents
-------
Doc. ID
Title
Document
Date
Page
Count
Author
Addressee
Resource
Type
Program Information
Access
Control
Region
URL
647561
CERTIFICATE OF PROMULGATION, RULES
AND REGULATIONS FOR GROUNDWATER
QUALITY
5/29/1992
1
(STATE OF RHODE
ISLAND)
LAWS
056-SITE SUPPORT/0563-
State/T ribal
Involvement/09.10-STATE
TECHNICAL AND HISTORICAL
RECORDS
UCTL
1
https://semspub.epa.r
ov/src/document/01/6
47561
572965
LETTER REGARDING ADMINISTRATIVE
ORDER (10/18/1990 REVISED MAILING
LIST ATTACHED)
2/7/1992
6
Hohman, Merrill S
(Mel) (US EPA
REGION 1)
LTR
052-ENFORCEMENT/0522-
Negotiations/10.01-
CORRESPONDENCE
(ENFORCEMENT/NEGOTIATIO
N)
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
72965
259375
EXPLANATION OF SIGNIFICANT
DIFFERENCES (ESD)
3/8/1991
8
(US EPA REGION 1)
RPT
053-REMEDIAL/0531-Remedy
Characterization/05.04-
RECORDOF DECISION (ROD)
UCTL
1
https://semspub.epa.r
ov/src/document/01/2
59375
444694
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) VOLUME 1 OF 2
6/1/1988
519
(EBASCO SERVICE
INC)
RPT
053-REMEDIAL/0531-Remedy
Characterization/04.06-
FEASIBILITYSTUDY REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
44694
444695
REMEDIAL INVESTIGATION / FEASIBILITY
STUDY (RI/FS) VOLUME 2 OF 2 -
APPENDICES
6/1/1988
613
(EBASCO SERVICE
INC)
RPT
053-REMEDIALy0531-Remedy
Characterization/04.06-
FEASIBILITYSTUDY REPORTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/4
44695
561476
REVISED COMMUNITY RELATIONS PLAN
10/1/1986
27
(EBASCO SERVICES
INC)
(US EPA REGION 1)
RPT
051-COMMUNITY
INVOLVE ME NT/0511-
Community Involvement
Activities/13.02-COMMUNITY
RELATIONS PLANS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
61476
554634
AVAILABILITY OF GROUNDWATER IN
BRANCH RIVER BASIN, PROVIDENCE
COUNTY, RHODE ISLAND (10/15/1998
LETTERS ATTACHED)
12/1/1974
48
(US GEOLOGICAL
SURVEY)
RPT
056-SITE SUPPORT/0561-
Administrative Support/17.07-
REFERENCE DOCUMENTS
UCTL
1
https://semspub.epa.r
ov/src/document/01/5
54634
Key:
ADD-Analytical Data Document
CORR - Correspondence
EML- Email
FIG - Figure/Map/ Drawing
LAWS - Laws/Regulations/Guidance
LGL-Legal Instrument
LTR- Letter
MEMO - Memorandum
MTG - Meeting Document
PUB - Publication
RIDEM - Rhode Island Department of Environmental
Management
RPT- Report
UCTL- Uncontrolled
WP-Work Plan
Appendix G - Administrative Record Index and Guidance Documents
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