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'Other: ____.:~;TATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS s, 3 .10

DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 75 Davis Street - 204 Cannon Building Providence, R.I. 02908

28 February 1984

Mr. John Moebes, Chief Waste Response and Compliance Branch U.S. Environmental Protection A~ency

John F. Kennedy Federal Building Boston, MA 02203

Dear Mr. Moebes:

Enclosed is a copy of my comments which were presented at the public meeting on Western Sand & Gravel on 23 February 1984. Please incorporate these com­ments as a part of the official record.

0 We noted that both the EPA toxologist and the Center for Disease Control have once again evaluated the data regarding the risk to public health of contaminated water consumption. While the reports are positive, there are still uncertainties. Our concern is that the Center for Disease Control cannot clearly decide whether or not to advise individuals to drink or to avoid contaminated water.

Since we are only talking about seven wells which are contaminated, I strong­ly reiterate that the position of this Department is to provide temporary water supply to those individuals with contaminated wells. It is a small cost and given the uncertainty will minimize concern if followed through.

Very truly yours,

~~;tN~Barr • Muller, Chief

( Div n of Air and Hazardous Materials

BWM:tg Enc.

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STATD\J::NT TO TilE llNlTF.D STATES ENVIRONMENTAL PROTECTION AGENCY

RHODE ISLAND DEP,\RHIENT OF ENVIRONHENTAL MANAGENENT

\.JESTERN SAND AND GRAVEL RENEDIAL INVESTIGATION/FEASIBILITY STUDY

23 February 1984

I am Barry W. Muller, Chief of the Division of Air and Hazardous Ma­

terials, Rhode Island Department of Environmental Management. The follow­

ing comments are a statement of the position of the Department regarding the

Remedial Investigation/Feasibility Study (RI/FS) conducted by Arthur D. Lit ­

tle Company concerning Western Sand a nd Grave l haza rdous \vas t e sHe.

To date, DEM has expended over $307,000 in cleanup, site investig~ tion,

and site r ~rnediation activities . Most recently, the Sta t e expend~d over

$60,000 in the installation and operation of the recirculation system which

has effectively retarded contaminant flow to the brook and aquifer.

As a result of Superfund requirements, the RI/FS was most recently con­

ducted. The recommendations of that study are as follows:

1. Supply water to 50 domestic dwellings within the "affected

area."

2. Excavate and dispose of 400 yd. 3 of contaminated soil from

three loca'tions on the site (Area A, B, and C, Figure 4-6).

3. Phase out the existing recirculation system over a twenty-

four month period. Removal and disposal of all associated

equipment and materials.

4. Grade the site (lagoon area).

5. Fer.ce the s i te. The area is approximately 9.25 acres.

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6. Placards around perime ter of fence. ~ TO ·.

7. Honitodng program for a fifte en- year period with semi-ODE J

annual sampling from selected wells and surface water m A: :

locations.

The Department takes cxception .with some of these recommendations be­

lieving in essence the study used assumptions that are not above question.

The follO\~ing is the position of the Depar tment of Env ironmental Manage- Mu l

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ment. A permanent supply of water to 60 land parcels within the "affected sta 1

·.area" should be provided. The study only estimated that the supply should ·.on ;

be to 50 dwellings. The real estate survey conducted as a part of the RI/FS ng

identified 42 improved residential and commercial parcels and 18 unimproved ; e .

within the impacted area. Drinking water should be supplied to all of the5e 8C I

parcels. \Vhile not specified in the ::;tudy, \\ater must be brought to the tap ~ a

0 edof the 42 improved parcels.

It is firmly believed that a temporary water supply to those individuals >e I

with contaminated water must be provided until the permanent water supply is t :

in place.Based upon our review of the RI/FS, previous knowledge of the site, and

earlier consultant studies, it is recommended that between 1600 to 5000 cubic

yards of contaminated material be removed from four locations on the site

(Area A, B, C, and E of Figure 4-6 of the RI/FS). In addition·, provision for

additional removal should be in place as a contingency in the event more

contaminated material is discovered.

The RI/FS estimated that 400 cubic yards of contaminated soil be re­

moved. The precision of that figure is uncertain and is the lowest recom­

mended amount of that portion of the study. The Department reco~~ends that

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,. a larger volume of material be removed including the area that was once pit

03. This pit ~as filled in by Mr. Cardi prior to the Environmental Protec­

tion Agency (EPA) or the Rhode Isl and Department of Environmental Management

(RIDEM) r e1noval activities at the s~~e. Evid ence of this contamination was

clear when the recirculation system was installed. Prior to that activity,

a study by Goldberg Zoino Associates in June 1981 recomme nd ed removal of be­

tween 2000 to 4000 cubic yards of contaminated mat erial fr om the area north

of pit 04, i.e. pit #3.

The RI/FS specifies that the amount of material to be considered for i. i.

removal varies from 400 to over 20000 cubic yards. For sludges and adja­

cent contaminated soil, which represent a continued source of contamination,

removal is the only opt ion. To place a fixed number upon removal \~ithout

actual excavation, testing and analysis is short - sighted and restrictive.

We recommend that at least 1600 and up to 5000 cubic yards of excavation

~ and removal be planned for in order to assure as complete removal of a con­

tinued source of contamination as possible. That figure can always be

factored upward or downward as warranted by actual conditions.

The removal and off-site disposal of the major contaminant sources re­

maining on-site will reduce the duration and magnitude of contaminant release

to the environment. Although the study's model predicts that contaminant

d.ischarge to surface waters will be below EPA Ambient Water Quality Criter­

ia for Fresh\vater Fish Species, impacts on other aquatic and terrestrial

species were not directly assessed. Further, continual discharge to the

brook, swamp, and reservoir will act to restrict the recreational use of

these areas. Recent test data shows 334 ppb of VOC discharge to the brook.

Site closure without significant contaminant source removal will have a

more damaging effect on property values and future land use potential.

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The renoval and djsposal of an increased volume of contaminated material

from the site ~o•ill act as a se~fety m<:' nsure against inlterent and recognized

limitations of the model cmp l oyr>d , calculation of source strength and the

National Contingency Plan.

With regard to the recirculation system, the Department recommends that

the contemplated phaseout of the recirculation system be taken at a two-

year minimum. Its r emoval must be based upon cessation of r emoval by the

system of the non-aqueous phase layer of contaminants. In addition, if

temporary water supplies are not provided, the system phaseout should not

" Allbe initiated uritil the permanent drinking water supply is in place.

equipment and materials associat ed with the recirculation system must be

dismantled, removed and properly disposed of following system phaseout.

It is clear that by including the recirculation system as a part of

the rl:mcclial action, the costs of the system, its operation, and mainten­

ance are eligible for reimbursement. EPA has committed to removal and dis­

posal of all accumulated hazardous wastes in the storage tank. It is DEM's

hope that EPA will reimburse the state of Rhode Island for costs incurred

for the recirculation system.

The report recommends grading the site to reduce the possibility of

direct contact with any residual contamination that may remain. The Depart­

ment recommends grading, learning, and seeding of the lagoon areas following

removal of contaminated material. This will not only limit direct contact,

but will act to reduce rainwater infiltration and will control contaminant

runoff and soil erosion.

The Department agrees with the RI/FS recommendation of fencing the site;

an area of 9.25 acres. This area represents the property used in the past

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for \\'aste disposal, location of the recirculation system and the place \\•here

c ontamin~ted soils will r emain.

The Department agrees that the f enced area of the site should be pla­

carded. Hot-1ever, it is felt that \va'rning signs must also be placed in the

area of the brook, swamp, and mouth of the reservoir to protect unsuspect­

ing individuals from consuming or having direct contact with ,,•ater which

does not mee t EPA water quality standards.

Finally, the Department reco~nends that a monitoring program continue

until a sustained and substantial decrease in contaminant levels is reached.

Sampling locations will include wells, the brook, swamp, and the reservoir.

The emphasis of the monitoring program will be to evaluate the impact on

surface waters and to ~ssess groundwater contamination trends.