UNITED STATES FNvlRONMENTAL PROTECTION AGENCYRFCI ON [

THE MATTER OF:

C E N T R A L L A N D F I L L

Rhode I s l a n d So . l id Was teM a na ge me n t C o rp o ra t i on39 P i k e Street"Providence , , RI 02903

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) U.S. EPA) Docket No. ] -87- 1.016I

P R O C E E D I N G U N D E R SECTION 106 (a) OF THE )C O M P R E H E N S I VE ENVI R O N M E N T A L RESPONSE, , )COMPENSATION, , A N D L I A B I L I T Y ACT OF 1980 )( 4 2 LI . S . C „ S 9 6 0 6 ( a I ) A N D S E'C T I ON 7 0 0 3 )O F T H E R E S O U R C E C O N S E R V A T I O N A N D R E C O V E R S )ACT ( 4 2 U . S . C . S 6 9 7 3 ) . )

This A d m i n i s t r a t i v e Order by Consent (Consent Order) is

e n t e r e d in to v o l u n t a r i l y by and be tween the U n i t e d States ;

E n v i r o n m e n t a l Protection Agency ( E P A ) and the Rhode I s l a n d

s o L i. d Wa s t: e Ma na ge me n t Co r. p o r a t i on ( R I SWMC 'I . Th e Co ns e n t

0 r d e r c o n c e r n s t h e p r e p a r a t i o n o f t h e R e m P d i a I "I n ve s t i g

• 2

C o m p e n s a t i o n , and L i a b i l i t y Act o f 1980 ( C E R C L A ) , 42

U . S ,,C . § 9 6 0 6 ( a ) , a s a m e n d ed b y t h e Su pe r i:u nd A me n d me in t s

and R e a u t h o r i z a t i o n Act of: 1986 ( S A R A ) . Th i s a u t h o r i t y was

delegated 1 to the A d m i n i s t r a t o r of: the U n i t e d States

E n v i r o n m e n t a l P ro t ec t ion Agency ( R P A ) o n A u g u s t 1 4 , 1981,

by E x e c u t i v e Order 12316, 46 Federal^ Reg__is_te_r 4 ,223" '

( r t i - igus t

A d m i n i s t r a t o r , EPA, Reg ion I by EPA Delegation Nos. 1.4-14-A

and 14-14-C. This Consent Order also Ls issued p u r s u a n t

to the a u t h o r i t y vested in the A d m i n i s t r a t o r of E P A by

Section 7003 of the Resource Conservat ion and Recovery

Ac t ( R C R A ) , 42 U . S . C . « 6973 . T h i s a u t h o r i t y was,

de lega ted to t h e Reg iona l A d m i n i s t r a t o r , EPA, , Region "[

by EPA Delegat ion Nos. 8-22-A and R - 2 2 - C . Moreover , R T S W M C

consents to the j u r i s d i c t i o n asserted in th is Order fo r the

purposes of a n y subsequent proceedings for the e n f o r c e m e n t

of th i. s Or de r:. P u rs ua n t t o Se c t i on s .1.0 6 ( a ) a rid 1 21 ( f )

ol: C E R C L A , as amended by S A R A , and Section 7003 of R P R A ,

not ice has been provided to the State of Rhode I s l a n d of: the

scope of the response a c t i o n governed by t h i s Consent Order ,

o I: t he nego t i ,=i t i ons w i t h RI S W MC ,, a n d o f: the i s s u a nce o f

t h i s Consent Order. ,

STATEMENT OF PURPOSE

2 . T n e n t e r i n g i n t o th is Consen t Order , , t h e m u t u a l o b j e c t i v e s

o f R P A a n d R ' [ SWMC are: ( 1 ) t o e v a l u a t e t h e n a t u r e

and e x t e n t of: any t h r e a t to the p u b l i c h e a l t h , w e l f a r e

or the e n v i r o n m e n t w h i c h may be caused by the re lease or

.. "I ..

t h i: ea I: e ne d r e .1 e a s e o 1: h a z a r d ou s su hs t an ces „ po 1 Lu ta n ts ,

o r c o n t am i na n t s Fr om t h e C n t r a I L a n d f i l l , J o h n s h o n ,

.Rhode island by conducting a Remedial Investigation c:H:

t h e S i t e,, i n a cc o r da n ce w 11 h t h e wo c k p-.l a n s u h n 111Pd

by RISWMC dated February 1985, entitled "Revised Proposal

for Sampling,, Analysis, Monitoring and Reporting of

C o n d i 11 o n s a t t h e C e n t r a .1 L a n d i! i 11, Joh ns t. o n, Rho d e i; s 1

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a ny a n d a L 1. ot he r pot e n t i a I ] y r P s p o n s i b 1e p a r t i e s w i t b

r e fe rence to the Si te ,

F I N D I N G S OF FACT

4. RL SWMC is a public: corporation of the State of:

Rhode I s . l a n d created by act of the Rhode I s l a n d G e n e r a l

Assembly in 1974. The Corporation generates revenue

th rough resource recovery and the sale of its services .

RISWMC has the power to issue negotiable notes and bonds

to achieve its corporate purposes. R I S W M C is able to

cont rac t w i t h e n g i n e e r i n g f i r m s to assist them in

e n v i. r on me n t a 1 p r o j e c t s .

5. RISWMC present ly owns and operates a sol id waste

1 a n d f: i L1 ( a p p r o x i. rtia t e 1y 1 5 4 a c r e s i. n s i. z e ) 1 o c a t e cl o n

Shun P ike in J o h n s t o n , Rhode Island,. The land): i LI was

f o r m e r l y owned and ope ra t ed by the Si 1 ves t r i. Brothers

u n t i l i ts purchase on December c > , 1980, by R I S W M C . The

154 acre l a n d f i l l , w i l l h e r e i n a f t e r he termed the "Site."

6. The Site is located a p p r o x i m a t e l y 1. ,000 fleet f rom the

n o r t h w e s t e r n edge of S immons Rese rvo i r and a p p r o x i m a t e l y

3 , 5 0 0 f e e t sou th of the Almy Reservoir. , Cedar Swamp

B rook is located! a p p r o x i m a t e l y 200 f ee t f r o m the southern

border of : the l a n d f i l l and f lows sou theas te r ly a l o n g the

south pe r ime te r of: the Site,, e v e n t u a l l y feed ing in to the

S i. mmo n s Re s e r v o i r .

1. The S i t e cons i s t s of a 154 acre r e f u s e d i s p o s a l

1 L ce n s e d by t he c t a t e o f R h or] p T s 1:) n d , i. n c 111 d i n q

a o ne - t h i r d a c r e E" o i: me r 11 qu i d h a z a r d ou :=; »/a s t e d L s p oc; a 1

a r e a , T h e h a z a r d o u s w a s t e d i s p o s a l a rea w a s o p e r a t e d

f r o m December , 1976 t o M a y 3 0 , 1979 . I n J u l y 1 9 H 2 , t he

h a z a r d o u s w a s t e d i sposa l a rea w a s closed! w i t h 20 f e e t

ol: b o u l d e c s and g r a n u l a r f i l l , 5 f e e t of: f l y a s h , a 20

m i l P V C l i n e r , 10 f e e t o f F l y a sh and! a 2 - foo t g r a n u l a r

f i l l cover. From M a y 1 9 7 9 u n t i l t h e i n s t a l l a t i o n

of the PVC l i n e r , the hazardous waste disposal area

was used for sewage sludge disposal. , .

8 , Based upon h a z a r d o u s was te m a n i f e s t s on f i l e a t the

Rhode I s l and Hep art: merit of Envi ronmenta l Management

( R T D E M ) , it is es t ima ted t h a t d u r i n g 1978 and 1 9 7 9

a p p i: o x i ma t e I / I „ 5 irri i. 111 on g a 11 ons o f h a z, a r d ou R wa s t e

gene ra ted in Rhode ' I s l a n d 1 were d i s p o s e d of at the S i t e .

9. T h e h a z a r d o u s waste m a n i f e s t s o n f i l e at R I D E M

i n d i c a t e t h a t t h e was te s d i s p o s e d oF at t h e S i te i n c l u d e

a qu e ou s s o 1 u t i ons o 1! 1 a t e x wa p t: e , a c i d w a s t e , c or r os i v e

w a s t e , w a t e r soluble o i l s and waste s o l v e n t s , such as

me t: h y I e n e c h Lo r i de, t o 1 ue n e „ 1 , 1 , 1 1r i c h I or o e t: h a ne a n d

t e t ra c h 1 o r oe t h y 1 e ne .

I 0 ., ft m o n 11 o r i nq w e 11 n e t wo r k t h a t i n c L u d e s m o n i i o r i n q

w e l l s a r o u n d tour s i d e s o f t h e S i t e has been i n s t a l l e d

a n d h a s c; h < 3 w n t h a t c o n t:a rn i n a n t: s n a y h a ve be < > n r 1 e a s o d

... A

f ron the s i t e . Sanpl.es f r o m these wel l s were E ' l i r s t . t aken

on O c t o b e r 1 4 , 1980,. Resu l t s f r o m this s a m p l i n g and

add i t i ona l sampling since 1980, indicate that the fo l l owing

c o n t a m i n a n t s ace present, in the ground watec along the

s o u t h e r n and noi: t hea s t e r rn boundar ies of the site: chloro™

ben z e n e , b en zen e, t o 1 uene , 1 ,1, .1. -1 r ic h1oc o ethan e,. t et r a

c h 1 o ro e t hy 1 ene , 1 , 1 ••••d i. c h 1 o r o e t han e, 1 , 2 •••d i ch1o t: o e thein e,

xy lene and m e t h y l e n e c h l o r i d e . Along the sou thern boundary ,

the levels of contamination range from 550 parts per billion

( p p b ) of chlorobenzene (October 14, 1982) to trace

c o n t a m i n a n t s in wel l s located alone:] the face c loses t to S h u n

P ike Along the northeastern boundary of: the Si te in wel ls

located around the sludge disposal area and the fo rmer

haza rdous was te disposal a r ea , the levels of c o n t a m i n a t i o n

are as h igh as 34 ,000 ppb of chloro benzene ( J a n u a r y 1 9 8 3 ) .

I 1 „ Trace amounts of 1 ,1 , 1-tnchloroethane , 1. , 1-d.i c lnloroet ban e ,

i: et r ach ioroet hy lene , t r i c h l o r o e t h y iene, to Luene and me thy 1 ene

c h l o r i d e have been detected in d r i n k . i n g water well samples

t aken f rom homes located in the area s u r r o u n d i n g the site.

These subs tances have been shown in s c i e n t i f i c s tudies to

h av e ad v e r se e f E e c t s o n h uma n h e a 11 h.. Ho mes w i. t h h i g h

levels have been connected to pub l i c water or suppl ied

bo t t l ed w a t e r . The source of these chemica l s has not

y e t b e e n d e t e r nined ..

12 . The p re sence u f these c h e m i c a l s i n the y r o u n d w a t e r u n d e r

am] a d ] a c e n t to the Si te i n d i c a t e s t h a t t h e l a n d f i l l

r e 1 e a s e s co n t amL n a 11 on i. n t o t: h e e n v i ron men t.

http:Sanpl.es

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1 3 . Da I: =J cn 1 1 ec t e d f! r n m t h e s a r f- a ce w a t e r s a m p 1 e s f r o tn

Ceda r S w a m p Brook d o w n s t r e a m of t h e S i t e i n d i c a t e s t h e

p r e s e n c e o f 1 , 1 , 1 -• t. r i c h 1 o r o e t h a n e , c h 1 o r ob e n z e n e a n ti

benzene in the s t r e a m . " I t i s suspected t h a t the

c o n t a rn i na t i o n h a s o r i. g i n a I: e d f c o rn re .1. e a s e s a t t h e s i t e .

1 4 „ E P A h a s d e t e r m i ned t Ih a t e nv i r o nm e n t a L c o n t a m i n a t i o n

i n t h e a r ea o f: t h e S i t e ma y p os e a p r e s e n t: o r p o t: e n t i a L

threat to avian and mammalian species or wildlife that

r e s i d e a n d f e e d u p o n t h e w a t e r , v e g e t a t: i on ,, o r g a nis ms a n d

other animals in the re g ion of the Site.,

1 5. P u r: s ua n t t o Se c t i on 10 ':> f B )( b ) o I: C ER C LA , 4 2 U „ S . C ,.

S 9 6 0 5 ( 8 M b ) , the S i te was proposed Cor i n c l u s i o n on the

N a t i. on .a 1 P r i. o r i t i e s L i s t ( M P L ) pu b 1 i s h e d by t h e

A d m i n i s t r a t o r of! EPA in t h e Federal Ri-'Sister i n

October , .1984 .

16 . EPA has budgeted f u n d s f o r EPA pe r sonne l and contractors

t o o v e r s e e a ny s t u d i. e s c on d u c t e? d by p o t e n t i a 11. y r e s p o n s i h 1 e

p a r t i e s re 1. a t e d t o t h e s i t: e .

17. The S i t e i s a " f a c i l i t y " w i t h i n the m e a n i n g of Sec t ion

10 1. ( 9 ) o f C R RCLA , 4 2 U ., S ,. C ., «i 9 6 0 1 ( 9 ) .,

18, . Respondent R'[ SWNIC is a ""person"" as d e f i n e d in Sec t ion

.1 0 1 ( 2 1 ) o f C ER C LA , 4 2 U . S ., C . S 9 6 n 1 f 2 1 ) , a n d S e c t i on

6 c1 0 0 4 ( 1 5 ) o F RC R A , 4 2 U ,. S . C ,. S > 0 3 ( 1 5 ) .,

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19. R e s p o n d e n t R L SWMC is the o w n e r a n d o p e r a t o r of the $ i t- e

a nd t h e t: e 1: o t: e , i. s a p o t e n t i. a 11 y t: e s p o n «. i. h 1. e p a r t y pu r s u a n t

t o S e c t i on 1 0 7 ( a ) o F C FL, RC LA , 4 2 U „ S . C „ p o a e d

S i t e are hazardous substances as d e f i n p d

I 0 1 ( 1 4 ) o t C E RC LA , 4 2 U. S . C ,. S 9 6 0 1 ( 1 4 ) .

o E a t t. 'h e.

i n Sect ion

2 1 . FPA has de t e rmined t h a t the a c t u a l r e leases and/or

th rea tened releases of h a z a r d o u s substances f rom the

f: a c 11 i. t / rti a y p r e.s e n t a n i mm i ne n t a n d s ub s t a n t i. a 1 e nda ng e r -••

merit to the p u b l i c h e a l t h , w e l f a r e or the e n v i r o n m e n t

w i t h i n the m e a n i n g of! Section l O f t ( a ) of: CERCLA, 4 2 U . S . f .

§ 9 ft 06 ( a ) ,.

2 2 . The past , present and p o t e n t i a l irni .gr at Ion of haza rdous

s u b s t a nc e s i: rom t h e S i t e co n s t i. tu t e s a n a c t u a 1 a n d/ o r

t h re a t e n e d "' r e 1 e a s e " a s d e f i n e d i n S e c t i on 1 01 ( 2 2 ) o i:

C E R C L A , 42 U . S . C . S 9 6 0 1 ( 2 2 1 , as amended by SARA.

23. S o l i d w a s t e s and h a z a r d o u s w a s t e s , as those terms are

d e f i n e d i n Section 1 0 0 4 ( 2 7 ) a n d ( 5 ) o f : R C R A , 4 2 U . R . C .

S 6 9 0 3 ( 2 7 ) and ( 5 ) , have been 'handled, , stored and

d isposed at the Site.

24. Respondent R1SWMC

o f s o 1 i. d wa s t e a t

has

t h e

c o n t r i b u t e d

S i t e „

to the d i s p o s a l

2 5 . £ PA h a s d e t e r m i n e d t h a t t: h e h a n < H i ng , =; t o r a g e a n d

disposal of solid waste and hazardous waste at: the

s i t e may present an imminent and substantial

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end ange rnent to health or the environment w i t h i n

t he me an i ng o f Sec t i on 1 0 0 3 ( a ) of R CRA, 4 2 U „ S . C .

§ 697-H'a),.

26. EPA has determined that, in order to protect: public

health and welfare and the environment, it is necessary

that actions be taken to investigate, and if necessary,

abate such situation. EPA has determined that such actions

include, but: may not necessarily be limited to, the RI/FS,

which is the subject of this Order. The actions called

foe in this Order are consistent, with CERCLA, as amended by

SARA, and, to the extent possible, with the National

Con t: i in g e n cy P 1 a n ( NCP ) , 4 0 C . F ,, R . P ar t 3 0 0 .

2 7 . C P A ha s a r r ang ed 1: o r ov e r s .1 g h t and r ev i e w o f the R1/ F S

by bo t h q u a 1 i f i ed E P A p e r s on 11 e I a nd q u a 1 i. f i ed c o n t: r a c t: o r s,

in a c c o r d a n c e w i t h Sec t ion 1 0 4 ( a ) o f C E R C L A , a s amended

by S A P A .

2 8 . EPA h a s < i e t e rm i ned t: h a t R IS \t MC i s q u a 11. f i ed t o co n d u c t

t h e RI /FS and tha t the R L / F S w i l l be conduc ted p r o p e r l y

a n d p r o m p t l y , i n acco rdance wi th Sect ion 1 U 4 ( a ) o E C E R C L A ,

as amended by S A R A , i f R . L S W M C engages a q u a l i f i e d c o n t r a c t o r

p u r s u a n t to Pa rag raph 30 and i.i: the R I / F S is conducted as

d e s c r i b e d in t h e RI W o r k pi an and p u r s u a n t : to the c o n d i t i o n s

131: t h i s C o n s e 111 O rd e r.

2 9 . T h i s

u po n

C o n s e n t Order

t: h e f o 11o wi n g

s h a l l a p p l y

p a r t: i e s:

t o a n d b e b i n d i n g

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a , Th e {I n i 1: ed S t a t es P nv 1r on me n t a 1 Prot ec t- i. o n

Ag e n cy ,

b . R I! SWM C„ i t s aq e n t ?> , enp 1 oy pes ,

r e p r e s e n t a t i v e s , a nd c o n t r a c t o r s „

ORDER

Based on the foregoing, it is hereby AGREED TO AMD ORDERED

that the following work sha LI be performed:

30. All work performed pursuant to this Consent Order shall.

be under the direction and supervision of n qualified

individual with appropriate expertise,. Prior to the

initiation of site work, the 'Respondent shall

notify EPA in writing regarding the name,, title, and

qualifications of such individual and of: any contractors

and/or subcontractors to be used in carrying out the

terms of this Consent Order. EPA shall, have the right to

disapprove any individuaLs or contractors engaged by Rl SWMC

to conduct work, under this Consent Order if EPA determines

that such person4" are not qualified to conduct: the RL /F'S

as required by Section L04(a) of CERCLA, as .amended by .SARA.

All work per formed pursuant to this Consent Order is subject

to approval by EPA and shall be consistent with the NCP and

and CERCLA,, as amended by SARA. If any inconsistencies among

the above or any previously published EPA guidance are

discovered, then the provisions of: CERCLA, as amended by

SARA, wi 11 govern work under this Order.

... I ]...

31. W i t h i n seven ( 7 ) c a l e n d a r days of t h e e f f e c t i v e d a t P

o f : t h i s C o n s e n t O r d e r , t he R e s p o n d e n t s h a l l commence t he

Re med i a 1 T n ves 1.1 g a t i. o n., Th i s w o r k s h a 1 1 be c on d u c t ed i n

accordance w i t h the terms o f t h i s Consent : Order , EPA

Re me d i. a 1. "[ n ves 11 g a t i on ( RI ) g u i d9 nce d o c u n e n t s , i. n c 1 u d i n rj

the EPA " I in te r irn G u i d a n c e on Supe r f u n d Select - ion of R e m e d y , "

OSWER Direct ive No. 9355.0-1.9,, e f f e c t i v e December 24 , , 1986,

a n d t h e s t a n d a r d s , s p e c i f i c a t i o n s a n d schedu le c o n t a i n e d

in the Rl workp lan incorpora ted h e r e i n a s A t t a c h m e n t A ,

and A t t a c h m e n t s R and C to t h i s Order , .

3 2 . W i t h i n s i x t y ( 6 0 ) c a l e n d a r days o f t h e e f f e c t i v e da te

of this Consent Order, the Respondent s h a l l submit to RPA

a p l a n fo r a complete F e a s i b i l i t y Study ( F S ) . T h i s p l a n

s h a l l , be developed in accordance w i t h the E P < V FS g u i d a n c e

document. ' ) p r e v i o u s l y suppl ied to Rl SWMC by E P A , i n c l u d i n g

the EPA " I n t e r i m Guidance on S u p e r f u n d Select ion of Remedy , "

O SWE R D i re c t i v e No. 9 3 5 5 ., 0 - 19 , e f f e c 11 v e De cembe r 2 4 , I 9 8 6 ,

and s h a l l be i n c o m p l i a n c e w i t h the p r o v i s i o n s of r ' F R C L A , as

amended by S A R A . I f c a n y i neons is te rices be tween t h e E P A FS

g u i d a n c e documents and C E R C L A , as amended by S A R A , become

e v i d e n t , , then the provis ions of C E R C L A , as amended by S A R A , ,

s h a l l govern t he p l a n . A l l r emed ia l , a c t i o n s proposed fo r t he

s i te unde r t h i s order sha l l comply w i t h the c l e a n - u p

s t a n d a r d s of Section 121 of CERCLA, as amended by SARA.

T h i s FS W o r k p l a n w h e n added to the Rl W o r k p l a n s u b m i t t e d

b y P I SWMC d a t e d F e b r u a r y 1 9 f i ' : > r a n d a s m o d i f i e d h e r e i n ,

w i l l f o r m the basis f o r i n v e s t i g a t i o n s u n d e r t h i s o r d e r ,

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33. Rased on d a t a p rov ided by the RI , EPA p re sen t ly i n t e n d s to

conduct an En da n gee me nt Assessment ( I R A ) for the s i te .

E P A w i l l p r o v i d e R e s p o n d e n t an o p p o r t u n i t y t o r e v i e w

and comment upon t he E A W o r k p l a n and d r a f t o f t he E A .

S h o u l d EPA choose not: to conduct: the EA, i t : reserves the

r i g h t to r equ i r e RI SWMIC to conduct such a s t u d y . Based

on the EA,, RI SWMIC shall f o r m u l a t e and e v a l u a t e a n u m b e r of

a l te rna t ives for on-site 'source control, on-site waste

mi n i m i zat ion , destruct ion ,, and t t reatment, . of f-••?; ite

it: e me d i a 1 a c t i ons a n d t h e n o a c t i on a 11e rna t:iv e,.

34 . A f t e r r ece ip t of the FS W o r k p l a n by EPA, , EPA w i l l

n o t i f y the Respondent in w r i t i n g of E P A ' s approva l or

d i s a p p r o v a l of the FS W o r k p l a n or any par t t he reo f .

In the even t of any d i s app rova l , EPA wi l l s p e c i f y in

w r i t i n g both the d e f i c i e n c i e s and any EPA recommended

m o d i f i c a t i o n s regarding the FS Workplan.

35, W i t h i n t h i r t y ( 3 0 ) c a l e n d a r days o f . the receipt of

EPA n o t i f i c a t i o n of FS W o r k p L a n d i s a p p r o v a l , the Respon

den t sha l l amend a n d s u b m i t to EPA a revised FS W o r k p l a n .

In the event : of: subsequent d i sapprova l . oE the E:'S

W o r k p l a n , EPA re ta ins the r ight : to conduct,, at i ts op t ion ,

e i the r an FS or a complete RI /FS pursuant to its a u t h o r i t y

u n d e r C E B C L A , as amended by SARA. ,

... •[ 3

3 6 . Upon E P A a p p r o v a l , R e s p o n d e n t s h a l l i m p l e m e n t : t h e

t a s ks de t a 11ed i n t h e a p p r ove d Feas i h i 1 i t y S t u d y ( K S)

W o r k p l a n . T h i s work sh r i l l , be conduc ted i n accordance

w i t h t he t e r m s o f t h i s Consen t O r d e r , - t he R P A FS g u i d a n c e

docu in e n t s , t h e s t a nd a r d s , spec i i: i c a t i. on s , a n d s ch e d u 1 e

c o n t a i n e d i n the FS W o r k p l a n , and A t t a c h m e n t C to t h i s

O r d e r .

37,. The Respondent shall provide monthly w r i t t e n progress

repor ts to E P A . At. & m i n i m u m , these progress reports

shall.:: ( 1 ) describe the ac t ions ; w h i c h have he en t a k e n

toward achieving compliance w i t h this Consent Order,

(2 ) i nc lude a l l resul ts o f s a m p l i n g and tests and a l l

other da ta rece ived by the R e s p o n d e n t , and ( 3 ) i n c l u d e

a l l plans; and procedures comple ted subsequent to EPA

a p p r o v a l of the RI and FS W o r k p l a n s d u r i n g the past:

m o n t h „ as w e l l as such ac t i ons , d a t a , and p l a n s w h i c h are

schedu led for the n e x t m o n t h , . These reports? are to be

' s u b m i t t e d to E P A by the t e n t h day of each mon th f o l l o w

i n g the e f f e c t i v e date of t h i s Consen t Order, .

J R . The R e s p o n d e n t sha l l p r o v i d e d r a f t a n d f i n a l PT a n d F S

Repor t s to E P A according to the schedule con ta ined i n

A t t a c h m e n t C.

!! 9 . E P A. wi 1 1. r

... i 4 part thereof:. In the event of any disapproval, FPA

w i l l specify in writing both the d e f i c i e n c i e s and the

reaso n s F or such d i s approva 1..

40. Within thirty (30) calendar days of. receipt of EPA

in ot i f: i. c a t i. on o f p re L i. m i n a ry o r f i na 1. re poct d i s a p p ro v a 1,

ot: such addition.:!], time reasonably necessary by the

Respondent and approved by EPA, the Respondent

shall amend and submit to EPA such revised reports.

In the event of disapproval, EPA retains the right

to amend such reports, to perform additional studies,

and to conduct an RI, FS or complete RI/PR pursuant

to its authority under CEPCLA, as amended by SARA.

41 ,. Documents, including reports, approvals, disapprovals,

and other correspondence, to be submitted pursuant to

this Consent Order,, shall be sent, to the following

addresses or to such cither addresses as the Respondent

o r E P A he r e a f: t e r ma y de s i gn a t e i n wr i. t i n g :

I I Documents to be submitted to RPA should be sent tn:

(4 copies)

Kenneth Wenger E nv i. ron me n t a 1 P rot ec t i on Age n cy W a s t e M a n a gem e n t D i v i. s i o n J FK Fede ra I Flu i Ld i. ng - HSV-1 9 0 7 Boston, MA 0 2 2 0 3

2 ) Documents to be s u b m i t t e d to the Responden t s h o u l d he

s e n t t o : Th oma s E . Wr igh t , E xe c u t i v e ll i. re c t o r R . I ,, So 1 i d Was t e Mia na ye me n t C o rp o ra t i on 39 P i k e SI: ,. Providence, , R . I . 0290"!

- 1 5

4 2 . The R e s p o n d e n t , s h a l l make Lhe r e s u l t s of a l l s a m p l i n g

a n d / o r tests or o t h e r d a t a genera ted by Lhe R e s p o n d e n t /

o r on the R e s p o n d e n t ' s b e h a l f , w i t h respect to t h e

i m p 1 e m e n t: a 1i o n o f 1: h i. s C o n s ein t 0 t:d e i:, av a i 1a b 1 e to L F A

a n d s h a 11 s u b rn 11 t: h e se r e s u 11s i n mo n t h 1 y pr o g re s s i: e •-•

por ts as desc r ibed in P a r a g r a p h 37 and A t t a c h m e n t C to

th i s Co risen t Otrd er,

EPA w i l l make a v a i l a b l e to t he Respondent the r e s u l t s o f :

s amp 11 ng a nd /o r t e s t: s o t: o t: h e t: d a t a s im i1 a r 1 y g e n e i: a t ed b y

E P A .

At the request : of : E P A , the Responden t s h a l l a l l o w s p l i t o it-

d u p l i c a t e samples to be t aken by E P A and/or its a u t h o r i z e d

t: e p r es e n t a t i v e s, o f any s am p 1 e s co 1. .1 e c t ed by t.h e R e s poin d e n t

p u r s u a n t : to the i m p l e m e n t a t i o n of: t h i s Con sent O r d e r . The

R e s p o n d e n t sha l l n o t i f y EPA not less than 5 d a y s in advance

o f a n y s a m p 1 e c o 1.1 e c 11on a c t:i v i t y .

4 3. E P A a nd / o r a n y E PA a u t h o r i z ed r e p r e s e n t a t i v e s h a 1 1

h a v e the a u t h o r i t y to e n t e r and f r e e l y move about: a l l

property at the S i te at all reasonable t imes for the

purposes o f : , in te r a 1i_a:_ i n spec t ing and copying r e c o r d s ,

o p e r a t i n g logs, and c o n t r a c t s r e l a t ed to the S i t e ;

r e v i e w i n g the progress of the Respondent in c a r r y i n g out

t h e terms o f t h i s Consent O r d e r ; c o n d u c t i n g such t e s t s a s

EPA or t h e P r o j e c t C o o r d i n a t o r deem neces sa ry ; us i n-j a

a c a m e r a , sound r e c o r d i n g / o r o t h e r d o c u m e n t a r y t y p e

c q u L p men t:; and v e r i f: y .1 n g t: h e d a t a s u b n 111 ed t o E P A

by the Fie 3 pond en t:,, The R e s p o n d e n t s h a l l p e r m i t : such

... i 6

persons to inspect and vr i . l l , upon reques t , p rovide cop ie s

of a l l records, f i l e s , photographs , document ' s , and o ther

wr i. 11ngs , in c .1 ud 1 ng a 11 s .amp 1 i ng and mon 11:o r i nq d a t a,

in any way p e r t a i n i n g to work u n d e r t a k e n p u r s u a n t to

t h i s Consent Order. A l l par t ies w i t h access to the

Site p u r s u a n t to this paragraph shal l comply wi th a l l

approved hea l th and safe ty plans. Re a so in .able e f f o r t s w i l l

be made to conduct work dur ing normal l a n d f i l l operat ing

hour s, and w i t h a m i n i m u m of: i n t e r f e r e n c e w i t h the ope cat ion

o f t h e 1 and f: i 1 1 . The pro v i. s io n s o i: t hi s o t: d e r in n o way

l i m i t E P A ' s au thor i ty under § 3007 of: RCRA and § 104

of C B R C L A , as amended by SARA.

44 . The Respondent may assert, a c o n f i d e n t i a l i t y c l a i m , i E:

appropr ia te , covering part 01: al l of: the i n f o r m a t i o n

requested by t h i s Consent Order: pursuant to 40 C . F . R .

§ 2 . 2 0 3 ( b ) an d S e c 11 on 10 4 (e ) ( 1 ) o f C ER C LA, a s a me nd eel by

SARA. Such an assertion sha l l be adequately substant iated

when the assertion is made. Analytical data s ha. 1.1 not be

claimed as conf ident ia l by the Respondent. Intormation

determined to be conf ident ia l by EPA wil l be a f fo rded the

pro tec t ion specified in 40 C . . F . R , Par t 2, Subpart B, and

in Sect ion 1 0 4 ( e ) ( 7 ) of: C K R C L A , as amended by SARA. I f

no such c l a i n accompanies the i n f o r m a t i o n when i t i s

s u b m i t t e d to E P A , i t may b e made a v a i l a b l e to t h e p u b l i c

by C P A w 11: ho u t: f u r t. h e r n o t i c e t o t h e R e s po n d e n t.,.

- ] 7

45. W h e n e v e r n o t i c e is r e q u i r e d t.o be g i v e n or a repor t ,

or p l a n is r e q u i r e d to be f o r w a r d e d by one p a r t y to a n o t h e r ,

i t s h a l l be d i r e c t e d to the D e s i g n a t e d C o o r d i n a t o r s s p e c i f i e d

in Par,:i g raph 4 1 .

4 6 . E P A ' s D e s i g n a t e d C o o r d i n a t o r s h a l l h a v e t h e a u t h o r i t y

vested i n the Remedia l P r o j e c t M a n a g e r by 40 C . F . P . P a r t 300 ,

i n c l u d i n g b u t n o t L i m i t e d t o t h e a u t h o r i t y t o s top work

b e i ng p e c f o r me d pu rs u a nt t o t h i. s Co n s e n t: 0 r d e r ,.

47 . T h i s Consen t Order s h a l l he e f f e c t i v e upon the s i g n i n g o f

t h e F e g i ona 1 Ad mi n i s t ra t: o r . A 1 1 t i mo s f o r p e r f or ma n ce o f

r e s p on s e a c t: i v 1 1 i e s s ha 1 .1 he c a 1 c u "I a t e d f: r om t h a t d

R T / F S W o r k p l a n . I n o rder to p r o v i d e q u a l i t y a s surance

a nd ma i n t a i n q \ i a 1 i t y co in t r o 1 re q a r d i ng a 11 s a m p 1 e

Spect romet ry , etc.) baken at regularly scheduled sample

times, may be provided to each laboratory for analysis.

49. R L S W M C s h a l l p reserve , d u r i n g bhe p e n d e n c y o f t h i s

Consent O r d e r a n d for a m i n i m u m of: s i x ( 6 ) years a f t e r -

app rova l of the f i n a l RI /F 'S , a 1.1 records and documen t s

in t h e i r : possession and in the possession of : t h e i r

d i. v i s i on s , em p 1 o y ee s , a ge n t s , a ccou n t a n t: s , c o nt r a ct or s ,

or a t t o r n e y s w h i c h relate;1 i n any w a y to the s i t e ,

desp i t e a n y d o c u m e n t r e t e n t i o n p o l i c y to the

c o n t r a r y , A f t e r t h i s s ix . year pe r iod , the Responden t

s h a l l n o t i f y EPA w i t h i n 30 c a l e n d a r days p r io r to the

des t ruc t ion of any sue hi d o c u m e n t s . Upon request by E P A ,

the Responden t sha l l make a v a i l a b l e to EPA such records

or copies of a n y such records,, A d d i t i o n a l l y , , i f IE PA

reques ts that some or al l document::; he preserved fo r a

longer p e r i o d of t i m e , t he Responden t s h a l l comply w i t h

t ha t reques t „

I? I s PJHF R ES n L t] T r ON

50. If R1SWMC objects to any EPA no- 1: ice of disapproval or

decision made pursuant to this Consent Order,, RISWMC

shall notify EPA in writing of its objections within

fourteen (14) days of receipt, of the decision. EPA and

R 1 S WM C w i. 1. 1 t h e n h a v e a n a d c! 11 i o n a 1 F o u r t e e n (14) d a y s

from the receipt by EPA of the notification of objection

to reach agreement. [f agreement cannot be reached on

... 2 iQ

a n y issue w i t h i n t h i s f o u r t e e n ( 1 . 4 ) day p e r i o d , H PA s h a l l

i mme d i. a t e 1 y p r ov i de a wr i t t en a t 3 t erne n t o f 1 t c=. d Pc i. a i on

to R I S W M C . Respondent sha l l not: be deemed oi.it: of

compl i ance w i t h t h i s Consent O r d e r d u r i n g t h e p e n d e n c y

o f a n y d i s p u t e t: e s o 1 u t i. o n p r o c e e d i n g s d e s c r i he d i n t h i ::>

p a r a g r a p h .

- P R F O R M A N C V S T r P l J L A T E D F ™ A/n: ? S

51 . A. The; p a r t i e s agree t h a t the t i m e l y conplet ion of

t h e work r equ i r ed by th is Orde r is i m p o r t a n t . The p a r t i e s

t o t h i s 0 r d e t: s h a 1 1 u s e t h e i r b e s t e f: f o r t s a n d s h a 1 1

u n d e r t a k e a l l reasonable m e a s u r e s to e n s u r e t h a t the t i m e

r equ i r emen t s s e t f o r t h i n t h i s O r d e r a r e met .

B « I f: a ny e v e n t o c c u r i w h i c h c a u s e s d e 1. a y i n t h e a r h i v e

merit of the r e q u i r e m e n t s of: t h i s Consent O r d e r , the

R e s p o n d e n t sha l l , have the b u r d e n o f ! p r o v i n g t h a t the

delay was caused by c i r c u m s t a n c e s beyond the reasonab le

control of: the Respondent w h i c h c o u l d not have been

overcome by clue d i l i gence , . The Respondent: s h a l l , p r o m p t l y

n o t i f y E PA ' s D e s i g n a t e d C o o r d i n a t o r o r a 11 y a n d s h q 11 ,

w i t h i n seven ( 7 ) business days of o ra l n o t i f i c a t i o n to

EPA, n o t i f y EPA i n w r i t i n g of the a n t i c i p a t e d l eng th a n d

cause of the d e l a y , the measures t a k e n and /or to be t a k e n

to p r e v e n t o r m i n i m i z e the d ^ l a y , a n d the t i m e t a b l e by

w h i c h t h e R e s p o n d e n t i n t e n d s t o i m p l e m e n t these m e a s u r e s .

I f t he pai r t ie- ; can agree t h a t t h e d e l a y or a n t i c i p a t e d

-- 2 1

delay has been or will be caused by circumstances beyond

the reasonable control, of: the Respondent, the t imp for

performance hereunder shall be extended for a period

equal to the delay resulting from such circumstances,

The Respond e n t sha 11 a d op t a 11 reason a b 1 e me a su res t o

avoid or minimize delay. Failure of the Respondent: to

comply with the notice requirements of this paragraph

shall constitute a waiver of the Respondent's right: to

request a waiver of the requirements of this Consent

Order. Increased costs of performance of the terms of

this Consent Order or changed economic circumstances

shall not be considered circumstances beyond the reason

able control), of the Respondent,.

In the event that EPA and the Respondent cannot (agree

that any delay in achievement of the requirements of this

Consent Order, including the failure to submit any report

or document, has been or w i l l be caused by circumstances

beyond the reasonable control of the Respondent:,, the

dispute shall be resolved in accordance with the provi

sions of Paragraph 50 hereof.,

C. Except as excused pursuant to Subparagraph R, above,,

RISWMC shall be liable to pay the following stipulated

p enalties for failure to comply w i t h ;iny time deadlines

e s t: a b I i. s hed p«j r R u a n t t o t h i s Co n s e n t O r d e r, i nc ] u d i nn

-22

Per i od o f: F a_ i l_u re Jto_Com£ 1 y P e n a 1 ): % Pe r Da_y_

1st - 14th day S i n n . 00

15tht - 28th day S 2 5 0 . 0 0

B e y o n d 2 8t h d a y S ]. , 0 0 0 . 0 0

A n y s u c h p e n a 1 1y s h a L 1 be du e a n d p a y a b 1 e t e n ( 1 0 'I d a y s

f o l l o w i n g r e c e i p t of a w r i t t e n demand by E p A . Payment- of

any such p e n a l t y shal l be made by c e r t i f i e d c h e c k pay* h iP

t o Treasurer , , U n i t e d States o f A m e r i c a , and n a i l e d to the

f o l l o w i n g address w i t h

- 23

a ge n t. s , con s u L t a n t s o r co n t. r s c t o r s i n r a r r yr i n g o 111 t h e

a c t i v 11 ies pu r s u a n t: t: o t Ih i s 0r cl P r.

RE I _M_B URS_EME_N_T_n_F_ _C _OSTS

53 . A t the end of each year , EPA s h a l l ' submit to R I SWMC an

a cc ou in t. i rig o f: a 11 c o s ts i nc u r r P d h y t: h e I J . S „ Gov e r rime n t:

in overseeing and r e v i e w i n g the conduct: of the R I / F S u n d e r

t h i s Consent: Order., Rl SWMC agrees , w i t h i n 30 c a l e n d a r days

of receipt of t h a t a c c o u n t i n g , , to r e m i t : a check f o r t he

a m o u n t o f : those cos ts made p a y a b l e to the H a z a r d o u s

Substances Supe r f u n d , . Checks should spec if ical ly re fe rence

t h e id e n t i t y o f t h e s i t e a nd b e a d cl r e s s ed t o:

U . S. E n v i. r on m e n t a 1 Pro t e c t i o n A g e n c y Ac c ou nt i ng Op e r a t i on s O f f i ce ( P M - 2 2 f i )

P .O. Box 2 9 7 1 , Room M - 3 4 1 9 W a s h i n g t o n , D . C , 2 0 0 1 3

A t: t e n t: i o n : [ Co .11 e c t: i o n Of 1: i

.... 2 4

OTH]ER_LAWS

54 . A I L .act ions requi red to be t a k e n p u r s u a n t to t h i s Order sha l l

be u n d e r t a k e n in accordance w i t h the r equ i r emen t s of: a l l

app l i cab le s ta te and federal laws and r egu l a t i ons , i n c l u d i n g

laws r e l a t i n g to occupat iona l s a f e t y and h e a l t h , and in

accordance w i t h app l icab le requ i rements , of o ther f e d e r a l

e n v i r o n m e n t a l laws, , as d e f i n e d in c u r r e n t EPA pol icy, .

In the event tha t there is a c o n f l i c t in the app l i ca t i on

of: f e d e r a l or s ta te laves or r egu la t i ons , , the more s t r i ngen t

of the c o n f l i c t i n g provis ions sha l l a p p l y ,

55. This Consent Order may be amended by mutua l agreement

of: the part ies . Any such amendment ( s ) shal l be in w r i t i n g ,

J?ROC£DUREJR2R_RJ:2/^

56. Except: for the FS W o r k p l a n , the d r a f t and f i n a l RI

Repor ts , and the d r a f t and f i n a l FS Reports w h i c h are

governed by Paragraphs 32-36 and 38-40, EPA w i l l rev iew

all P l a n s , Reports and other del iverabl .es ( R e p o r t s )

s u b m i t t e d by Respondent to de te rmine whe the r they are

cons i s t en t w i t h the requi rements of the W o r k p l a n and

the Consen t Order., I f EPA de te rm tries that r ev i s ions to

a Repor t are necessary , , EPA w i l l n o t i f y 'Respondent o f

IS P A ' s requested r ev i s ions , a n d , to the e x t e n t necessary

http:deliverabl.es

otr cles i rab .1 e, K PA an d Responde n t s ha 1.1 e xped i t i ou s 1y

c o n f: e r t o d i s cu E; s Ei; P A " s p r opo s e d r e v i s ion p, „ P e s p on d e n t

shell..I. t h e n submi t , a d r a f t of t he Report: a c c e p t a b l e to

E P A i n accordance w i t h a d e a d l i n e For r e v i s i o n set by

EPA w h i c h is a p p r o p r i a t e to the n a t u r e a n d e x t e n t of

t he proposed r ev i s ions . I f R e s p o n d e n t f a i l s to s u b m i t

a re v i. s e d Re p o t: t w i. t h i. n t h e s p e c i f i e d de a d 1 i n e,, t h e n

EPA may invoke the provisions of paragraph 50,. T i:

Respondent submi t s a revised Report w i t h i n the d e a d l i n e

but: EPA d e t e r m i n e s t ha t a l l or part, of : the r e v i s e d

Report: f a i l s to comply w i t h the s p e c i f i c a t i o n s of th is

Consent : Order o r w i t h F P A ' s r e q u e s t f o r r e v i s i o n s , , t h e n

E P A s h a l l , so n o t i f y Respondent and E P A may t h e n i n v o k e the

d i s pu t e r e s o 1 u t: i on p r o ce du r e s o I: p a r a g r a p h 5 0 . r> u r i n g t h e

period of any d i spu te c e s o l u t i o n i n v o k e d under the c i r c u m

s t ances of the p r e c e d i n g sentence, , p e n a l t i e s s h a l l not be

assessed u n d e r pa rag raph 51 fo r de lay i n p r o v i d i n g a s a t i s ™

f a c t or y re v i s ed Re p o r t. 1f «_ h e d i. s pute r e s o 1. u t i on pro c e du r e

invoked he re in re su i t is i n agreement: between Respondent:

and EPA on all issues referred to it, then a m o d i f i e d

Report, r e f l e c t i n g a l l of the ag reemen t s reached i n the

d i spu te r e so lu t ion procedure s h a l l be s u b m i t t e d to F P A

f o r f i n a l r e v i e w a n d approval , . EPA w i l l , p rov ide w r i t t e n

n o t i c e to Responden t when a Repor t has been q i v e n F i n a l

a p p r o va 1 u n d e r t h i s p a r a g r a p h , w h e r e u p on t h e i m p 1 e m e n t

-26

subsequen t pa r t s of: t h e w o r k p l a n to t h e e x t e n t : t h a t

such w o r k can he done I n d e p e n d e n t l y of EPA comment and

a p p r o va L o E: a p re ce d i. n g R e por t ..

U p o n s a t i. s f: a c t: i o n o 1! i. I: s o h 1 i. g a t i. ons u n d e r t hi i s C n n s e n t

Order E P A w i l l issue a c e r t i f i c a t e to the Respondent:

t hi a t i t s r e s p on s i b i 1 i t i e s un d e r t: h i s C o n s e n t O r d e r h ave

been c o m p l e t e l y and s u c c e s s f u l l y d i s c h a r g e d and pe r fo rmed

in accordance w i t h the p r o v i s i o n s of CERCLA , as amended

by S A R A , and the N C R ,

5 "7 . N o t w i t h s t a n d i. n g c omp .1. i a n c e w i t h t h e t e r irn s o (! t h i s

Consent Orde r , i n c l u d i n g the comple t ion of an RPA

a p p r ov e d R e me cl i. a 1 1 n v e s t i g a t i o n a n cl F e a s i b i 1 i. t y S t udy ,

the Respondent is not released f r o m l i a b i l i t y , i f a n y ,

f o r a n y a c t i o ns b e y o n d t he t e r ms o f t h i s C on s e n t: 0 r d e r

t a k e n by EPA respect ing the Si te . RPA reserves the

r i g h t to take a n y e n f o r c e m e n t ac t ion p u r s u a n t t o C E R C L A ,

as amended by SARA,, and/or any other a v a i l a b l e legal

a u t h o r i t y , i n c 1 u d i n g t he r :i ght t o s e e k i. nj u n c t i. ve re 1 1 e f ,

mi o n e t a r y p e na .1. t: i e s , a n d pu n i (• i v e d a PI a g e s f o r a ny v i o 1. a t i o n

of l a w our t h i s Consent. Order. This Consen t Order does not

c o n s t i t u t e any dec is ion on p reau thor i za t ion of f u n d s u n d e r

Sec t ion 1 1 1 ( a ) ( 2 ) of C E R C L A , as amended by S A R A . Work

p e r f o r m e d he ire u n d e r does not re lease R'[ SWMf f r o m , or l i m i t

E P A a u t h o r i t y t o r e q u i r e , , a r e m e d i a l d e s i g n ( R D ) a n d r e m e d i a l

a c t i o n ( R A ) f o r t h e s i te .

- 2 7 .

5 8 . I f , i n t h e course o f : p e r f o r m a n c ? o f t h e a c t i o n s r e q u i r e d

by t h i. s Co n s e n t 0 r d e r, E P A he 1 i e v es t h a t: R ] S WM C h a s

H a i l e d to comply ma t e r i. a 11y w i t h any of the p rov is ion ; : ,

of t h i s C o n s e n t O r d e r , EPA w i l l s u b m i t to PT SWMC A

w r i 11 e n n o t i ce o f 11s d e t: e r n i n a t i o n , w h i ch n o t i ce s ha 1 .1

i n c lude a d e s c r i p t i o n of the a c t i o n ' s needed t o remedy the

n on •••

• 2 8

ET IS SO AGREED AMD ORDERED Bt:

L Wiclhci el. 'R . Del. and Reg i ona .1. A dm i. n i s t ra t or Env i r on me n t a 1 Pr otec 11on Ag e n cy

Date

I. T IS SO A G R E E D :

s1 an d So 1 i. d Was t: e 'Wa na ge me n t •poration

Joseph H. 0" Donne 11, Jr., Chairman

Da t e

ATTACHMENT A

R EVI S ED P F 0 PO S A L F O R S A M P L I. N G ,

A N A LY SI S , MOM I TO RI NIG AN D R E FOR T [ NG O F

C O N D I T I O N S A T T H E C E N T R A L L A N D F I L L

J O H N S T O N , , RHODE: I S L A N D

Submitted by:

Rhode Island Solid Waste Management Corporation

February 1985

REVISED PROPOSAL FOR SAMPLING,

ANALYSIS, MONITORING AND REPORTING OF

CONDITIONS AT THE CENTRAL LANDFILL

JOHNSTON, RHODE ISLAND

Submitted by:

Rhode Island Solid Waste Management Corporation

1 ̂ ^L,

February 1985

i/

WEHRAN ENGINEERING Consulting Engineers

February 26, 1985

Mr. Ronald T. Delfino, Director Engineering and Operations Rhode Island Solid Waste Management Corporation 39 Pike Street Providence, RI 02903

RE: Revised Proposal for Sampling Analysis,

Monitoring, and Reporting of

Conditions at the Central Landfill

Johnston, Rhode Island

USEPA Docket No. 84-1045

(WE Project No. 02254324/C-l)

Dear Mr. Delfino:

Enclosed is our revised proposal for sampling analysis, monitoring, and reporting of conditions at the Central Landfill. This proposal was revised in accordance with comments contained in a letter from the United States Environmental Protection Agency (USEPA) which was received on January 28, 1985, and based on discussions at a meeting with the USEPA on February 1, 1985. We believe that this proposal addresses all the issues raised by the USEPA.

Please call us if you have any questions.

Very truly yours,

Joseph J. Gurda, P. E. Vice-President Wehran Engineering Corporation

Michael A. Powers Associate Goldberg-Zoino & Associates, Inc.

JJG/MAP/cas Enclosure

Research & Design Center:

666 East Main Street

Middletown, NY 10940

(914) 343-0660

A New York Professional Corporation • A New Jersey Business Corporation

TABLE OF CONTENTS

Page

1.00 INTRODUCTION 1

1.10 PURPOSE OF THE STUDY 1

1.2 0 PROPOSED STUDY SCOPE 1

1.30 PROJECT ORGANIZATION AND STAFFING 2

2.0 0 BACKGROUND INFORMATION 2

2.10 GEOLOGIC SETTING 3

2.2 0 PAST DISPOSAL PRACTICES 4

3.00 DATA EVALUATION 6

3.10 GROUNDWATER DATA EVALUATION 6

3.2 0 CONTAMINANT IDENTIFICATION 7

3.30 EXISTING DATA DEFICIENCIES 8

3.31 Landfill Monitoring Wells 8

3.32 Private Domestic Supply Wells 8

3.33 Integrity of Monitoring Wells 9

3.34 Sampling and Analysis Regularity 9

4.00 FIELD STUDY PLAN 9

4.10 RESIDENTIAL WELL SAMPLING 9

4.2 0 BEDROCK FRACTURE TRACE ANALYSIS 10

4.21 Viewing of the Photographs 11

4.22 Key Recognition Elements 11

4.23 Trace Analysis Utilization 12

4.30 EARTH RESISTIVITY SURVEY 12

4.31 Sounding Survey 13

4.32 Profiling Survey 14

4.4 0 MAGNETIC GRADIOMETER SURVEY 14

4.5 0 SEISMIC REFRACTION INVESTIGATION 15

4.6 0 AIR QUALITY SURVEY 15

4.70 SUBSURFACE EXPLORATION PROGRAM 17

4.71 Vertical Seismic Profiling 17

4.72 In-Situ Bedrock Permeability

Evaluation 18

4.73 Test Pit Explorations 18

4.80 MONITOR WELL INSTALLATION 19

4.90 SAMPLE COLLECTION 19

4.91 Groundwater Sampling 19

4.92 Surface Water and Sediment Sampling 20

4.93 Subsurface Soil Samples 20

5.00 LABORATORY ANALYSES 20

6.00 DATA EVALUATION AND REPORTING 21

6.10 DATA EVALUATION 21

6.11 Groundwater Quality Evaluation 21

6.12 Surface Water Quality Evaluation 22

6.2 0 PROGRESS REPORT 22

6.3 0 FINAL REPORT 23

7.0 0 PROJECT SCHEDULE 23

TABLES

TABLE NO. 1 SUMMARY OF DATA SEARCH

TABLE NO. 2 ESTIMATED AGE OF TONNAGE IN PLACE AT THE

CENTRAL LANDFILL

TABLE NO. 3 SOURCES OF CURRENT LANDFILL MATERIAL

TABLE NO. 4 OBSERVATION WELL DATA

TABLE NO. 5 PROPOSED BORING LOCATION DATA

TABLE NO. 6 ESTIMATED SCOPE OF CHEMICAL ANALYSES

FIGURES

FIGURE NO. 1 PROJECT LOCUS

FIGURE NO. 2

FIGURE NO. 3

FIGURE NO. 4

FIGURE NO. 5

FIGURE NO. 6

FIGURE NO. J

APPENDICES

APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

EXISTING MONITORING WELLS

GROUNDWATER CONTOURS

PROPOSED ELECTRICAL RESISTIVITY SURVEY

PROPOSED TEST DRILLING LOCATIONS

PROPOSED SURFACE WATER SAMPLING LOCATIONS

BEDROCK CONTOURS

RESUMES

GOUNDWATER QUALITY DATA

QA PLAN

HEALTH AND SAFETY PLAN

1.00 INTRODDCTION

This document is a technical proposal for sampling, analysis,

monitoring, and reporting of hydrogeologic conditions at the

Central Landfill in Johnston. Rhode Island. Refer tO Figure

1 for a proiect locus plan. This study plan was prepared for

the Rhode Island Solid Waste Management Corporation (RISWMC)

by Wehran Engineering and Goldberg-Zoino & Associates (the Proiect

Team^ in response to EPA's comments (forwarded to RISWMC on

January 28. 1985^ on an October 5. 1984 study plan.

That October 5. 1984 document was prepared in response to an

administrative order. Docket No. 84-1045. issued to RISWMC on

June 29. 1984. Major revisions to the earlier study plan are

delineated in this document by underscoring.

1.10 PURPOSE OF THE STUDY

The overall purpose of the study is to evaluate the effects

that the landfill has had, and may have on the environment and

human health. The issues to be addressed are: the types of

contaminants present in the landfill, the pathways by which

the identified contaminants may enter the environment and, the

potential effects that landfill contaminants may have on potential

receptors.

The end product of the study will be a report which will: detail

all investigations undertaken as a part of the study, describe

the studies findings, and provide appropriate conclusions and

recommendations. The principal objectives of the report are

to: identify the major effects that the landfill may have already

had on the environment, assess the likely effects that the landfill

may have on the environment in the future and, if necessary,

provide recommendations to reduce significant adverse effects

of the landfill on the environment and/or human health.

1.20 PROPOSED STUDY SCOPE

The scope of the proposed study was developed based on: the

Project Team's experience with similar projects, the hydrogeologic

setting in which the landfill was developed, existing available

information, requirements of the United States Environmental

Protection Agency and the Rhode Island Department of Environmental

Management, and the desire of the RISWMC to run an environmentally

safe and cost-effective landfilling operation.

The types of contaminants which are in the landfill have been

tentatively identified by a review of past disposal practices.

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These findings will be substantiated by the collection and testing

of samples from within the landfill debris. The two major potential

pathways of contaminant migration have been identified as groundwater

flow, including groundwater migration within the bedrock, and

wind blown dust particles. Identifiable potential receptors

of contamination are residential supply wells. Cedar Swamp Brook,

and the Simmons Reservoirs. Additional studies will be undertaken

to evaluate the effect of the landfill, if any, on the Almy

and Scituate Reservoirs, and residential wells within these

watersheds.

1.30 PROJECT ORGANIZATION AND STAFFING

The study will be completed for RISWMC by the project team with

support from specialty subcontractors. Specifically, chemical

analyses will be performed by Rhode Island Analytical Laboratories

of Warwick, Rhode Island, and test drilling to be provided by

contractors to be selected on the basis of solicited proposals.

The Project Team is under the direction of Richard A. Peluso,

P.E., Senior Vice-President of Wehran Engineering Corporation.

Mr. Peluso will review the performance of the project team and

monitor the project's progress. Assisting the Project Director

in management tasks will be Joseph J. Gurda, P.E., Senior Engineer

and Project Manager for Wehran. The Project Manager will administer

all technical tasks and subtasks, provide coordination with

the Project Director, and maintain communication with the Rhode

Island Solid Waste Management Corporation representatives.

William J. Siok, Senior Hydrogeologist and Director of Wehran's

New England office, will serve as Wehran's manager for the site

investigations.

The hydrogeologic study team is under the overall direction

of Michael A. Powers, P.E. of Goldberg-Zoino & Associates. Mr. Pow

ers will continuously monitor all the major technical aspects

of the hydrogeologic site investigation. Michael F. Conway,

as GZA's Project Manager, will coordinate the daily investigative

and analytical tasks of the investigation.

Assisting RISWMC will be Mr. Anthony Perrotti, Rhode Island

Analytical Laboratory's Director, who will oversee all chemical

analytical work. Resumes of the above key team members are presented

as Appendix A.

2.00 BACKGROUND INFORMATION

There exists, through a variety of sources, a considerable amount

of information regarding conditions at the Central Landfill.

As an initial task much of this information was collected, organized

-2

and evaluated. As additional information is received it will

be incorporated into the data base.

Table 1 presents a summary of the contacts made to date and

the types of information made available to the Project Teayn.

In general the information assembled can be divided into two

categories; that relating to the hydrogeologic setting, and

that regarding the types and quantities of wastes that were

reportedly disposed of at the site and which have been detected

in the area's groundwaters. The following sub-sections provide

a brief overview of background information. Project Team evaluations

of that data are presented in Section 3.00.

2.10 GEOLOGIC SETTING

The Central Landfill study area and its immediate environs are

underlain by shallow bedrock and unconsolidated sediments primarily

of glacial origin. The general geologic sequence consists of

a met a-igneous bedrock, glacial till, glacial outwash, and subsequent

recent swamp deposits.

According to the published interpretation of surficial geology

of the site environs as mapped by Robinsond) , the glacial sediments

at the landfill consist of till, deposited at the base of advancing

ice or deposited directly from within the wasting ice mass.

Outwash deposits are found in the southeast portion of the landfill

site along Cedar Swamp Brook, and peripheral to the southeast

of the landfill along the walls of the valley occupied by the

Simmons Upper and Lower Reservoirs. The outwash materials were

deposited by flow between the valley walls and an ice mass remaining

in the center of the valley.

Generally, in terms of site hydrogeology, local topography,

shallow but typically dense bedrock, and a limited thickness

of till cover appear to focus the direction of both surface

and groundwater flow from the landfill area to the outwash aquifer

southeast of the study area.

Bedrock underlying the landfill site and the majority of the

North Scituate Quadrangle has been mapped by Quinn (2) as the

Scituate Granite Gneiss, a meta-igneous intrusive unit. This

rock is primarily crystalline, exhibiting foliation, which has

been attributed to magmatic flow. The rock fabric is essentially

impermeable with groundwater flow being limited to cracks and

fissures within the rock mass. A limited review of private

supply v;ell data indicates that wells developed in the rock

typically have yields of less than 5 gallons per minute (GPM) .

Observations of visible exposures generally confirmed bedrock

underlying the site to be dense, crystalline, and of granitic

composition. Rock along the western periphery of the active

-3

landfill area was highly fractured and exhibited three principal

joint orientations.

Fracture density may be reflective of rock blasting during past

quarry operations at the site. Fracture continuity, depth and

areal extent under the study area will be further evaluated

by fracture trace analysis and rock core test drilling. See

Section.q 5.00 and 5.70.

Unconsolidated sediments overlying bedrock over the RISWMC property

consist of glacial till. Till is generally a dense, poorly

sorted material deposited directly by glacial ice and consisting

of sediments ranging in size from clay to boulders. The till

in the North Scituate Quadrangle has been described as generally

sandy, consisting of boulders, pebbles, sands and silt, and

generally less than 5% clay sized particles. A more compact

till, with a lower percentage of pebble sizes and a higher clay-size

content is reported to occur to the southwest at Lawton Hill,

along the south periphery and in the northeast portion of the

study area. Due to its dense, unsorted nature, glacial till

is generally of low permeability. Published literature indicates (3)

that domestic supply wells developed in the till generally provide

sustained yields on the order of 5 GPM or less.

Glacial outwash deposits in the study area are limited to the

Cedar Swamp Brook valley and the valley occupied by the Simmons

Reservoirs southeast of the Central Landfill. These deposits

are mapped by Robinsond) as paired kame terraces formed by

the deposition of sediments by flow between the valley walls

and an ice mass remaining in the center of the valley. Robinson

characterizes these outwash sediments largely as variable in

gain-size composition, sorting and stratification. Published

literature (2) indicates that supply well yield in outwash sands

and gravels in the vicinity of the Simmons Reservoirs to be

potentially 100 to 300 GPM.

Past sand and gravel/rock quarry operations and subsequent landfilling operations have largely altered original kame geomorphology

at the southeast portion of RISWMC site. The depth and extent

of the more permeable, sands and gravels characteristic of deposits

remaining on site and potentially in hydraulic connection with

the kame terrace deposits along the Simmons Reservoir valley

walls will be evaluated by test pits and borings.

2.20 PAST DISPOSAL PRACTICES

In 1952, Silvestri Brothers purchased part of the present Central

rohnston, Rhode Island. From 1952 to 1955, Landfill Site in Johns

the area in question was used to conduct a combination sand

& gravel/quarry stone operation. In 1955, Silvestri Brothers

started a refuse burning dump on the 65 acre site. Due to public

-4

health concerns with burning wastes in an open area, Silvestri

Brothers discontinued burning solid waste and started burying

disposed materials in 1962.

Until its sale to the RISWMC on December 9, 1980, the 25 year-old

landfill had accepted approximately 5 million tons of municipal,

commercial, and industrial solid waste (for estimated tonnage,

see attached Table 2) . This landfill is presently the largest

sanitary landfill operation in the State of Rhode Island. Currently

27 of Rhode Island's 39 communities use the landfill. Private

carters also use the site. For more details, see attached Table 3.

The present 154 acre landfill (see Figure 2) includes a one-third

acre portion where approximately 1.5 million gallons of manifested

and reported hazardous waste from Rhode Island were disposed

of between December 3, 1976 and May 30, 1979. Within this hazardous

waste area, bulk liquid waste was dumped into 3 trenches that

had previously been excavated to bedrock. Throughout this three

year period, these trenches were left exposed to the elements.

This area was then used for disposal of sewage sludge until

July 1982 when it was capped with boulders. 5 feet of granular

fill. 20 feet of flv ash, a 20 mil PVC liner. 10 feet of fly

ash and a 2-foot granular fill cover.

The Rhode Island State Police have also investigated reports that prior to 1980 drums of chemicals were buried at the landfill. These allegations have been denied by the former operator of. the landfill. Other than the installation of monitoring wells, no explorations have been performed to substantiate these allegations. Information provided by the State Police will be used to locate test pits to be excavated as part of this study.

Hazardous waste manifests on file at Rhode Island Department

of Environmental Management (RIDEM) indicate that the wastes

disposed of at the former hazardous waste area include latex

waste, acid waste, corrosive waste, water soluble oils and waste

solvents, including methylene chloride, toulene, 1,1,1-trichloroethane and tetrachloroethylene. Monthly operating reports for

transporters on file at Massachusetts Department of Environmental

Quality Engineering (Mass. DEQE) indicate that an additional

1 million gallons of wastes including motor oils, industrial

oils and emulsions, solvents, lacquers, organic chemicals, inorganic

chemicals, cyanide, plating wastes, clay and filter media with

chemicals, plating sludge and oily solids were disposed of at

the site. These monthly operating reports are not structured

with the checks inherent to the post-CERCLA manifest system.

The previous landfill owner denies that some substances indicated

on these monthly reports were ever disposed of at the site.

From 1980 to 1983, the RISWMC operated two separate areas at

the Central Landfill: one area received between 1500-2000 tons/day

of solid waste, and the other received 225 tons/day of wastewater

-5

treatment plant sludge. Since obtaining ownership of the Central

Landfill, RISWMC has disposed of an annual average of approximately

one-half a million tons of solid waste and over 50 thousand

tons of municipal sludge. Within the last year, RISWMC has been

allowed to co-dispose municipal and industrial sludge with solid

waste throughout the active facility area.

In addition to the above materials the Central Landfill has

also received industrial waste products at an average rate of

approximately 100 tons per days. This material includes drums

of nnn-hazardous industrial waste products. All industrial

waste materials have been, on at least one occasion, tested

and approved for disposal by the RIDEM. For example, grab samples

iLf_products from the American Hoechst Corporation of Coventry

R.I. analyzed in September 1983 and February of 1984 and found

to be non-hazardous by the Rhode Island DEM.

In October and December 1984. samples of groundwater were collected

bvR.T. Analytical Laboratories (RIAL) from eight on-site monitoring

wells. These samples were analyzed by RIAL for pH. conductance.

chlorides, iron, the eight drinking water metals, and the volatile

organics on the EPA's list of priority pollutants. The results

of that testing were compared to previous on-site analytical

test data. In general . the results of the October and December

1984 testing fell within the range of previously reported test

results. While these data have not yet been subjected to a

statistical evaluation, the initial review suggests that niU

Evaluation of surface topography, bedrock contours, boring logs

from previous investigations, as well as water level elevations

in monitoring wells indicate that both surface runoff and groundwater

flow across most of the site largely tend in a generally south

easterly direction. Figure 3 provides a groundwater contour

map of conditions at the site, as interpreted from groundwater

elevation data collected in August, 1984. Figure 7 provides

a bedrock contour map depicting the results of previous subsurface

explorations. Refer to Table 4 for a summary of the actual

groundwater elevation data. Note that Figure 3 was developed

based on a limited amount of data and actual conditions may

vary from the conditions shown on Figure 3.

When the flow patterns suggested by Figure 3 are evaluated in

conjunction with available analytical data (see section 3.2)

it appears that a source of volatile organic contaminants exists

upgradient or to the northwest of observation well J. This

generally corresponds to the area where liquid chemical waste

were reportedly disposed. Well E, which is upgradient of both

well J and the liquid chemical waste area exhibits similar volatile

organics at levels one to two orders of magnitude lower than

have been detected at well J. Well M is. to the north of Well E

and appears to be in a separate water shed. Samples frPIH this

well also exhibit low levels of volatile organics, indicating

a potential for at least seasonal migration of landfill leachate

to the Almy Reservoir watershed.

Based on both chemical analytical data and reported geologic

information it appears that both the overburden and the bedrock

are possible pathways for contaminant migration. For example,

at the location of monitoring well cluster "B", the overburden

well generally exhibited higher concentrations of contaminant

than did the bedrock well, where as at cluster "C" the contaminant

concentrations in the rock and overburden are similar.

3.20 CONTAMINANT IDENTIFICATION

Based on reported disposal practice, and an evaluation of existing

groundwater analytical data, it appears that the primary contaminants

present in groundwater at the Central Landfill are volatile

organic compounds. The compound present in highest concentrations,

and accounting for the majority of the total volatile organics

detected, is chlorobenzene. Chlorobenzene has been reported

in concentrations as high as 34 parts per million (ppm) in ground

water at well J.

Graphical presentations of available landfill groundwater quality

data are presented in Appendix B. These bar graphs indicate

relative observation well contaminant levels at points in time.

The recurring apparent trend observed in these figures is that

well J exhibits contaminants at levels orders of magnitude higher

than the more downgradient wells.

-7

The current Occupational Safety and Health Administration (OSHA)

standard for exposure to chlorobenzene is 75 ppm in air averaged

over an eight hour work shift. No SNARL (Suggested No Adverse

Response Level) or RMCL (Recommended Maximum Contaminant Level)

values have been established for chlorobenzene in water. The

solubility of chlorobenzene in water is reported as 500 ppm

and the specific gravity is 1.1. Other contaminants reported

present in groundwater at the site include benzene, ethylbenzene,

xylene, toluene, 1,1,1 trichloroethane, tetrachloroethylene,

and dichloromethane. Review of available private domestic well

data indicates that chlorobenzene has not been reported present

and that 1,1,1 trichloroethane accounts for most of the volatile

organics reported present in the private wells.

3.30 EXISTING DATA DEFICIENCIES

A series of point-in-time analytical profiles have been developed

for the landfill observation wells. These are presented in

Appendix B. Recently acquired information i.e. well elevation

data, indicates that well M may not constitute an upgradient

point, therefore a basis for statistical evaluation of the down-

gradient concentrations may not exist.It appears that the protocol

or lack of adherence to same, in sampling observation/monitoring

wells and private domestic wells may constitute cause for caution

in using existing chemical information for detailed evaluations

of groundwater contamination. Recent testing performed for

RISWMC by Rhode Island Analytical (see Appendix B-l) does, however,

indicate these data may be useful in evaluating general groundwater

quality trends. The following subsections detail apparent data

deficiencies.

3.31 Landfill Monitoring Wells

Based on interviews of the RISWMC personnel who were charged

with sample collection, in "some" sample rounds observation

well groundwater samples were collected utilizing a "hand operated

bilge pump and a garden hose". Additionally, it appears no

attempts at pump and hose cleaning between sample collection

points or sampling rounds were made. A memorandum dated September

27, 1984 from RISWMC indicates sampling methodology followed

in other sample collection rounds deviates from current EPA

protocol. (See memo in Appendix D).

3.32 Private Domestic Supply Wells

According to Rhode Island Department of Health personnel

the sample collection protocol for private domestic well sampling

involved running the faucet for a prescribed period of time

(5 minutes) and then collecting a sample from the faucet. While

this method of sample collection might yield analytical results

which are representative of the quality of ingested water, the

-8

http:exist.It

reported levels may not adequately reflect the groundwater quality

at the point of extraction.

3.33 Integrity of Monitoring Wells

A basis from which to evaluate the integrity of existing

monitoring wells does not exist. The available boring logs

do not, in general, include installation details regarding placement

of screen packing or bentonite seals. At least one monitoring

well (well D) was observed to have a loosely placed protective

casing, and well A is reportedly so out of plumb that it cannot

be sampled by bailer. It was recently learned that additional

riser pipe had been installed on some wells to prevent their

loss due to landfill operations. This necessitated new topographic

survey of well elevations. This survey data has been utilized

to develop the groundwater contours presented in Figure 3.

3.34 Sampling and Analysis Regularity

The existing data indicates that not all wells were sampled

during each sample round and not all parameters were determined

for each sample. Thus it is difficult to separate temporal

from areal variations in chemical concentrations.

4.00 FIELD STUDY PLAN

Based on evaluation of available existing data and consideration

of the items discussed above, the following technical approach

is recommended. As the purpose of the study is investigative

by nature, the outlined sequence is necessarily conditional,

with each task relying, to some extent, on the results of the

previous task.

In an effort to insure that the proposed studies are performed

in a manner consistent with the NCP, 40 CFR Part 300, RCRA and

other applicable state and federal statutes, the project team

will discuss applicable sections of 40 CFR Part 300 with the

EPA project site manager prior to execution of any specific

task. All studies will be performed in accordance with the

requirements of the QA Plan (see Appendix C) and will follow

the guidelines presented in the health and safety plan (Appendix D) .

4.10 RESIDENTIAL WELL SAMPLING

Sampling and analysis of residential wells in the area of Central

Landfill has been conducted at irregular intervals and by v^i-ous

parties since 1980. Both the Rhode Island Department of /Health

|\ and a private analytical laboratory have reported the pfesencdx

of volatile organic contaminants in some residential wells

-9

In order to evaluate the potential effects of the landfill on

residential wells, water quality sampling and analyses will

be implemented. The residential well sampling will be conducted

in accordance with the project OA plan.

The program will be directed at identifying potential contaminant

receptors and will be performed as a phased program. Phase

I win include the sampling and analysis of approximately thirty

residences. The scope, number or need for subsequent phases

win he determined by the results of previous phases.

Phase I of this program will concentrate on homes using bedrock

wells as their primary source of drinking water. Additionallyf

the Phase I testing will be directed towards homes which are

close to the landfill and believed to be downgradient of the

site. The task of selecting potential residences to be tested

win he performed by the Project Team. Gaining access to these

homes will be accomplished jointly by the Solid Waste Corporation

and the US EPA.

Based on the recommendation of Mr. Donald Berger of the US EPA.

re.qjdential well sample collection will be from the kitchen

faucet, provided no home treatment system exists between the

faucet and the well. No sample will be collected after home

treatment systems. Sampling will be performed in accordance

with the project OA plan. The first set of samples will. in

a n cases. be analyzed for all compounds on the EPA's list of

priority pollutants.

At the recommendation of the EPA, and as part of Phase I. a

second sample set will be collected from the same locations

and under the same conditions within 7 days of the initial collection

date at each location. This second sample set will be analyzed

for the volatile organic chemicals on the EPA's list of priority

PQ.13utantS. As it is anticipated that volatile organic compounds

win constitute the majority of contaminants detected, the results

from this second sample set will serve to assess short term

temporal variations in water quality and will help establish

the degree of reproducability achieved.

4.20 BEDROCK FRACTURE TRACE ANALYSIS

Evaluation of available geologic information and observations

by geologists during field reconnaissance indicate that the

site is underlain by the Scituate Granite Gneiss.

Granite, in general, has a tendency to fracture in response

to stress conditions that occur during various episodes of the

geologic history.

An indication of the relative density and geographic orientation

of bedrock fractures, which is the major factor affecting bedrock

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hydraulic conductivity and groundwater flow patterns may be

determined through the trained geologic interpretation of appropriate

aerial photographs.

Geologic interpretation of aerial photographs is generally considered

to be a two-step process. The first step includes observation

and identification of features on the photographs. The second

step involves rational processing of this data in terms of geologic/hydrogeologic significance. The features of surface expression

used in photogeologic interpretation are identified on the basis

of recognition elements, characteristics of the photographs

that result from the scale selected, the rock types observed,

the overlying vegetation, and the soils of the terrain photographed;

and related factors.

4.21 Viewing of the Photographs

Photographs may be viewed singly as mosaics of photographs,

or as stereoscopic pairs. For the purposes of this study, stereo

scopic pair, will be utilized as more details such as fine lines

or textural differences are shown clearly in this mode. Such

clarity is in many places a direct result of the common association

of fine lines and textures with relief changes, which are exaggerated

in most stereoscopic models.

4.22 Key Recognition Elements

The elements to be evaluated in viewing aerial photographs

of this site are relative photographic tone, texture and pattern.

A. Photographic Tone

Photographic tone is considered to be fundamental to all

other recognition elements. Tones on conventional aerial

photography range from black through shades of gray to

white. Because of the ability of the human eye to differentiate

subtle tone changes, relative photographic tone is one

of the useful facets available to the geologist interpreting

aerial photographs.

The usefulness of photographic tone depends on the problem

under consideration and how tone is used in association

with the other recognition elements. This is particularly

useful in fracture trace analysis.

B. Texture

The term "texture" as it applies to aerial photography

interpretation has been defined as the "frequency of tone

change within the image, and is produced by an aggregate

of unit features too small to be clearly discerned individually

on the photograph" (Colwell 1952).

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Texture in the photographic sense is actually a feature

composed of several characteristics, including photographic

tone, shape, size, and pattern and observation of all these

factors is necessary when applying this recognition factor

to fracture trace analysis.

C. Pattern

Pattern refers to the orderly spatial arrangement of geologic,

topographic, or vegetative features on a photograph.

Patterns resulting from particular distributions of lines

are frequently of structural significance, representing

possible expressions of faults, joints, or fractures indicative

of hydrogeologically significant areas.

4.23 Trace Analysis Utilization

The results of the fracture trace analysis will be interpreted

and used to evaluate proposed locations for the bedrock observation

well installations.

4.30 EARTH RESISTIVITY SURVEY

Approximately 3000-foot of electrical resistivity determinations

will be run in the approximate location indicated on Figure

4. The earth resistivity geophysical technique provides a method

for shallow subsurface investigation by the means of electrical

measurements taken at the ground surface. This method has been

well documented in the literature as being a useful and reliable

method for delineating the approximate locations of groundwater

contamination plumes. In addition, it is much less expensive

than drilling wells, extracting, and analyzing water samples.

Earth resistivity study is a technique for measuring the variations

of subsurface geologic strata by passing successive electrical

currents through the earth's surface in the area of interest

and measuring resultant voltage drops between input and measuring

electrodes. Earth resistivity readings vary, depending on the

lithology, density, degree of saturation, and nature of saturation

of the geologic strata tested.

Where groundwater quality varies significantly with respect

to total dissolved solids, and hence electrical conductivity,

contrasts in groundwater quality can be discerned electrically.

However, natural and artificial conditions affecting the conduct

ivity/resistance of subsurface materials will often mask the

existence of groundwater pollution. Therefore, its application

is limited to those areas where significant variations in groundwater

guality occur which can be differentiated from other changes

in resistivity due to factors other than water quality.

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The natural resistivity of earthen materials varies significantly.

Dense bedrock or other non-porous materials ordinarily exhibit

high resistivity values. Some porous but unsaturated materials,

such as dry sand, will exhibit moderately high resistivity values.

Even saturated clean sands and gravel containing low dissolved

solids (salts) can exhibit moderately high resistivity, hence,

low conductivity. Conversely, dirty gravels containing intermixed

clays will exhibit lower resistivities due to the free ion content

(salinity) of the charged clay particles.

Because clays and silts are capable of holding more water (above

the water table) than clean sands and gravels, they, predictably,

exhibit lower resistivity. Equal resistivity readings do not

always signify similar materials if the survey is conducted

where moisture contents vary appreciably. Therefore, periods

of extended rainfall can create problems in the interpretation

of data results.

Resistivity can be correlated with various materials. For dense

rocks, expected values may range from several thousand to several

tens of thousands of ohm-feet. Most soils, since they are moist

and contain clays with net ionic charges, have lower resistivities

in the range of 20 to 200 ohm-feet.

The chemical character of , the groundwater occupying the pore

spaces of the soil also affect apparent resistivity, particularly

if the groundwater has a high specific conductance as a result

of contamination. As would be expected, the high groundwater

conductivity decreases the overall soil resistivity. It has

been well documented that, where this is the case, and where

the natural resistivity of the soil is relatively uniform, the

earth resistivity technique can greatly facilitate delineation

of the areal extent of a groundwater contamination plume.

4.31 Sounding Survey

A brief sounding survey would be conducted at the site

where prior information reveals highly conductive, contaminated

groundwater.

Electrical resistivity soundings are performed by progressively

increasing the electrode spacings which send the current progres

sively deeper, permitting an indication of the vertical variability

of the soil's apparent resistivity. The Wenner electrode config

uration would be used in the sounding survey. In this procedure,

the depth of measurement is roughly equivalent to the probe

spacing.

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4.32 Profiling Survey

A profiling survey would then be conducted in which the

electrode spacing is held constant and readings are taken at

various locations in an effort to define the areal limits of

the plume of contamination. Electrode spacing (s) would be determined

from the sounding survey, as discussed previously. The initial

effort of the profiling survey is to establish a range of background

apparent resistivity in the area. Once background levels are

determined, readings are then taken within the suspected area

of the plume migration. The location of each Earth Resistivity

Station (ERS) as well as the apparent resistivity measured at

each station would then be recorded and plotted on a site base

map.

4.40 MAGNETIC GRADIOMETER SURVEY

Proton precession vertical gradiometer surveys have been utilized

in several applications to successfully locate magnetic anomalies

which may be associated with buried material. The gradiometec

is a differential magnetometer which allows resolution of composite

or complex anomalies into individual constituents and automaticallv

removes the regional magnetic gradient to allow better definition

of shallower anomalies.

Because of allegations that drums of chemicals were buried at

Central Landfill prior to 1980. the application of vertical

gradiometer survey to determine the location and extent of buried

drums has been considered.

Since RISWMC began operations at the site in December 1980.

an average net elevation increase of 30 to 40 feet has been

experienced across the landfill area with lifts of 60 feet

or more placed in some areas. Included in the refuse placed

bv RTSWMC are shredded and unshredded scrap metals, white goods,

and hundreds of nonhazardous and empty drums.

Based on GZA's experiences with magnetometer applications at

landfills and the fact that "it is relatively important in any

ground gradient applications that there be no significant surface

magnetic noise. for gradient anomalies tend to greatly enhance

such .qhallow noise sources which would be detrimental for most

objectives(3) ," it is anticipated that a gradiometer survey

would not generate useful data.

Allegations regarding the disposal of drums of chemicals at

the landfill prior to 1980 have been referenced above. Attempts

to identify particular areas of drum disposal through records

search and interview have not proven fruitful. The former site

operator vehemently maintains that although-bulk hazardous liquids

in excess of a million gallons were deposited at the landfill,

drums of chemicals were not deposited there.

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In addition, were allegations regarding disposal of drummed

waste prior to 1980 found to be true. it iS highly unlJKely

that any such drums would, at this time, contain liquid wastes.

After careful consideration, it is. therefore, recommended that

the search for buried drums be limited to the execution of borings

at proposed locations WE 85-1 through WE 85-4 in the landfill

area and the excavation of test pits in the white metal axe^

(a location delineated by the state police) and the evaluation

of groundwater quality trends.

The rationale for selection of the boring locations is that

the area targeted coincides with where the bulk of landfilling

occurred during the time of the alleged drum disposal.

4.50 SEISMIC REFRACTION INVESTIGATION

Seismic refraction techniques are used to determine the velocity

of compressional waves through subsurface strata and provide

information regarding strata density and depths to contrasting

strata interfaces such as a bedrock-overhurden boundary.

In an amenable environment such information as depth to groundwater,

depth to bedrock and subsurface strata boundaries might be determined

t?y seismjg refraction. in a landfill situation, however, the

presence of random debris and pockets of biodegradation gas

products would result, respectively, in signal scatter and attenua

tion. The acquisition of useful data under these conditions

is unlikely.

Application of seismic refraction around the perimeter of the

landfill would not provide high resolution results as the subsurface

strata is known to consist of fractured bedrock overlain by

a glacial till. These strata exhibit similar wave velocities

and provide poor resolution of interface depth.

Based on the above limitations, the use of a seismic refraction

survey at the Central Landfill site is not recommended. TeSt