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REVIEW AND EVALUATION OF

CLOSURE PLANS FOR

LANDFILL AND RESOURCE RECOVERY INC

NORTH SMITHFIELD RI

Sutaitted by

WHITMAN BOWARD INC 45 Willi Strt

Wlleale y Maaeacbuae tta OZ181

MARCH 30 1981

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~====------==-=====--------~=====---=----=~=T==_=====c----

_---- (-~middot- _ - WHITMAN amp HOWARD NC ~1 _Engineers and Architects2~ 45 WILLIAM STIUIET WILUSLIY MASS 021SI bull TIL 17middot217middot5000 -middotshy~middot--middot-shymiddot-bullD ~ -middot- - 0shyMarch 30 1981____ =_ ___ -middot- _ ~ A l otio

__ ~ Mr Bar ry w Muller Princi pal Engineer State of Rhode Ialand Department of Environmental Management Division of Air and Hazardous Materiala 75 Davie Street - 204 cannon Building Providence R I 02908

Dear Mr Muller

We are pleased to submit herewith our report on our review of the closure plan for the hazardous waste portion of the landfill operated by Landfill and Reaource Recovery Inc in North Smithfield R I

The text of the report details the review ite findingbull and our recoaaendatione A simplified euary etatent would be that in our opinion the Cloaure Plan bullubbullitted by L amp RR ia unacceptable in that it doea not addre cloeure of the hazardous waete portion of the landfill ae a eeparate isaue

we would be pleased to discuss this report vi th you at your convenience and we appreciate the opportunity to be of eervice to the Department of Envi ronmental Management

Very truly yours

WHITMAN amp HOWARD INC

~middotcent~1~~it- J~anR Brlg Asaociate - Bydrogeoloqist

Steven L Dean Manager Groundwater Management systems

JRB pdd

TABLE OF CONTENTS

1 0 INTRODUCTION

11 General 1 2 Purpoae and Authority 1 3 scope of work

2 0 BASELINE DATA

21 General 7 2 2 Site Content 9 2 3 Previoua Inveatigationa and Aaaeaamenta 11 24 Exiating Conditionbull and Oper ationbull 16

3 0 REVIEW AND EVALUATI ON

31 Gene ral 18 3 2 Reatricte4 Acebullbullbull and

Activity Separation 20 3 3 vertical Expanaion 22 3 4 Activity Separation 26 3 5 Leachate Collection Syltem 27 3 6 Groundwater Monitoring 28 3 7 amprthcover and Liner Maintenance 29

4 0 FINDINGS AND RECOMMENDATIONS

41 r indinga 30 4 2 RecOIIIDenda tiona 31

PLATES

Locua Plan 7A Sectionbull 20A Sectionbull 208 Sectionbull 20C Leachate Collection Syatem Alternative 27A

1 0 INTRODUCTION

11 ~ By an order iuued on June 20 1980 the

State of Rhode Illand Department of Environmental Manaqement

Divbion of Air and Hazardous Materiala (hereinafter referred

to as DEM) required Landfill and Resource Recovery Inc

(hereinafter referred to as LampRR) to prepare a closure plan

for their landfill facility located in North Smi thfield

Rhode leland The order was iasued

to ensure that the highest de9ree of attention is provided to protect the public health and environment from any adverse consequences caused by LampRRs oper ation

and it contained the following di rectives

11 1 By July 18 1980 install one aulti-level well at the toe of the refuse dope at a point equidistant between the two presently installed BARCAD type wells which were installed by the State in February 1980

2 By July 15 1980 complete and aubmit to DEM for approval a full ground water topotiJrampphic aurvey of the entire landfill d te

3 By Auguat 1 1980 aubmit a plan to the DEM preshyacribinq baaed on the apecificationa of the ground water aurvey the planned location of a network of multi-level or BARCAD-type wella at bedrock or three timea the number of cluater vella The well referred to in section 1 above can be considered aa one of the multi-level vella or theae cluater wella

4 By August 15 1980 submit a plan for closure of the entire facility

5 By September 1 1980 have all wells installed

LampRR appealed the order and hearings on this matter

began on July 24 1980 The original hearing officer

excused himself on Auquat 4 and the hearings were continued

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under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

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f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

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feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

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5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

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urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

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d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

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1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

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While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

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0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

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In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

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LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

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report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

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A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

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e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

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ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

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Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

nz C6

REVIEW AND EVALUATION OF

CLOSURE PLANS FOR

LANDFILL AND RESOURCE RECOVERY INC

NORTH SMITHFIELD RI

Sutaitted by

WHITMAN BOWARD INC 45 Willi Strt

Wlleale y Maaeacbuae tta OZ181

MARCH 30 1981

~

~====------==-=====--------~=====---=----=~=T==_=====c----

_---- (-~middot- _ - WHITMAN amp HOWARD NC ~1 _Engineers and Architects2~ 45 WILLIAM STIUIET WILUSLIY MASS 021SI bull TIL 17middot217middot5000 -middotshy~middot--middot-shymiddot-bullD ~ -middot- - 0shyMarch 30 1981____ =_ ___ -middot- _ ~ A l otio

__ ~ Mr Bar ry w Muller Princi pal Engineer State of Rhode Ialand Department of Environmental Management Division of Air and Hazardous Materiala 75 Davie Street - 204 cannon Building Providence R I 02908

Dear Mr Muller

We are pleased to submit herewith our report on our review of the closure plan for the hazardous waste portion of the landfill operated by Landfill and Reaource Recovery Inc in North Smithfield R I

The text of the report details the review ite findingbull and our recoaaendatione A simplified euary etatent would be that in our opinion the Cloaure Plan bullubbullitted by L amp RR ia unacceptable in that it doea not addre cloeure of the hazardous waete portion of the landfill ae a eeparate isaue

we would be pleased to discuss this report vi th you at your convenience and we appreciate the opportunity to be of eervice to the Department of Envi ronmental Management

Very truly yours

WHITMAN amp HOWARD INC

~middotcent~1~~it- J~anR Brlg Asaociate - Bydrogeoloqist

Steven L Dean Manager Groundwater Management systems

JRB pdd

TABLE OF CONTENTS

1 0 INTRODUCTION

11 General 1 2 Purpoae and Authority 1 3 scope of work

2 0 BASELINE DATA

21 General 7 2 2 Site Content 9 2 3 Previoua Inveatigationa and Aaaeaamenta 11 24 Exiating Conditionbull and Oper ationbull 16

3 0 REVIEW AND EVALUATI ON

31 Gene ral 18 3 2 Reatricte4 Acebullbullbull and

Activity Separation 20 3 3 vertical Expanaion 22 3 4 Activity Separation 26 3 5 Leachate Collection Syltem 27 3 6 Groundwater Monitoring 28 3 7 amprthcover and Liner Maintenance 29

4 0 FINDINGS AND RECOMMENDATIONS

41 r indinga 30 4 2 RecOIIIDenda tiona 31

PLATES

Locua Plan 7A Sectionbull 20A Sectionbull 208 Sectionbull 20C Leachate Collection Syatem Alternative 27A

1 0 INTRODUCTION

11 ~ By an order iuued on June 20 1980 the

State of Rhode Illand Department of Environmental Manaqement

Divbion of Air and Hazardous Materiala (hereinafter referred

to as DEM) required Landfill and Resource Recovery Inc

(hereinafter referred to as LampRR) to prepare a closure plan

for their landfill facility located in North Smi thfield

Rhode leland The order was iasued

to ensure that the highest de9ree of attention is provided to protect the public health and environment from any adverse consequences caused by LampRRs oper ation

and it contained the following di rectives

11 1 By July 18 1980 install one aulti-level well at the toe of the refuse dope at a point equidistant between the two presently installed BARCAD type wells which were installed by the State in February 1980

2 By July 15 1980 complete and aubmit to DEM for approval a full ground water topotiJrampphic aurvey of the entire landfill d te

3 By Auguat 1 1980 aubmit a plan to the DEM preshyacribinq baaed on the apecificationa of the ground water aurvey the planned location of a network of multi-level or BARCAD-type wella at bedrock or three timea the number of cluater vella The well referred to in section 1 above can be considered aa one of the multi-level vella or theae cluater wella

4 By August 15 1980 submit a plan for closure of the entire facility

5 By September 1 1980 have all wells installed

LampRR appealed the order and hearings on this matter

began on July 24 1980 The original hearing officer

excused himself on Auquat 4 and the hearings were continued

-l shy

under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

-2 shy

f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

-3shy

feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

-4shy

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

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d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

~

~====------==-=====--------~=====---=----=~=T==_=====c----

_---- (-~middot- _ - WHITMAN amp HOWARD NC ~1 _Engineers and Architects2~ 45 WILLIAM STIUIET WILUSLIY MASS 021SI bull TIL 17middot217middot5000 -middotshy~middot--middot-shymiddot-bullD ~ -middot- - 0shyMarch 30 1981____ =_ ___ -middot- _ ~ A l otio

__ ~ Mr Bar ry w Muller Princi pal Engineer State of Rhode Ialand Department of Environmental Management Division of Air and Hazardous Materiala 75 Davie Street - 204 cannon Building Providence R I 02908

Dear Mr Muller

We are pleased to submit herewith our report on our review of the closure plan for the hazardous waste portion of the landfill operated by Landfill and Reaource Recovery Inc in North Smithfield R I

The text of the report details the review ite findingbull and our recoaaendatione A simplified euary etatent would be that in our opinion the Cloaure Plan bullubbullitted by L amp RR ia unacceptable in that it doea not addre cloeure of the hazardous waete portion of the landfill ae a eeparate isaue

we would be pleased to discuss this report vi th you at your convenience and we appreciate the opportunity to be of eervice to the Department of Envi ronmental Management

Very truly yours

WHITMAN amp HOWARD INC

~middotcent~1~~it- J~anR Brlg Asaociate - Bydrogeoloqist

Steven L Dean Manager Groundwater Management systems

JRB pdd

TABLE OF CONTENTS

1 0 INTRODUCTION

11 General 1 2 Purpoae and Authority 1 3 scope of work

2 0 BASELINE DATA

21 General 7 2 2 Site Content 9 2 3 Previoua Inveatigationa and Aaaeaamenta 11 24 Exiating Conditionbull and Oper ationbull 16

3 0 REVIEW AND EVALUATI ON

31 Gene ral 18 3 2 Reatricte4 Acebullbullbull and

Activity Separation 20 3 3 vertical Expanaion 22 3 4 Activity Separation 26 3 5 Leachate Collection Syltem 27 3 6 Groundwater Monitoring 28 3 7 amprthcover and Liner Maintenance 29

4 0 FINDINGS AND RECOMMENDATIONS

41 r indinga 30 4 2 RecOIIIDenda tiona 31

PLATES

Locua Plan 7A Sectionbull 20A Sectionbull 208 Sectionbull 20C Leachate Collection Syatem Alternative 27A

1 0 INTRODUCTION

11 ~ By an order iuued on June 20 1980 the

State of Rhode Illand Department of Environmental Manaqement

Divbion of Air and Hazardous Materiala (hereinafter referred

to as DEM) required Landfill and Resource Recovery Inc

(hereinafter referred to as LampRR) to prepare a closure plan

for their landfill facility located in North Smi thfield

Rhode leland The order was iasued

to ensure that the highest de9ree of attention is provided to protect the public health and environment from any adverse consequences caused by LampRRs oper ation

and it contained the following di rectives

11 1 By July 18 1980 install one aulti-level well at the toe of the refuse dope at a point equidistant between the two presently installed BARCAD type wells which were installed by the State in February 1980

2 By July 15 1980 complete and aubmit to DEM for approval a full ground water topotiJrampphic aurvey of the entire landfill d te

3 By Auguat 1 1980 aubmit a plan to the DEM preshyacribinq baaed on the apecificationa of the ground water aurvey the planned location of a network of multi-level or BARCAD-type wella at bedrock or three timea the number of cluater vella The well referred to in section 1 above can be considered aa one of the multi-level vella or theae cluater wella

4 By August 15 1980 submit a plan for closure of the entire facility

5 By September 1 1980 have all wells installed

LampRR appealed the order and hearings on this matter

began on July 24 1980 The original hearing officer

excused himself on Auquat 4 and the hearings were continued

-l shy

under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

-2 shy

f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

-3shy

feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

-4shy

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

-------N

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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LMltshy------r LMlWIU- ~--BIMCMILL_L -~

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SECTIONS -208shy

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SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

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should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

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direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

TABLE OF CONTENTS

1 0 INTRODUCTION

11 General 1 2 Purpoae and Authority 1 3 scope of work

2 0 BASELINE DATA

21 General 7 2 2 Site Content 9 2 3 Previoua Inveatigationa and Aaaeaamenta 11 24 Exiating Conditionbull and Oper ationbull 16

3 0 REVIEW AND EVALUATI ON

31 Gene ral 18 3 2 Reatricte4 Acebullbullbull and

Activity Separation 20 3 3 vertical Expanaion 22 3 4 Activity Separation 26 3 5 Leachate Collection Syltem 27 3 6 Groundwater Monitoring 28 3 7 amprthcover and Liner Maintenance 29

4 0 FINDINGS AND RECOMMENDATIONS

41 r indinga 30 4 2 RecOIIIDenda tiona 31

PLATES

Locua Plan 7A Sectionbull 20A Sectionbull 208 Sectionbull 20C Leachate Collection Syatem Alternative 27A

1 0 INTRODUCTION

11 ~ By an order iuued on June 20 1980 the

State of Rhode Illand Department of Environmental Manaqement

Divbion of Air and Hazardous Materiala (hereinafter referred

to as DEM) required Landfill and Resource Recovery Inc

(hereinafter referred to as LampRR) to prepare a closure plan

for their landfill facility located in North Smi thfield

Rhode leland The order was iasued

to ensure that the highest de9ree of attention is provided to protect the public health and environment from any adverse consequences caused by LampRRs oper ation

and it contained the following di rectives

11 1 By July 18 1980 install one aulti-level well at the toe of the refuse dope at a point equidistant between the two presently installed BARCAD type wells which were installed by the State in February 1980

2 By July 15 1980 complete and aubmit to DEM for approval a full ground water topotiJrampphic aurvey of the entire landfill d te

3 By Auguat 1 1980 aubmit a plan to the DEM preshyacribinq baaed on the apecificationa of the ground water aurvey the planned location of a network of multi-level or BARCAD-type wella at bedrock or three timea the number of cluater vella The well referred to in section 1 above can be considered aa one of the multi-level vella or theae cluater wella

4 By August 15 1980 submit a plan for closure of the entire facility

5 By September 1 1980 have all wells installed

LampRR appealed the order and hearings on this matter

began on July 24 1980 The original hearing officer

excused himself on Auquat 4 and the hearings were continued

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under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

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f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

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feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

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5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

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d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

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In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

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LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

1 0 INTRODUCTION

11 ~ By an order iuued on June 20 1980 the

State of Rhode Illand Department of Environmental Manaqement

Divbion of Air and Hazardous Materiala (hereinafter referred

to as DEM) required Landfill and Resource Recovery Inc

(hereinafter referred to as LampRR) to prepare a closure plan

for their landfill facility located in North Smi thfield

Rhode leland The order was iasued

to ensure that the highest de9ree of attention is provided to protect the public health and environment from any adverse consequences caused by LampRRs oper ation

and it contained the following di rectives

11 1 By July 18 1980 install one aulti-level well at the toe of the refuse dope at a point equidistant between the two presently installed BARCAD type wells which were installed by the State in February 1980

2 By July 15 1980 complete and aubmit to DEM for approval a full ground water topotiJrampphic aurvey of the entire landfill d te

3 By Auguat 1 1980 aubmit a plan to the DEM preshyacribinq baaed on the apecificationa of the ground water aurvey the planned location of a network of multi-level or BARCAD-type wella at bedrock or three timea the number of cluater vella The well referred to in section 1 above can be considered aa one of the multi-level vella or theae cluater wella

4 By August 15 1980 submit a plan for closure of the entire facility

5 By September 1 1980 have all wells installed

LampRR appealed the order and hearings on this matter

began on July 24 1980 The original hearing officer

excused himself on Auquat 4 and the hearings were continued

-l shy

under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

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f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

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feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

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5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

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urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

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d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

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0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

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In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

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LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

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report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

under Mr Frank P Geremia Adjudicative Bearing Officer on

Auqust 6 through 8 concluding on Auquat 14 1980 One of

the Conclusions of Law resulting from these hearings wa1

that

The requirements for closure and moni taring of the facility including groundwater wells by LampRR ordered by the Director on June 20 1980 are baaed on the 1tatutory and requlatory authority of the Director as enumerated above and are reasonable requirements to eff ect the intended purpoaes of the law and requlations

In addition the hearings also resulted in the iuuance of

the f ollowi ng

~

l That LampRR submit a plan for closure of the hazardoul Wamp8te facility by November 15 1980 Such plan shall include

a) A description of the methods to be used to restrict access to the facility and to prevent adc1i tiona hazardous waste disposal

b) A description of design and installation apecifications for the ialpermeable PVC liner including depth and analysis of cover above and installation procedure used The cover aaterial shall be at least two feet deep above the liner consilt of clean fill only and be free of boulders

c) A description of adequate top soil and vegetation sufficient to repair any eds tinq eros ion damage and to prevent f uture eroaion at the site

d ) A descr i ption of the methods to be used by LampRR t o establish and maintain a f inal grade that promotes surface water runoff without excessive erosion and to divert surface water drainage around and away from the 4isposal area

No references to proposed expansion of the LampRR facility

-2 shy

f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

-3shy

feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

-4shy

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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t of the docum

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(

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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SECTIONS -208shy

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SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

f) A hazardous waste site closure plan map or maps prepared and 1tamped by a registered profeuional engineer in the state of Rhode Ialand drawn to a minimum scale of one inch to one hundred feet (1 11 bull 100 ) delineating the following

i) Surface contourbull at intervala of five feet

ii) Groundwater contours at intervals of five feet and portraying groundwater flow

iii) Fences gatea road1 atructurea major aurface featuru etc

iv) North arrow and bar scale

v) Ground vater and surface water monitorshyinq devicea and atationa both existing and proposed

vi) Final cover areabull

vii) Top aoil and vegetation cover

viii) Final gradea

ix) Legal boundariu

x) Are vhere hazardoua waste have been placed

xi) Area covered by iaper~~eable PVC liner

xii) Areaa propoaed for continued unitary landfill (not hazardoua) operationa

g) A deacription of any other meaaurea to be conatructed undertaken or maintained and proposed by LampRR to protect groundwater and aurface water or to control air emiuiona from the facility

2 That LampRR install three additional multi-level monitoring wells (nine vella if cluster wells are used) by October 30 1980 The vella should be of the BARCAD type and of a deliqn in accordance vith Monitoring Well Design and installation criteria (See Attachment Exhibit A-1) (In lieu of BARCAD type wells cluster vella may be uaed but then of course the minimum number of vella would be three times the number of BARCAD type wells ) vith sampling points at three levela--within ten

-3shy

feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

-4shy

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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t of the docum

ent

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

feet of the maximum groundwater tilhle at time of well installation at bedrock illld at a midpoint between the other two aampling levels The midpoint sampling level may be eliminated if the upper and lower sampling levels are separated by leas than twenty feet

The wells shall be located at the places accepted by Mr Frank Stevensons letter of Auquat 1 1980 along with the southern moat proposed well being located 25 east of OB-5 11 boring These locations are shown on Exhibit A-7 as open triangles with a cross hair pattern

3 ~~1~~~0~o~a~a~~I~t~eam~~Uo~lng system for as long as the OEM Director determines the hazardous waste poses a threat to the environshyment This monitoring plilll shall assume that the

~~~ara~~~~ ~~~fi~~~ap~~~to~0~ie and further ahall include as a minimum the followwing

a) A description of suplinq progru which IampRR ahall carry out whereby every multi-level well at the LampRR facility is sampled at each level at leaat once every three bullontha with the firat amplel froa all wells being taken by November 6 1980 whereby an analyaia of all volatile organics all utall from the primary drinking water stAndarcS and a groundshywater analyaia which ia currently required by the Depertment il made in accordance with accepted practice and all resulta immediately submitted to OEM and whereby OEM is formally notified of all samples to be taken at least 48 hours prior to each sample actually being taken

b) A program for physically maintaining the multi-level wells whereby the continued active life of each well through all sampling levels or a replacement is allured

4 That IampRR aubmi t to the OEM Director a final plot plan and cross sections that delineate the location of each type of waste disposed of at the facility by November 15 1980

-4shy

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

5 That LampRR shall establilh and continue in effect financial arrangements that are adequate to finance the longbullterm monitoring and maintenance required by this order and ahall describe these arrangements in writing to the DEM Director by November 15 1980 and further that LampRR ahall actually carry out the plana required above by thia order

6 That ahould monitoring results indicate the need for additional action to asaure that hazardous wute will be kept from endangering drinking water suppliea the DEM Director may order such additional action

7 That this adjudicative hearing officer will retain jurisdiction of this matter for purposes of detenininq compliance with the provisions of this order

The order signed by Frank P Geremia with concurrence

by w Edward wood Director DEM on october 15 1980

12 Purpose and Authority The purpou of this report

ia to provide OEM with a written review and evaluation of a

closure plan subaitted to them by LampRR The contractor is

required to e~nt upon speeific bauea and areas of the

plan as outlined in the scope of Work (paragraph 1 3 below)

on Septaber 5 1980 the DEM requested proposala from

eonaul tanU that would address the 1teo contained in their

order of June 20 1980 The request stated that OEM had

failed to receive an adequate c losure plan from LampRR that

covered the requirements of the closure order

On November 26 1980 the DEM issued a revised proposal

which requeated bids for review of a closure plan aubmitted

by LampRR This proposal contained a definitive scope of

-sshy

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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t of the docum

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

urvicea to be provided by the contractor Whitman amp Boward

Inc (hereinafter referred to u WampB Inc and or the Conshy

tractor) received notice of acceptance of ita bid to perform

the requi red work on December 19 1980 and a notice to

proceed was i ued by OEM and received by WampH Inc on

February 12 1981

1 3 Scope of Work By contract WampB Inc is required

to provide OEM with a written report conforming to the

following

1 The Contractor will conduct a technical review of the cloaure plan for the hazardoua waate portion of Landfill amp Rource Recovery Inc facility The entire plan bullbull 1ubmitted by Landfill amp Reaource Recovery Inc will be reviewed aa to ita adequacy by the Contractor Contractor ahampll particularly aa1e11 thoae probl a1 enuaerated below

a The Contractor 1hall review and evaluate Landfill amp Reaource Recovery Inc 11 plan of 17 Noveaber 1980 to reatrict acebull to the hazardoua waate portion of LampRR

b LampRR propo1e1 extendve vertical expanshydon for aolid waate di1po1al over the exiltinq hazardoubull waate diapoaal area o LampRR hu already placed a liner over the hazardoua waate dilpoaal area The Contractor ahall bullbullbullebullbull the impactbull of vertical expampMion over the impermeable liner and the impact of the expandon on leachate formation Parti cular attention to the impact on liner inteqrity under vertical expansion should be addresaed

c o The Contractor ahall review and evaluate LampRR 1 1 plan of 17 November 1980 for keepinq aeparate the 1olid waste disposal activities from the hazardous waste aite

-6shy

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

d The Contractor shall review and evaluate the leachate collection system for the hazardous waste portion of the facility and delineate additional requirements neceuary for an acceptable leachate collection 1ystem for the hazardous wute portion of the tacili ty

e The Contractor bullhall review and evaluate LampRR 1 s 17 November 1980 program for groundwater monitaring both during operation and folloving any final closure of the entire facility Recommendations

~~~a~i~1~94er~~Innr~~aillowingclosure are required A colt estimate for the long term monitoring of the lite and a method to en1ure financial means therefore (i e bonding trus t fund bull etc ) bullhould be developed

f The contractor shall review and evaluate a program bullubbullitted by LampRR on 17 November 1980 of earth cover and liner maintenance to continue in perpetuity after the overall clo1ure of the facility Coat eattatea for thia aaintenance ahould be developed

2 0 BASELINE DATA

21 2 Landfill and Re1ource Recovery Inc ie

a corporation regbtered in Rhode I sland Their buaineaa is

waate diapoaal and their principal landfill operation ia at

a lite in North Saithfield Rhode Ialand This lite is

located along Oxford Road approxibullately one and one-half

miles aouthweat of the Village of Slatersville Oxford Road

runs along the western edge of the site The Blackstone

Valley Electric Co power line and euement border the site

to the north and east and a forty foot wide riqhtbullof-way

and power line for the Rhode Uland Power Transmission C~

cuts through the lite in an east-west direction This

easement roughly parallels an existing storm water dral nr

-7shy

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

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swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

swale and in combination they serve to divide the site

into tvo segments The total area of the site ia about

forty-five acres Of this approximately thritybullone acres

are located north of the easement swale line and the remaining

fourteen acres are located south of this barrier

The site has operated as a combination gravel pit

clbpoaal area for a number of years Recorda indicate that

wtea vere dumped at the site as far back as 1927 In

1974 the property vas acquired by LampRR Under their ownershy

ship unknown quantities of municipal co1111ercial indu8trial

and hazardous wtea have been deposited at the lite

Alaost all of this aaterial has been placed on the northern

portion of their property While the exact proportions

CQIIPOSition and location of these various wtes are unknown

the Gereaia hearings accepted as a finding of fact that

between March and Septeaber 1978 LampRR accepted over one

aillion gallona of hazardous waste and that this material

vas never segregated frobull other vaates

LampRR s landfill h been governed by a variety of vas te

aanagement facil i ty operating rules and requlationa enacted

by the State Originally enforcement of these s tatutes vas

the responsibility of the Rhode Island Department of Health

This function was transferred to OEM in 1977 Under both

agencies LampRR bas applied for and been granted licenses to

operate their facility The first license vas issued in

History of Involvement at LampRR Inc prepared by Frank B stevenaoa March 6 1980

-8shy

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

1976 The lut license was issued on January 25 1980 and

it expired on December 31 1980 Hearings regarding renewal

of this license are currently being held

22 Site context LampRRs site is located on the east

face of a plateau separating Trout Brook and the Slatersville

Reservoirs Richmond and Allen identified the formation u

a Kame Delta (Qkd) and theorized that it devel oped during

the ninth stage of deglaciation and l ate glacial outwuh

sequence They contend that this format ion is the largest

of f our Kue deltAs i n the Georgi aville quadrangle In a

discusaion of fluvioqlacial ice-contact depolita Richmond

and Allen state that

bull x deltas are coaposed of stratified drift the long steeply inclined foreset beds are bullostly of sand whereas the overlying topset beda are preponderantly of subaerially channeled aand and 9Iave1 bull

Ricbaond and Allen aa well aa Johnston and Dickerman

recognized the value of these deposita with respect to

qrounctvater Quoting froa the former source

bullbull Deposits of auch uniform texture may have a r e l atively high porodty Coarse well-sorted gravels of this type generally have a relatively high permeability and speci fic yield and thus provide excellent res ervoi r s for atorage of groundwater

bullRichmond GM and Allen W B 1951 The Geology and Groundwater Resources of the Georgiaville Quadrangle RI RI Port and Industrial Development Commiuion Geological Bulletin No 4

Johnston HE and Dickerman D C 1974 ttAvailability of Groundwater in the Branch River Basin Providence County Rhode Island u S C s Water Resources Investigations 18-74

-middotshy

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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SECTIONS -208shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

While recognizing the limited number of well logs

available in the area for their atudy and stressing the need

for further work to confirm the extent of the resource

Johnston and Dickerman estimated that the acquifer in the

Slatersville area has a conservative subatained yield of

five and one- half million qallona per day FUrthermore

they s tre that

bull The computed yields r epreaent estimates of amounts

~~a~~=~~I~ine~mwl~=~so~y a~=a~~tn= sarily indicative of optimum or maxiaum yielda obtainable rom the strati fied-drift aquifer Additiona amounts are available from areas not 110deled bull

Richaond and Allen also aapped the bedrock underlying

the landfill site It ia the Esaond 9ranite of Paleozoic

ampCJe coar CJIained light gray to pink in color containing

feldspar quartz and aica The top of the bedrock drops to

a pre-glacial channel the northeastbullaouthwest trending axis

occurring about fifteen hundred feet north of the landfill

Tbe landfill occupies about three percent of a sixteen

hundred acre aubmiddotwatershed of the Branch River drainage

basin Thia sub-watershed draiu into the lower portion of

the Slatersville Reservoirs via Trout Brook The moa t

aiqnificant porti on of run-off traversi ng the aite i n a weat

to east direction flows off of the Kame delta through a

natural awale west of Oxford Road Flow ia culvert ed under

Oxf ord Road and travels along a smaller awale which aa has

been previoualy mentioned combinea with the Rhode Island

-10shy

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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SECTIONS -208shy

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SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

0

Power Transmiaaion Co right-of-way to divide the aite into

two nctiona The norther portion of the d te drainbull into

Trout Brook via a small awale which pauea under the Blackshy

atone Valley Electric co trampru~miaaion line juat aouth of

the point where the line bends and change to a norht-aouth

orientation Thia awal e drains almoat all of the northern

portion of the aite i nc luding a s ubstantial portion of the

exist i ng landfil l mound and aho carriu aome run- of f f rom

the high ground off of and to the north of the landf ill

2 3 Previous Invutiqationa and Aueumenta The LampRR

lite hu been the subject of a conaiderable UDount of

investigation and study over the laat aeveral yeara In

1974 four wells were drilled on the property It b believed

that they were inatalled bullbull part of a pre-purchaae inveatigashy

tion conducted by uJlll Five aore welh were drilled in

1976 In 1977 bulleven aonitoring wellbull were bwtalled u per

the Rul and Requlationa for Operating Solid Wa8te Manaqeshy

aent Facilitiebullbullbull Roy F Webullton Inc inatalled four monitorshy

ing welb adjacent to the property in 1978 bullbull part of the

Statebull 208 invebulltigation Thebullbull were aupled in 1979 by a

firm retained by the Town of North smithfield Reault bull of

theae testa led to the inatallati on of three a ulti-level

monitor ing 11BARCAD11 type welh by OEM earl y in 1980 They

wer e sampled i n March 1980 Teat reaulta led OEM to require

LampRR to inatall four multi- level cluster wella later that

year

- 11shy

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

In July 1978 Roy F Weston Inc prepared two reports

for the Rhode Island Statewide PlaMing Program Both

reporta addrel8ed iuues pertinent to a plan of regional

water quality One of the reports Detailed Analysis of

Landfill I11pacte on Water Quality 11 studied the potential

impacts of aixteen landfills in the State The LampRR site

wu one of the sixteen aelected A major component of

Wuton 1 bull work was the inetallation and sampling of wells at

theabull aitea Four wellbull were inatalled at LampRRs landfill

surface s ources were also sampl ed and analyzed One o f the

wells located in the swale east of the eite ahowed hydroshy

carbon contamination and a high COD value attributable to

the preaence of leachate 11 In discuing the environmental

tpact of the e1te Weaton concluded that

The landfill baa at pnaent ainillal iJIPact on ita aurroundinqa Problema with leachate volume aay occur in the future if the total property of 36 acres ia filled with refuee then natural attenuation and renovashytion aay not be eufficient

Weaton s eecond report Reco~~U~ended Leachate Control

Alternatives 11 developed a claification ayatem for landfills

bued upon the landfills operational status ampnd its degree

of impact on water quality Impact waa determined by the

analytical reeulte of sampling performed during the first

report Weston claaaified the LampRR aite aa an Active

Landfill having 11inor i11pact In diecuing thb clauiicashy

tion Weston noted that an ample soil zone for attenuation

lllay exist between the baae of the landfill and the water

middotb1e or point of qroundwater diacharqe While classifyinq

-12shy

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

LampRR u a minor impact lite Weston repeated hia prior

comment relati ve to potential dqnificant impact should the

entire thrity-dx acre aite be landfilled Aleo in completshy

ing his dis cuion on Minor Impact - Aes sment 11 Weston

noted that

a minor impact aa aaseased today may be advenely impacting future water supplies or may become a major i mpact u the leachate gener ating c haracteristics of a l andfill change with time

The Rhode I sland statewi de Planni ng Program 208

r eport iasued in 1979 i dentified the Slatersville aquif~r aa

having 11 soae potential for future municipal water supply

developaent Aa such the report contended that the area

should be considered ttenvironaentally sensitive and protected

frobull degradation noting that the LampRR landfill b located

on the aquifer the report recomended closure of the site

in a aanner that would ainiaize infiltration should leachate

contaaination becou evident The rep~rt als o reco-ended

th8 establishment of vegetative cover and the construction

of be rms and other erosion control measures at the lite

In late 1980 the Town of North Smithf ield contracted

Whitaan amp Boward Inc to conduct and prepare an environmental

impact uaeaament on groundwater integrity as affected by

LampRR 1 s landfill The report has been aubmi t ted to the Town

for their review and comment

The final document pertaining to LampRR s aite ia the

recently released draft of a report entitled Preliminary

site Aaaeaament and Emergency Action Plana for Landfill and

Resource Recovery North Smithfield Rhode Island The

- 13shy

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

report was prepared by Ecology and Environment Inc for

EPA Ita objective was to determine the nature and extent

of pouible surface and groundwater contamination from the

landfill and to develop draft emergency action plana for

abatement of future environmental damage potentially arising

from the ei te

The apparent thrust of the report were the hazardous

wast es d isposed of at the landfi ll The report noted that

the aite context s eeme d ideal f or l eachat e mi gration of f shy

a te and that the ins tallati on o f the PVC liner coupl8d

with disposal aethods and waste characteristics are probably

alleviating or towing migration of contaminants Addreinq

the aatter of the adequacy of existing monitorin9 wells the

authors atted that they were properly situated and screened

at appropriate levels provided that all hazardoua waatea

were buried in the one location reported by LampRR bull owners

However additional survey and on-site investigation was

recobullended to confirm the location and extent of the hazardous

The value of much of the information and data derived

from teatin9 and monitorinq some of the wells i nstalled on

and around the ai te ia questi onable in the opinion of many

professionals To date tes t i ng haa i ndi cat ed levels of

c ont ami nation principal ly heavy aetah and tot al organic

carbon However the question of the degree of contamination

(ie gross aiqnificant minor etc ) aa well aa its exact

source ia often the subject of considerable debate There are

several reasons for this unfortunate situation

- 14 shy

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

A prime reason for the debate over the reliability and

authenticity of available data h the lack of a clear

concis e underatanding of the hydrogeologic conditions at

LampRR 1 a a i te The i mportance of thia information wu noted

in an EPA report when the authors s tated that

Determination of the flow rate and direction of ground water are prerequisitea to monitoring well placement Drilling will be required and measurements must be made of the piezometric s urface 11

Under a dbcuuion entitled tiDe f i n tion of the Hydrogeologic

Setting 11 the report noted that

The hydroCJeologic setting of the landfill h probably the bulloat 111portant factor in eetabliehing the need for and deaiqn of a landfill monitoring ayatem Prior to selecting a landfill site information u to eurficial and bedrock geolo9Y depth to the water table and direction and rate of ground water flow ehould be deterained In the past aubaurface conditione have not been well-defined landfillbull have been located on laneS such ae awaapa or abandoned qravel pita tradishytionally considered uaeleee and of low econobullic value Ground water pollution potential ie preeent in theee areae and in the caae of gravel pit the potential ie high For tbeae reaeone the need for monitoring and abatellent procedurebull ie acute

Thie eame report lieted data that a ground water

inveetigation ahould provide The liat contained the following

depth to the water table

b the extent of ground water mounding caueed by an exiat i ng landf ill

c the natural rate and direction of flow

d the degree of influence the landfill has on the rate and direction of flow

Fenn 0 Cocozza E and Isbister J Braida 0 Yare B Proux P Procedurfa Manual for Ground Water Monitoring at Solid waste Oiapoul Facilities U S Environmental Protection Agency Report EPA 530 SW 811 Cincinnati Ohio 1977

-15shy

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

e the locationa of recharge and ctiacharge areaa

f the types and interconnection of aquifers

g the rate of aite i nfiltration relative to the total ground water flow

Definitive data pertinent to the items liated above

haa not been available for review The abaence of auch data

precludea verification of the exiating moni torinq well

ayatem with reapect to the adequacy of the number of pointa

inatalled point locations and acreen or aampling point

elevationa Alao the identification of an accurate baCkshy

ground well cannot be aade

Other acton affecting the validity of available aubshy

aurface teat raaulta are the condition of the aample pointl

the frequency of taating differencebull in thoda uaed to

gather IUIPlaamp varying laboratory procedureamp aa well aa

are than one aat of atandarda to which the teat raaul ta can

be coparad

Another factor ia the lack of infomation relative to

the type and location of the varioua typea of waatea within

the total landfill not juat under the exiating liner In

eaaence both where to look for contamination aa well aa

what apecific typea of contamination to look for aeem to be

valid queationa that either cannot or have not been poaitively

anawered

24 Exiating conditions and Operations The moat

dominant feature of the landfill ia a large eliptical

-l6

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

ahaped dome located on middot the northern portion of the property

The dome ia approximately fifty feet high and it coven an

area of about eight and one-half acres About one-half of

the mound ia covered with a liner Assuming elevation 275

aa the bottom of the mound ita estimated volume ia about

three hundred and aixty thouund cubic yarda based on field

aurvey dated June 1980

In January 1980 LampRR covered a portion of the mound

with a 20 mil PVC liner Earthen cover was placed over the

liner and gra baa become established over the majoritY of

this aoil layer However from eight to twelve feet of

liner ia expoaed to aunlight around almoat the entire perimeter

of the DOund probably due to either water or wind eroaion

Water erosion is the ore probable cause and ita effects are

evident over alaoat all of the ateeply eloped uncovered

auracea of the aound Gulliea are co1111on and in soae

places have become deep enough to expose waste materiala

under the aoil cover

currently landfilling h taldng place along the east

and s outheast facea of the mound Refuse h being dumped

apread compacted and covered with aoil in what seems to be

a relatively continuous operation In-dtu soill are being

excavated and uaed for cover This excavation baa created

very ateep eroding slopea along the northwest face of the

site A aimilar condition exists on the west face of the

remains of an existing hill along the eaat edge of the

property

-17

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

-----------N

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Image

11 le11 clear than thl1 notice It 11 dut to the

of the documen

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LMltshy------r LMlWIU- ~--BIMCMILL_L -~

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SECTIONS -208shy

aACXIIUINHILLshy_

WfTANCiaIHO-[

u _ ___

--~~

TMIULN fKWI -shy

11(1110 an___-shy

-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

Landfilling around the exilting hazardous waste area is

increasing the potential for leachate development and migrashy

tion As has been mentioned a considerable area of uncovered

landfill embankment exists around the edge of the liner

The active area to the southeast of the liner is fairly

flat A roadway rings the top of the mound and acta aa a

atep or plateau In combination these conditions offer a

liqnificant area for i nfiltration of precipitation Migration

could follow gradients downward and i nto the area under the

liner The pressure of the active dilpoaal area against the

southeast face of the mound would encourage such an ampnCJUlar

flow The function of the liner is bei ng negated by this

condition Also this condition il probably causing a

oundill9 of the groundwater profile under those exposed

areaa

3 0 UVIW and EVALUATION

31 2npound closure doCUJRenta submitted to OEM by

LampRR consist of four plana and a text The plant~ were

prepared by Wehran Engineering and conaiat of (1) Preliminary

Proposed Final Grade (2) Preliminary Ground Water Contour

Map amp Monitoring Well Locations (3) Preliminary Sections

and (4) Detaih The text consists of a materials and

installation specification for a PVC membrane and a narrative

that addressee certain referenced i tema contained in the

Geremia hearings testimony All closure docwnents are

stamped Received RI Dept of Environmen~al Management

Division of Air and Hazardous Materials Nov 17 1980

- 18

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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LMltshy------r LMlWIU- ~--BIMCMILL_L -~

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SECTIONS -208shy

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SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

The intent and direction of the submittal by LampRR is

expandon rather than closure A major expans ion of the

northern portion of the lite and the complete development of

the southern portion of the property are the dominant elements

of the closure documents

Sectiona taken acrou the plans indicate that about two

hundred and seventy thousand cubic yards of material will be

excavated on the northern portion of the lite and about two

million two hundred and ninety thousand cubic yards of

landfill material will be added This represents approxishy

utely a seven hundred percent increase in the amount of

aaterial currently existing on that portion of the lite On

the southern section about four hundred and ninety thousand

cubic yardl of aaterial will be excavated and nine hundred

and forty thousand cubic yards of aaterial will be landfilled

In collbination with the northern exparulion the total proposed

increaae in landfill is about ten times the current in-

place volWDe

It should be noted that the sections drawn to estimate

the quantity of expansion assumed elevation 260 as the

bott011 of the proposed excavations The closure plans note

that excavation will not be carried closer than five feet

above the seasonal high round water level However

sufficient data does not exist to determine that elevation

Elevation 260 was chosen as a conservative figure Should

groundwater be lower the quantities and proportionbull could

increase liCJilificantly

-19

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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LMltshy------r LMlWIU- ~--BIMCMILL_L -~

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-- middotshyi -~-

VICTOftY HIGHWAY---shy

SECTIONS -208shy

aACXIIUINHILLshy_

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TMIULN fKWI -shy

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-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

The propoud expanaion will have a dgnificant impact

on the viaual character of the surrounding landscape As

ahown i n the aections the pr oposed heights ~or both portions

of the property will make them one of the moat dominant l and

forma in the area Aa land forma they will be out of

charact er with their environment with respect to ahape and

contour It 11 very unlike l y that they will suppor t vegetashy

tion consistent vi th their s urroundingbull thereby maki ng

their bulk and shape even more evident

3 2 Restricted Acceu and Activity Separati on LampRR s

pribulle concept o~ restricted acce~s to the hazardous waste

portion of their landfill seeaa to be encapsulation With

the exception of a text statement relative to a cable and

lock preventing vehicular acceSI frobull the front of the ei te

and another reference to inatructions to the landfill a

staff aa to what wastes are not to be accepted it ia the

only concept inherent in their aubaittal A concept of

additional landfilling separate and apart from the hazardous

waate area ia not addressed

Ecology amp Environment Inc a report recociuzed the

potential iJDpact of the hazarctoua vaate portion of the landshy

fill on the environment and recommended i n-the-fi eld survey

and i nves t i gation t o det ermi ne the extent and location of

the hazardoua materials The Geremia hearinga accepted as

fact the testimony that the hazardous wastea were not s eparated

from other materiala The order from theae hearings directed

LampRR to bull aaaume that the hazarctoua vaate will poae such a

- 20shy

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11(1110 an___-shy

-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

-----------N

OnC

E If tho film

Image

11 le11 clear than thl1 notice It 11 dut to the

of the documen

t

(

LA

ND

FIL

L

amp

RE

SO

UR

CE

R

EC

OV

ER

Y

AD

MIN

IST

RA

TIV

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RE

CO

RD

-

~

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~ i=

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bull W

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~~

0 I bull o

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bull i ~ ~~ gt-

(

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)

L shy

LMltshy------r LMlWIU- ~--BIMCMILL_L -~

-~

-- middotshyi -~-

VICTOftY HIGHWAY---shy

SECTIONS -208shy

aACXIIUINHILLshy_

WfTANCiaIHO-[

u _ ___

--~~

TMIULN fKWI -shy

11(1110 an___-shy

-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

L shy

LMltshy------r LMlWIU- ~--BIMCMILL_L -~

-~

-- middotshyi -~-

VICTOftY HIGHWAY---shy

SECTIONS -208shy

aACXIIUINHILLshy_

WfTANCiaIHO-[

u _ ___

--~~

TMIULN fKWI -shy

11(1110 an___-shy

-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

aACXIIUINHILLshy_

WfTANCiaIHO-[

u _ ___

--~~

TMIULN fKWI -shy

11(1110 an___-shy

-~ middot-

SECTIONS - 20Cshy

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

threat for a substantial although i ndefinite period of

time Both of weston 1 a studi es recognized the potential

of adverse impact from the d te particularly if it waa

developed to its full extend

All of thue opinions and concludona aeem rational

Should significant problema develop that can be traced to

the hazardous wute portion of the landfill remedial action

may entail conatruction activitiea in ancSor around the

exiating wute dhposal area Implementation of LampRR 1 a plan

would hinder auch remedial meaaurea and may in fact n~gate

thbull coapletely Given an extended period of time prior to

either the development or detection of a aource related

pollutant problem LampRR a expanaion could eliainate available

on- aite area needed to illpleaent theae bullbullbullurea In view of

the uncertaintiea of conditiou under the PVC liner and the

extent of profeional opinion that a potential problu doea

exht a rational concept would aeera to be one which conaiden

the entire landfill a potentially hazardoua aite and iaolatea

it from any other propoaed activities The queation or

iaaue of the need for physical barriers auch aa fencea

etc could be examined in an u-needed context given developshy

llent plana for ancillary portiona of the site as well aa the

reaulta of an exteuive ongoing pollutant monitoring program

after a separate cloaure plan for the existing facility ia

aubmitted and approved

-21shy

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

3 3 Vertical Expansion The 20 mil PVC liner covering

the hazardous waste area of the existing landfill was supplied

by Staff Industries Upper Montclair New Jersey Personnel

at Staff were unable to supply data relative to the performshy

ance of their product under extended burial conditions

Product specification supplied by Staff are standard ASTM

teat results ASTM teatJ performed on 20 mil PVC liner

material are done under controlled laboratory condition~~

which do not reflect actual in-the field aituation For

exuaple in diacuaainq the significance of their Graves Tear

Teat (Dl004) ASTM states

apeciaen geometry and speed of testing in this teat aethod are controlled to produce tearinq in a u area of stress concentration at values far below those usually encountered in service

Research that b been done to 4ate on PVC as a landfill

aaterial baa bean directed acre to ita reaction to leachate

rather than ita ability to withstand loading In 1979

Matrecon Inc Oakland California prepared a study for

EPA antitled Liner Materials Exposed to Municipal Solid

Waste Leachate Alaoat all of the aateriala testing done

for this report was performed under laboratory conditiona

Within these parameters PVC as a material performed well

although it did have the highest permeability to water vapor

of any of the qroups of materials tested

-22shy

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

One portion of their report that did not rely on

laboratory conditiona was the recovery of a a ample of PVC

liner from a demonstration landfill located in crawford

County Ohio The material had been buried under e i ght to

twelve feet of refuse and cover material for aix years

Testa performed on recovered samples correlated with laborashy

tory testa However the liner had been protected by a

layer of clay and i b degree of exposure to leachate could

only be es t imated The report also noted that the liner had

t aken the s hape o f the soil and that depressions o f aa much

aa aix i nches i n one foot o f area were observed The report

di d not s tate the nature or caus e of the depressions

In 1977 a field s tudy to t eat the behavior of refuse

under controlled loading waa conducted at the Morgantown

West Virginia a unicipal landfill Refuse in this ins t a llatbull

i on had been in place for many years and i ta depth waa ten

f eet A r ec tangular teat cell waa establis he d and loa ded to

approxiaate ly one thous and pounds per s quare f oot The size

o f the teat ce ll waa fifty feet by ninety feet and settlement

platfonu wer e i nstalled in the mi dd l e and at each end

settleent in the center of the cell occurred sooner and

was of a greater magnitude than at the ends due to the fact

that the average atresa in the center waa estimated to be

approximately twice aa much as that on either end At the

Rao SK Moulton L K amp Seals RK Settlement of Refuse Landfilla in Geotechnical Practice for Disposal of solid Waste Materials ASCE 1977 pp 574-598

-23shy

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

end of three hundred and fifty days the center had settled

just over two feet and each end had settled about one and

one quarter feet In terms of original depth the test cell

had settled from twelve and one half percent to over twenty

percent

It hu been suggested that the bulk of the refuse

landfilled at the LampRR aite ia commercial and that only

North Smithfield uses the facility to dispose of municipal

wastes ldsuming an average weight of five hundred pounds

per cubic yard of waate and that aix inches of soil cover

will be placed over each yard compacted in-place the

total dead load bearing on the center of the existing landshy

fill aound when LampIUl s maximum expanaion plan ia coJII)leted

could be in the range of forty-aix hundred pounda per square

foot LampRR statebull that the PVC liner vas placed over a two

foot deep layer of fine a and or fine ailty sand The ability

of thia bullaterial to withstand theae loads or to apread thu

out evenly enough to avoid liner penetration from solid

objectbull in the landfill cannot be determined All that can

be atated is that there ae to be a very significant

possibility that the integrity of the liner may be destroyed

under the propoaed plan of expansion Penetrations would

probably occur in or near the center of the cover just over

the area designated as containing the hazardous wastes

Penetration of the liner would probably lead to higher

Conversation with Frank B Stevenson Principal Engineer OEM

-24shy

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

moieture leveh in these areu which could result in an

increase in both leachate generati on and aigration

The probable impact of vertical expansion on leachate

formation within the exieting landfill area is a function of

two factors the density moisture ratio of the existing

refuse and the amount of additional moisture that expansion

may introduce into this area If additional moisture is

prevented frobull entering the existing landfill the quantity

of leachate will not increaae However if compression

increases the densityoiature ratio significantly the

field capacity of the refuse could be reached or exceeded

resulting in the conversion of previously static moisture

into leachate The rate of flow of the leachate would

increase and the flow would start sooner Siailar changes

in the rate and duration of flow frobull active saturated

landfill areas would also occur given sufficient compression

Conversely decompression and resultant expansion of wastes

would reduce flow rates and delay leachate aigration

The concept of any vertical expansion over the existing

landfill area seeaa ill advised Problema auociated with

potential damage to the existing liner in combination with

the almost certain increase in leachate formation and migrashy

tion are likely to create significant increaees in what now

appears to be a minor but growing problem of degradation of

a valuable environmentally sensitive natural resource

-25shy

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

34 Activity Separation The matter of keeping separate

the solid waste dbpoul activities from the hazardous wute

dbpoul area has been discussed to 1ome extent under section

3 2 above The closure documents do not present a nparate

operational concept except for the development of the

southern portion of the d te LampRR feela that disposal

activit ies cannot be eparated on the northern section of

the landfi ll In their text they contend

11 bullbullbullPleau keep in mind that although the state requires only a closure plan for the hazardous wute portion of the facility it iB very difficult if not impoible to separate that portion of the operation froa the continushying functions of tree harvtinq reforestation sanc1 and gravel excavation and sanitary landfill operation There is no attupt aade in the following plau to wmeceaaarily tie plan for the continuing operation of a aanitary landfill to the plau regarding waate already diapoaed of but rather we a4viae that it ia practically ipoaaible to aeparate th- ror exuple your enginHringly aound requirnt nWiber l d (froa the Gereaia hearingbull) for diverting aurface water draining around and away froa the diapoaal lite could not be acc011pliahed except by filling the aand and gravel excavation areaa via the aanitary landfill bullethod and regrading the entire lite

The contention that the aanitary landfill aethod ia the

only way that proper aurface gradianta can be devel~ped to

divert aurface run-off around and away from the exiatinq

diapoaal aite il falle The atatement that it il difficult

if not iapoaaible to aeparate the hazardoua waate portion of

the lite from the continuing functionbull of a landfill operation

cannot be proven until a closure plan for the hazardous

waate area void of any reference to propoaed expansion

-26shy

I ---

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

baa been prepared Such a plan will delineate the extent

and limita of the aecurect area and will allow for an examinashy

tion and review of remaing areas of the lite that could be

developed such a plan h not included i n LampRR 1 a submittal

although it waa a specific requirement of the order generated

by the Geremia hearings

35 Leachate Collection s ystem LampRRa cloampure aubshy

mi tta l does not contain a l e achate collect i on system for the

bazardouamp wu te porti on of the f acili ty Drawi ngamp prepared

by their conault i ng engineer do show 14 ABS leachate cOllecshy

tion pipes in aectiona taken through the landfill A

typical iMtallation detail ia alae provided However the

pattern and extent of ampuch a ayatem ia not ahovn in plan

view and there are no details relative to leachate containshy

MDt and treataent

AD acceptable leachate collection ayatu for the huardoua

wute portion of the facility h ahovn on the following

plate IU bullajor coaponenu are two iapervioua cut-off

valla located and angled in a llAJUler ao bullbull to intercept and di vert

potenti ally polluted groundwater to a well which would be

aized to pump the cont ami nated water to the aurface

The l ength and exac t locat ion of the walla would be

de termined after complete and accurate aaaeaament has been

made of the groundwater flow pattern under the aite The

walla would extend from the aurface down to bedrock The

alurry trench or wall construction technique would probably

- 27shy

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

1

QAAIMMl llltoLI --

I LEACHATE COLLECTION SYSTEM ALTERNATIVE

SCALE Ibull 300

-27Ashy

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

be ideal for thil installation The well would be acreened

and a ized baaed upon data from the drilling log It would

probably be four inch diameter minimum Detailbull aa to

treatment dhpoaal of the well water would be developed

bued upon it anticipated volume and compoaition a a well u

the location of the well point

36 Groundwater Monitoring LampRRI monitoring procram

ia euentially acceptable if it doea in fact conform to

groundwater condi tiona on-ate However there are acme

exceptioll8 Two additional aulti-level monitoring well

ahould be conatructed One between CW-2 and CW-4 on the

northern aide of the landfill to intercept any leachate

which aight be aoving in a northerly direction and the

other waat of oxford Road in an area aufficiantly r-oved

froa the landfill for a background well

All welh should be pUIIped continuously (at least two

hundred to two hundred and fifty gallons) to remove pouible

pollutant froa drilling water etc Some welh may be too

deep to purge

Samples should be taken once every three montha and

water level bulleuurements should be taken with each water

bullample The next samples which are taken should be analyzed

for Priority Pollutant Standard Anions and Cations Gross

Alpha and Beta radioactivity Asbestos pH Turbidity Total

Organic Carbon Total Organic BaloqinB Chemical OXidation

Demand Biological Oxidation Demand Specific Conductance

and Fecal Coliform The samples taken for the next year

-28shy

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

should include Volatile orqanica Trace metals Standard

Anions and Cations Total Organic Carbon Biological and

Chemical oxidation Demand pH Specific Conductance aa well

aa any other key indicators which were indicated in the

firat analyaia After the first year of sampling the key

indicators should be sampled every three months and other

parameters once a year for a period of up to ten yeara If

a significant leachate plume b detected a ayatematic qrid

of mul ti-level bullonitoring wella s hould be utabliahed to

accur ately del i neat e and analyze auch a plwae

All clus t er vella ahould be maintained in good wor king

order and i f fo r any r e on any vella are rendered uaeleaa

they should be replaced

Coat Eatiute for Moni torinq

Firat aet of analyaea

$1900 00 each x 12 auplea

Analyaea for next year

$660 00 each x 12 auplea

x 3 aeta

Continuing analyaea

$12 720 per year

To enaure monies for the aamplinq and maintenance of the

monitoring vella OEM and LampRR could enter into an escrow

account

3 7 Earth Cover and Liner Maintenance LampRR bull program

for earth cover and liner maintenance appears to be adequate

However overall gradients on the the alopea of the proposed

-29shy

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

landfills are excessive These elopes scale two to one and

are in excess of the two and one half to one maximum slope

recommended by Staff Industries the aupplier of the existing

PVC liner Staff a personnel recommend three to one as a

preferred elope for top cover and this recommendation appears

to be rational in light of potential erosion that could

expoae the liner to sunli9ht which over a period of yean

deatroya the i nteg-rity of the material

The total area to be maintained under LampRR a completed

landfill b about thirty-six acrea If we aaaume that middot

annually on the avera9e two percent of thia area will

require aobulle type of re-seeding due to erosion the annual

coat would be about dx thouaand dollars (Thirty-five

hundred aquare yarda at about one dollar and seventy cents

per yard not including topsoil) Should in-situ topsoil

not be available or should the erosion take place in relashy

tively inacceible areas the unit price could 90 as high

as two dollara and fifty cents per yard depending mainly on

the topaoil coat

4 0 FINDINGS and RECOMMENDATIONS

4 1 Findings LampRR a closure aublllittal b unacceptable

It doea not propose or address closure of the hazardous

waste portion of the landfill as a separate issue divorced

from expansion of the site The contention that refuse is

the only material suitable for filling to achieve proper

run-off away from and around the landfill ia incortect It

doea not contain definitive information relative to the

-30shy

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

direction o f the flow and depths of groundwater below the

landfill It does not contain specific data relative to the

protection of groundwater from contamination by e l ements in

the hazardous waste disposal site The issue of control of

air emission from the site ia not addressed It does not

contain the location of each type of waste disposed of at

the f acility

4 2 Recomme ndations The landfill s hould be closed

Contami nat i on has been detected An adequate groundwater

analysis and plan has not been developed The locatio~ and

elevation of the aonitorinq system h subject to verification

Hazardous wastes have been buried at the ampi te and their

location is questionable The current operation encourages

leachate developMnt LampRlt should be required to prepare

and subait to DDI an acceptable closure plan This plan

should not contain any reference to expansion and it should

conaidbullr the entire landfill area as it now exists as a

potential hazard to the aquifers It should contain a

definitive syste for contaminant rebulloval and treatment It

should assuae that the d te will pose a threat for a sub

stantial although indefinite period of time after clos ure

The following are s uggested details and procedures f or such

a clos ure p l an

accurat e information must be p r e s ented vi th

respect to groundwater Depths t o groundwater as well as

groundwater flows must be determined accurately This

i nformation should be consistent vith the elements recommended

- 31shy

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

0

for groundwater invutiqation as contained in the EPA document

referenced in 2 3 (Previoue Investigations and Assessments)

b portions of the existing liner that are

exposed should be examined with reepect to ita phylical

condition and integrity If acceptable it should be rolled

back up over the edqe of existing eoil cover and temporarily

held in p l ace

c all exposed aurfacea of the exhting landfill

s hould be f i lled and gr aded ao a1 to provide at l east t wo

fee t of clean cover over any wtu Maximum s l ope s hould

not exceed three to one

d additional quantities of impervious aubrane

aaterial aucb aa 20 ail PVC should be placed on the expod

slopes extending out pt the toe of the ound at let

three feet and up to and be joined vith the edge of the

existing liner The intallation of the liner ehould be

conaiatent with the manufacturer bull recouendationa

e all portiona of expoaed liner bullhould be

covered with at let one foot of protective aoi l Additional

f i ll bull hould be placed around the toe of the mound to facilitate

aurface drainage and run-of f

f all f i l led are aa bull hould receive one foot of

bulloil to be aeeded for erosion protection

g dltation bina bullhould be conatructed enshy

d te to collect bullurface run-off

h a leachate collection system should be

incluC in the plan with provisions for leachate treatment

and dlti -middot al - 32shy

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574

i an acceptable ground and surface water 11onitorshy

inq program should be developed and maintained both on and

off-site

j the applicant should prepare estimates as to

cost of remedial action should gross contamination occur

The applicants ability to cover such costa should be proven

and asbullured Definitive bindinq long-term financial

agreements should be developed for extended maintenance of

the site

A final recommendati on pertains to the advieabili tY of

re-openinq the LamplUl s ite or any other disposal dtes on

areas containinq or aupportinq valuable natural resources

The tera Msecure landfill is tenuous in that the potential

0 for catastrophic events such as earthquakes etc always

ezbta If additional sites which would not endanqer natural

resources are available elsewhere it would ee prudent to

utilize th rather than to risk potential irreversible

environaental dampluqe All other existing disposal facilities

should be reviewed in this sue context

bull -33shy

  1. barcode 561574
  2. barcodetext SDMS Doc ID 561574