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FINAL WORK PLANFOR
PETERSON PURITAN, INC.LINCOLN/CUMBERLAND, RHODE ISLAND
REMEDIAL INVESTIGATION/FEASIBILITYSTUDY
VOLUME I: TECHNICAL SCOPE OF WORK
SEPTEMBER 1986
EPA Contract No. 68-01-6939
Work Assignment No. 159-1L40
Document Control No. 272-VP1-WP-DDET-1
Prepared for: U.S. Environmental Protection AgencyRegion IBoston, MA
Prepared by: Camp Dresser & McKee, Inc.Boston, MA
This Work Plan was prepared by the REM II Team in accordance with the itemsof the U.S. EPA Contract No. 68-01-6939.
TABLE OF CONTENTS
Section Page No.
1.0 INTRODUCTION
1.1 Site Location and Status 1-1 1.2 Objectives of RI/FS 1-5
2.0 SITE DESCRIPTION
2.1 Nature and Extent of Contamination 2-1 2.2 Environmental and Public Health Concerns 2-4 2.3 Site Geology and Soils 2-5 2.4 Site Hydrogeology 2-8 2.5 Surface Water Hydrology 2-11
3.0 SITE HISTORY
3.1 Chronological History of the Site 3-1 3.2 History of Known Public Concerns 3-5 3.3 History of and Need for Response Actions
at the Site 3-6
4.0 DISCUSSION OF EXISTING DATA BASE AND DATA GAPS 4-1
5.0 SCOPE OF WORK
5.1 TASK 0 Develop Work Plan Memorandum 5-2 5.2 TASK 1 Work Plan Preparation 5-2 5.3 TASK 2 Screening of Preliminary Remedial
Technologies 5-3 5.4 TASK 3 Remedial Investigation Scope of Work 5-7 5.5 TASK 4 Identification of Preliminary Remedial
Technologies 5-37 5.6 TASK 5 Baseline Risk Assessment 5-37 5.7 TASK 6 Preparation of Remedial Investigation
Report 5-44 5.8 TASK 7 Remedial Investigation Support 5-44 5.9 TASK 8 Development of Alternatives 5-50 5.10 TASK 9 Initial Screening of Alternatives 5-52 5.11 TASK 10 - Detailed Evaluation of Remaining
Alternatives 5-53 5.12 TASK 11 - Preparation of Draft Feasibility
Study Report 5-63 5.13 TASK 12 - Final Feasibility Study Report 5-63 5.14 TASK 13 - Conceptual Design of Selected
Remedial Alternative 5-64 5.15 TASK 14 - Feasibility Study Support 5-64
TABLE OF CONTENTS (Cont'd)
Section
ATTACHMENTS
A - Summary Evaluation of Other Reports B - Surface Water Sampling Data C - Groundwater Sampling Data D - Peterson-Puritan In-Plant Boring Data E - Lonza Sampling Data F - List of References used in Developing Work Plan G - Schedule of Deliverables H - Schedule of Activities
LIST OF TABLES
Table No. Page No.
Text
1 Toxicological Data on Contaminants found in the Quinnville Wells 2-6
2 Lonza and Syntron Parameters 4-4
3 Preliminary Assessment of General Response Actions 5-4
4 Preliminary Assessment of Remedial Technologies 5-5
Attachments
B-l Summary of Surface Water Sampling Locations
B-2 Surface Water Sample Collection
B-3 Surface Water Volatile Organics Screening Results of GZA Samples
B-4 Volatile Organic Priority Pollutant Concentrations in GZA Surface Water Samples
B-5 Volatile Organic Priority Pollutant Concentrations in Malcolm Pirnie Surface Water Samples in Brook A
B-6 Malcolm Pirnie Blackstone River Sampling Program Analyses
B-7 Malcolm Pirnie Blackstone River Elevations
C-l Summary of Groundvater Monitoring Locations
C-2 Monitoring Well Construction Details
C-3 Quinnville Wellfield Purge Tests
C-4 Volatile Organic Priority Pollutant Concentrations (ug/1) in Samples from Lincoln Supply Well No. 6 (LW-420)
C-5 Volatile Organic Priority Pollutant Concentrations in Samples from Lenox Street Well
C-6 Groundvater Volatile Organics Screening Results of GZA Samples
LIST OF TABLES (Cont'd)
Table
C-7 Malcolm Pirnie Groundwater Monitoring and Analytical Schedule
C-8 Volatile Organic Priority Pollutant Concentrations (ug/1 or ppb) in Samples from GZA Monitoring Veils
C-9 Volatile Organic Priority Pollutant Concentrations (ug/1 or ppb) in Samples from Existing Production and Monitoring Wells
C-10 Volatile Organic Priority Pollutant Concentrations in GZA Samples from J. M. Mills Landfill Monitoring Veils
C-ll Volatile Organic Priority Pollutant Concentrations in Samples from Malcolm Pirnie Monitoring Wells
C-12 Volatile Organic Priority Pollutant Concentrations in Samples from the Peterson-Puritan Groundwater Interceptor Veil
C-13 Trace Metals and Chloride Analyses on GZA Samples from J. M. Mills Landfill Monitoring Veils
C-14 Inorganic Concentrations for Selected Veils Vithin the Study Area
C-15 Field Measurements, Other Priority Fractions and Upgradient Parameters for Selected Wells Vithin the Study Area
C-16 Nonpriority Pollutant Peaks for Selected Veils Within the Study Area
C-17 Microbial Testing of Soils and Groundwater Along the BVSD Sewer Line
C-18 Water Level Measurement Data for Well Samples by Malcolm Pirnie
C-19 Water Levels in Wells before and after November, 1983 Pumping Test
D-l Peterson-Puritan In-Plant Boring Details
D-2 Volatile Organic Priority Pollutant Concentrations in Soil Samples from Peterson-Puritan In-Plant Borings and Septic Systems Samples
LIST OF TABLES (Cont'd)
Table
E-l Lonza Sampling Locations
E-2 Summary of Volatile Organic Sampling Survey Results at Lonza
1
2
3
4
5
6
LIST OF FIGURES
Figure No. Page No.
General Location of Peterson-Puritan Site 1-2
Definition of Site Boundaries 1-3
Peterson-Puritan Site Plan 2-2
Areal Extent of Blackstone River Valley Aquifer 2-10
Location of Production Wells in Lincoln and Cumberland 3-8
Peterson-Puritan Proposed Sampling Plan 5-15
1.0 INTRODUCTION
1.1 Site Location and Status
The Peterson-Puritan site is a parcel of land along the Blackstone River
between the towns of Ashton and Lonsdale in Providence County, Rhode Island
(see Figure 1). It is located approximately two miles south of the Town of
Ashton. On the U.S.G.S. map for the Pawtucket quadrangle, the site is
located at 41°55' longitude and 71°25' latitude.
The site area is about two miles long and extends approximately 2,000 feet
to the east and west of the main river channel of the Blackstone River,
which flows to the south and forms the boundary between the Towns of
Cumberland to the east and Lincoln to the west. Access to the site is via
Route 122, known as Mendon Road, to the east or Route 126 to the west (see
Figure 2).
In the northeastern corner of the site, in Cumberland, Rhode Island, there
is a small industrial park (see Figure 2). Located within this park are:
Owens-Corning Fiberglass Plant, Lonza Inc., Roger Villiams Food, Inc.,
Okonite Cable Company, Peterson-Puritan, Inc., and Healthtex Inc. Another
company called Syntron Inc. is located nearby, just northeast of the park.
The Peterson-Puritan facility was previously identified as a potential
source of groundwater contamination in the area and therefore, was chosen
as the site's namesake even though the site extends beyond the Peterson-
Puritan facility property. In a southerly direction, still in Cumberland,
Rhode Island, is the J.M. Mills Landfill which covers approximately 10
acres. Just south of the Lenox Street Well there is a solid waste transfer
station on the eastern side of the river before it bends southwesterly.
The western side of the Blackstone River is composed of private residences
with little or no commercial development. There is an abandoned
quarry/landfill operation, the Dexter Quarry, located on this western side
near the residences. (Several of these facilities have been suspected of
contributing to the contamination which exists at this site.)
1-1
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STATE OF RHODE ISLAND
Figure 1 General Location of "Peterson-Puritan Site
1-2
0 1000
SCALE
2000 40OC ()t)
FIGURE 2 Definition of Site Boundaries
1-3
The Blackstone River Valley Aquifer, which is the regional water table
aquifer, was first tapped by the Town of Cumberland as a water supply in
1950. Since that time several municipal supply wells have been installed
in the area. The Town of Lincoln installed three supply wells in this
area: Lincoln Well No. 1 in 1957, Lincoln Well No. 6 in 1970 and Lincoln
Well No. 9 in 1975. These wells are commonly referred to as the Quinnville
Wellfield (see Figure 2). The Town of Cumberland installed its Lenox
Street supply well in 1964, approximately 4,000 feet downstream of the
Quinnville Wellfield. The well locations are shown in Figure 2.
In October, 1979 during a routine statewide sampling of municipal supply
wells, the Rhode Island Department of Health (RIDOH) found volatile organic
contamination, specifically 1,1,1-trichloroethane and tetrachloroethylene,
in the Quinnville wells and the Lenox Street well. These supply wells were
then closed and have remained closed to date with the exception of short
periods where contaminant levels dropped low enough for usage. The
Quinnville wells provided forty-five percent of the Town of Lincoln's water
supply. Lincoln replaced these wells by installing two new wells, one in
each of the other wellfields they use (the Manville and Lonsdale
wellfields, both in the Blackstone aquifer) and by purchasing water from an
adjacent community (see Section 3.3). The Lenox Street well provided only
four percent of Cumberland's water supply and the deficiency left by
closure of the well has been taken up by their other wells.
As a result of the closing of these wells, the Environmental Protection
Agency (EPA) contracted Goldberg Zoino and Associates Inc. (GZA) to conduct
a limited hydrogeologic investigation to determine the source of contamina
tion. GZA completed this study in March of 1982 (Ref. No. 1, Attachment F)
and concluded that the Peterson-Puritan plant, which mixes and containerizes
various aerosol and non-aerosol products and is located in the small indus
trial park to the northeast of these wells, was responsible for the volatile
organic contamination. This contamination was the result of inadequate
historic waste disposal practices, including discharge of untreated process
wastewater to Brook A, direct subsurface disposal via floor drains, etc. (as
documented in an EPA plant inspection of the Peterson-Puritan facility in
1981). No quantitive information concerning wastes disposed of in these
1-4
manners is available. Based on this, the Town of Lincoln filed suit against
Peterson-Puritan. Peterson-Puritan then hired Malcolm Pirnie Inc. to do
another hydrogeologic study to evaluate the source of contamination. This
study (Ref. No. 2, Attachment F) was completed in June of 1983 and concluded
that, while Peterson-Puritan is responsible for the Quinnville Wellfield
contamination, the evidence is not conclusive that they are responsible for
the Lenox street well contamination. In 1984 Peterson-Puritan settled with
the town of Lincoln for $750,000 to compensate for the costs of new water
supplies. Peterson-Puritan then contracted Versar Inc. to write a remedial
investigation/feasibility study (RI/FS) (Ref. No. 3, Attachment F)
independent of EPA, which was completed in October of 1984. In addition,
several plant waste handling improvements were made and a recovery well was
installed in the southwest corner of the Peterson-Puritan property to
intercept the contaminated groundwater plume leaving the property.
Currently, the Peterson-Puritan site is ranked 365 on the National
Priorities List (NPL) of sites to be investigated and cleaned up under the
Superfund Program.
1.2 Objectives of the RI/FS
The purpose of the subject work assignment is to conduct an RI/FS for the
Peterson-Puritan site under an EPA enforcement lead. The purpose of the RI
is to collect data pertinent to identifying the contamination problems and
developing cost effective, technically feasible, and environmentally sound
remedial action alternatives for a given site. The FS will focus on the
development and evaluation of measures to be taken to alleviate identified
on-site and off-site contamination problems.
Attachment A of this work plan provides summaries of three previous studies
mentioned above, which address the VOC contamination of the Blackstone
River Valley Aquifer associated with the Quinnville wellfield and Lenox
Street well. This work plan was developed with the objective of addressing
the deficiencies in or data gaps associated with these reports. The
overall deficiencies noted include:
1-5
1) No quality assurance/quality control of data obtained by Malcolm
Pirnie on which risks are assessed and remedial actions are
evaluated (this data was used in Ref. Nos. 2 and 3, Attachment F);
2) No definitive assessment of potential sources other than the
Peterson-Puritan facility and the transport pathways between the
source(s) and the supply wells in the Quinnville wellfield;
3) No definitive assessment of any sources and the transport pathways
between the source(s) affecting the Lenox Street supply well;
4) Insufficient information to characterize the full nature and extent
of the plume emanating from the Peterson-Puritan facility versus
the potential for other contaminant sources in the area (e.g.
potential plumes from Dexter Quarry or J.M. Mills Landfill);
5) Insufficient information to evaluate the environmental effects of
the VOC contamination on the Blackstone River, it's floodplain and
any wetland areasassociated with the site;
6) Insufficient information to characterize the migration and
potential public health and environmental impacts of the
contamination downgradient of the site, i.e. Lonsdale wellfield;
7) No delineation of soil source areas at the Peterson-Puritan
facility;
8) Lack of compliance of the Versar report (Ref. No. 3, Attachment F)
with the RI/FS requirements of the NCP (November, 1985) e.g. no
institutional analysis identifying applicable or relevant and
appropriate requirements.
(Note that specific data gaps associated with these reports are
outlined under Section 4 of this work plan, which provides a
discussion of the existing data base and data gaps.)
1-6
This RI/FS work plan was developed to address the needs of the public with
in the surrounding area who are directly affected by both the contamination
problem and any proposed remedial actions, as required by appropriate
legislation and implemented by EPA and appropriate state agencies.
1-7
2.0 SITE DESCRIPTION
2.1 Nature and Extent of Contamination
Organic contamination was first detected in the Town of Lincoln's Ouinnville
supply wells and the Town of Cumberland's Lenox Street well in October of
1979. A routine statewide testing program of municipal wells revealed
concentrations of both 1,1,1-trichloroethane and tetrachloroethylene ranging
from 27-166 ppb. Since this discovery, extensive sampling of these and
other wells located in the Blackstone River Valley Aquifer at the locations
shown in Figure 3 has been done. The compounds consistently detected above
10 ppb on-site (using EPA approved analytical methods, QC & QC) include:
trichlorofluoromethane,
1,1-dichloroethylene,
1,1-dichloroethane,
trans-1,2-dichloroethylene,
1,1,1-trichloroethane,
trichloroethylene,
tetrachloroethylene,
benzene,
chlorobenzene,
chloroethane,
1,1,2,2-tetrachloroethane,
chloroform,
methylene chloride,
vinyl chloride,
1,2-dichloroethylene,
dichlorodifluoromethane, and
2-chloroethanol.
Refer to Appendix C for analytical data for each well.
The results indicate volatile organic contamination in the aquifer exceed
EPA primary drinking water standards. (See Ref. No. 4, Attachment F.)
2-1
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iSSi.
This is probably the result of a long history of use and disposal of
industrial and nonindustrial solvents in this area. Other contaminants of
concern found in the analyses of the groundvater in this area include:
12.5 parts per trillion (ppt) of dieldrin (a pesticide covered by the EP
toxicity test) in well MW A-l and priority pollutant metals arsenic,
cadmium, chromium, and lead at levels above EPA's primary drinking water
standards by Malcolm Pirnie, Inc. in 1983.
Concerning the extent of volatile organic contamination, several
conclusions can be reasonably drawn:
o The upgradient boundary of one plume is designated as the
Peterson-Puritan plant because two wells located just upgradient of
the plant showed no volatile organic chemical (VOC) contamination,
while those wells just downgradient of the plant had the highest VOC
levels on-site. These wells are all located on the east side of the
river.
o Other plumes may exist, as evidenced by high VOC levels in one well
even further upgradient of the site on the west side of the river.
o The VOC levels on-site have indicated considerable decline between
February of 1983 and July of 1984, with the exception of trans-1,2
dichloroethylene. (Note that this compound may be a degradation
product.) This may indicate that VOCs are being gradually flushed
out of the affected area and into the Blackstone River.
o Existing data from nested wells indicate that the vertical
distribution of VOCs consist of higher concentrations at shallow
depths close to the Peterson-Puritan plant and at deeper depths
toward the river. This may be due to dispersion and the pumping
effects of deeper wells in the Quinnville Wellfield during their
operating history.
Conclusions regarding the plume requiring further investigation include
those given below:
2-3
o The Blackstone River may be the present plume boundary and may have
been so since the pumping of the supply wells was discontinued in
1979. (Under such non-pumping conditions, it is recognized that
groundwater flow is toward the river and since VOC levels have
dropped, this conclusion appears logical.) The location of the
upgradient boundary of the plume near the river is questionable.
Also the plume's extent downgradient is dubious (i.e. it has been
postulated that it does not include the J.M. Mills Landfill).
o A controversy concerning the downgradient extent of the plume exists
about whether the Lenox Street well contamination is a result of the
VOC plume which exists in the Quinnville Wellfield. GZA believes it
is the same plume affecting the Quinnville and Lenox Street wells.
However, Malcolm Pirnie disagrees, believing that the cone of
depression for the pumping rate of the Lenox Street well is not
large enough to intercept the plume. Malcolm Pirnie notes that
trichlorofluoromethane, which is characteristic of the plume
affecting the Quinnville Wellfield, was not found in the Lenox
Street well. (Trichlorofluoromethane is an aerosol which is not
commonly used.) The Peterson-Puritan plant is the only known user
of the chemical in the industrial park upgradient of the site. Many
of the other VOCs found, however, are commonly used solvents which
could emanate from several other potential sources.
2.2 Environmental and Public Health Concerns
The 1984 Versar report (Ref. No. 3, Attachment F) included an endangerment
assessment which addressed the volume of contaminated groundwater beyond
the influence of the recovery well which discharges to the river. An
assessment of the risks incurred by a small population ingesting
contaminated fish and/or contaminated river water and the population of the
town of Lincoln ingesting the water from the downgradient supply wells in
Lonsdale (which intake water from the river) was made. No impacts to
public health were shown from this assessment. (Ref. No. 3, Attachment F.)
Also, no ecological impacts to the river were identified.
2-4
NUS Corporation completed an Endangerment Assessment for the Peterson-
Puritan site in May of 1984. They concluded that the major risk associated
with this site concerns consumption of contaminated groundwater. In their
study, several of the most commonly found volatile organics in the
Quinnville Vellfield were compared with EPA guidance levels (Ref. No. 4,
Attachment F). Two sets of guidelines were used: SNARLS (Suggested No
Adverse Response Levels) and CAG (Cancer Risk Levels by the Cancer
Assessment Group). SNARLS consider only toxic effects and do not address
potential carcinogenic responses. SNARLS were calculated based on chronic
long-term tests made using a 10 kg child, assuming consumption of one liter
of water per day. CAG levels represent levels which will result in one
additional cancer risk per million people, and are made assuming the
lifetime exposure of a 70 kg adult, living 70 years and drinking two liters
of water per day. A comparison of these levels is given in Table 1.
The following toxicological summary is given by NUS (Ref. No. 4, Attachment
F):
"Of the identified contaminants, 1,1-dichloroethylene, trichloroethylene, and tetrachloroethylene are suspected of having carcinogenic properties, and can therefore be considered the most toxic in relation to potential long-term toxic effects. Trichlorofluoromethane is treated as a potential carcinogen by EPA because of its similarity to a class of compounds suspected of being carcinogenic. The remaining compounds are capable of inducing toxicological and pathological responses at higher dose levels than those reported for groundwater from the Lincoln wellfield. The specific effects of these compounds at the concentrations seen cannot be precisely predicted, however, it can be assumed that their toxic properties are at least additive."
In conclusion, it is important to note that for carcinogens there is some
risk at any level of exposure; therefore, the presence of these compounds
in any level in drinking water is cause for concern. (At this time,
however, none of the supply wells are in use.)
2.3 Site Geology and Soils
Quartzite is the predominant rock type mapped along the valley of the
Blackstone River, with schist, marble, and greenschist generally found
2-5
TABLE 1
TOXICOLOGICAL DATA ON CONTAMINANTS FOUND IN THE QUINNVILLE WELLS
Compound Max. Concentration(ug/1)
trichlorofluoromethane 520
1,1-dichloroethylene 92
1,1-dichloroethane 48
t-l,2-dichloroethylene 2500
1,1,1-tricholorethane 630
trichloroethylene 24
tetrachloroethylene 67
* - draft SNARL
N/A - not available
Ref. No. 4 (NUS Endangerment Assessment, 1984)
CAG SNARL (ug/1) (ug/1)
N/A N/A
0.24 70*
N/A N/A
N/A N/A
N/A 1000
2.8 75
0.9 40
2-6
further from the river. Both the bedding and the foliation of the
Blackstone series strike northerly to northwesterly and generally dip 40 to
60 feet to the northeast. Bedrock elevations have been interpreted from
drilling logs using refusal depths which may not be accurate (i.e. they may
represent boulders or dense till rather than bedrock).
These limitations notwithstanding, the rock surface generally reflects the
surface topography, which is high in the upland areas and low beneath the
Blackstone River. Bedrock elevations range from a high of over 250 feet
relative to the National Geodetic Vertical Datum (N.G.V.D.) in outcrops in
the western corner of the site, to a low of approximately -30 feet N.G.V.D.
at a well on the Blackstone River floodplain. The zones of low bedrock
elevation form a trough-like depression or valley which generally parallels
the Blackstone River in the vicinity of the site. The trough was
subsequently modified by glacial activity and buried under glacial debris.
The bedrock outcrops along a ledge on the western side of the canal. Some
bedrock outcrops were also noted on the eastern side of the river in the
sand and gravel pits.
Directly overlying the bedrock are deposits of unsorted glacial materials
described as till. This material is thickest only within the valley and
thins out quickly along the valley walls. It is covered by sand and gravel
within the valley and exposed at the edges of the valley. Glacial till is
exposed however in most of the areas of higher elevation along the western
side of the Blackstone River, whereas it is not widely exposed on the
eastern side of the river which is a low-lying portion of the site within
the valley. Several borings completed during a previous investigation
encountered 0 to 10 feet of glacial till overlying bedrock (based on
refusal) across the site. These materials are probably not more than 10 to
15 feet in thickness over most of the Pawtucket quadrangle.
The remainder of the materials filling the bedrock trough and forming the
floor of the present river valley is a thick (up to 130 feet) deposit of
sand and gravel with some layers of silt and clay. These materials, mapped
as glacial kame terrace deposits, overlie till in low-lying portions of the
study area, but are absent in areas of higher elevation. The thickness of
2-7
the stratified deposits is controlled primarily by the configuration of the
bedrock surface; the deposits are thickest in the buried bedrock valley
described above and pinch out against the walls of the valley. Some of
these materials have been eroded and redeposited as alluvial material by
surface water since their initial deposition. These alluvial deposits
consist of the same material as the stratified sand and gravel deposits and
are generally less than five feet thick. There currently exist large sand
and gravel mining operations to the east of the site.
It should also be noted that a surficial organic silt and peat layer (3-7
feet thick) was noted in borings near the river. These soils appear to be
discontinuous in the study area however. Fill materials were also found in
a number of GZA borings. Borings in the valley floor encountered 3 to 4
feet of granular fill material placed over the sand and gravel deposits.
Up to 50 feet of miscellaneous trash fill was reported at borings in Dexter
Quarry on the west side of the river. (Note that industrial wastes were
dumped into Dexter Quarry between 1947 and 1975.)
Information collected from the Soil Conservation Service Soil Survey of
Rhode Island (Ref. No. 5, Attachment F) indicates that the Peterson-Puritan
plant itself is located on a surficial soil type mapped and described as
urban land, which may include small areas of mixed or altered soils of
several types. Around the plant and the river valley are areas of several
soil types, including the Hinckley gravelly sandy loam, Podunk fine sandy
loam, and a relatively large area characterized as gravel pits. These soil
types are all moderately to very permeable and can admit surface water
infiltration easily (Ref. No. 3, Attachment F).
2.4 Site Hydrogeology
The unconsolidated glacial outwash deposits, consisting primarily of stra
tified sand and gravel, constitute the Blackstone River Valley Aquifer,
which is the water-bearing reservoir that extends from the water table to
the bottom of the stratified deposits. The bottom of the aquifer is consi
dered to be either till or bedrock. Some well logs indicate that portions
of the stratified drift aquifer are composed of coarse sand and gravel.
2-8
The estimated geologic extent of the Blackstone River Valley aquifer in
Rhode Island was mapped by the U.S. Geological Survey (see Figure 4). The
aquifer extends northward into Massachusetts and southward beyond the Towns
of Lincoln and Cumberland. The width of the aquifer ranges from about
1,200 to 2,500 feet near the site. The entire aquifer is about 12 miles
long and covers an area of approximately 6 square miles. The amount of
groundvater in storage in these deposits is estimated to be approximately
14 billion gallons (Ref. No. 3, Attachment F).
The eastern boundary of the aquifer is approximately parallel to Mendon
Road in Cumberland, and the western boundary is in the vicinity of Route
126 in Lincoln. Both boundaries represent the contact of the stratified
sands and gravels with till or bedrock. The aquifer is continuous along
the Blackstone River Valley.
Depth to groundwater ranges from less than three feet to more than 20 feet
below the ground surface and the saturated layer is approximately 70-100
feet thick along the bedrock trough. The aquifer transmissivity and
hydraulic conductivity values used in all the previous studies (Ref. Nos.
1, 2 and 3, Attachment F) have been 100,000 gallons/day/foot and 1000 22
gallons/day/foogallons/day/foott ,, respectivelyrespectively,, based on pump tests from the USGS and the
towns of Lincoln and Cumberland.
The section of the Blackstone River Valley Aquifer within the site
boundaries receives water from three sources — areal recharge (the portion
of precipitation that infiltrates to the aquifer), flow from the till or
bedrock where these materials contact the aquifer deposits at the east and
west boundaries, and the Blackstone River, which usually acts as a
discharge point for groundwater but may release water to the aquifer when
groundwater is being pumped from the aquifer (Ref.No. 1, Attachment F).
During most of the year under non-pumping conditions, it has been stated
that areal recharge supplies most of the groundwater to the aquifer 2
(approximately 1 million gallons/day/mile ) (Ref.No. 1, Attachment F).
Recharge from the till and bedrock has not been accurately quantified. GZA
reported (Ref. No. 1, Attachment F) that the blow counts encountered for the
2-9
Original includes color coding.
APPROXIMATE SCALE 1 2*000
2 INCH
2000 *000 FEET
APPROXIMATE BOUNDARY f OF AQUIFER / » , t
FIGURE 4 Area! Extent of Blackstone Valley Aquifer
2-10
till were high indicating a dense material of low permeability. The bedrock
is not considered a source of water. Nevertheless, Ecology and Environment,
Inc. conducted a fracture pattern analysis of the Blackstone Series Bedrock
and reported the location of clusters of fractures which can act as conduits
for groundwater flow from the west near Dexter Quarry Brook toward the site.
They published a report on this in 1981 (Ref. No. 6, Attachment F).
Groundwater flow in the Blackstone River Valley Aquifer is toward the river
from both sides of the valley and eventually discharges to it through the
river channel. The vertical gradient of aquifer flow near the river has not
been determined. GZA postulates that most flow is perpendicular to the river
but near or under the river, flow is parallel to the river. Similarily, HP
suggests that flow is toward the river then upward and into the river. The
possibility of a deeper regional flow component has not been resolved.
During pumping conditions it is possible that groundwater from the river
and the aquifer on the west side of the river could be drawn to the
Quinnville wells. It has been postulated in reports by GZA (Ref. No. 2,
Attachment F) and Malcolm Pirnie (Ref. No. 2, Attachment F) that the Lenox
Street well may draw its water from the river, a portion of the aquifer
under the river, and/or from groundwater beneath the J. M. Mills Landfill.
The area of influence of any of the supply wells depends to a great extent
on local aquifer characteristics. An analysis of Quinnville Uellfield
pumping test conducted in 1974 by the U.S.G.S. (Ref. No. 7, Attachment F)
showed minimal alterations in natural flow conditions outside the vicinity
of the wellfield due to high infiltration rates from the river thus allow
ing less drawdown around the well (Ref. No. 3, Attachment F). Note however
that this test was only conducted on Lincoln Supply Well #6 (Lincoln Well
#9 had not been installed and Well #1 was not pumped.) Therefore, the
results of this test are not directly applicable to the pumping conditions
at the time of the wellfield operation and subsequent shutdown.
2.5 Surface Water Hydrology
The Blackstone River drains into the tidal Seekonk River south of Central
Falls. The entire Blackstone River Basin has a drainage area of 478 square
2-11
miles (373 square miles in Massachusetts and 105 square miles in Rhode
Island) and is 49 miles long. In Rhode Island the basin encompasses all of
Woonsocket and Cumberland, most of North Smithfield and portions of
Burrillville, Gloucester, Lincoln, Central Falls, Pawtucket and Smithfield.
Based on U.S. Geological Survey gaging stations, the average discharge of
the river is 729 cubic feet per second with a 10 year seven-day (7Q10) low
flow of 101 cubic feet per second at Uoonsocket, Rhode Island. The
Blackstone River has however been impounded in the past by textile mills
for power generation and processing. It also was and continues to be the
recipient of numerous discharges and waste disposal (Ref. No. 3, Attachment
F). The past river usage and the contributing factors to it's current
status of a Class C river is described below.
The quality of the Blackstone River is not good; the New England River Basin
Commission reported in 1975 that the water was "grossly polluted" because of
wastewater from combined sewer overflows upstream of Voonsocket and the
overloaded City of Worcester's (Massachusetts) secondary treatment plant
(Ref. No. 8, Attachment F). The river reach between Woonsocket and Central
Falls, where the site exists, is classified as a Class C water body, unsuit
able for bathing, public water supply, agricultural uses, or as a preferred
habitat for fish and wildlife. The water quality impact from surface runoff
is thought to be relatively minor, but additional data is needed for a
definitive determination (Ref. No. 3, Attachment F). Note that the river
itself may be a source of contamination of the Quinnville and Lenox Street
wells given that they draw their water from it during pumping.
The Blackstone River and Canal, though parallel but separate entities in
the vicinity of Lincoln, originate as a single stream upgradient of the
site. The Canal eventually terminates at Scott Pond, one mile south of the
Quinnville Wellfield. The Blackstone Canal is a 150 year old clay lined
canal. The water quality is similar to that of the Blackstone River. It
was used historically to transport cargo to the sea while traffic on the
river was directed inland.
2 --12
This site is in the 100 year floodplain of the Blackstone River. Evidence
obtained during site inspections (i.e. tires and debris found several feet
above the ground in the trees) reveals that the river frequently floods its
banks as the water level rises several feet. (Data on the flooding
patterns and storm event data for this river over the past decade including
several years prior to the closing of the supply wells will be obtained
during the remedial investigation.) Surface water flows into and out of
the river include industrial and stormwater discharges from Brook A, the
Dexter Quarry Brook, the stream draining the wetlands south of J.M. Mills
landfill and a man-made channel outflow from the river to the sand and
gravel operations north of the railroad.
2-13
3.0 SITE HISTORY
3.1 Chronological History of the Site
1947-1975 Industrial wastes were dumped into the abandoned quarry
(Dexter Quarry) to the south of the site.
1950 The Town of Cumberland first tapped the Blacks tone River
Valley Aquifer with its Martin Street Supply well.
1957 The Town of Lincoln installed its first supply well in the
Blackstone River Valley Aquifer, LW-383 (U.S.G.S.
designation) or No. 1 (town designation) on Figure 2.
1959 The Peterson-Puritan plant began operations.
1964 The Town of Cumberland installed its Lenox Street well.
1967 The Town of Cumberland's Martin Street Veil was taken out of
service due to the presence of iron.
1970 The Town of Lincoln installed another well (LV-420 or No. 6
on Figure 3).
June 1972 The City of Woonsocket Public Works Department which is
located upgradient of the site was found to be discharging
acid and solvent rinses from the meter repair shop at the
city water treatment plant to the Blackstone River. (It is
not known when this practice began.)
Sept. 1972 The City of Woonsocket Public Works changed their discharge
process by routing the wastes to the sanitary sewer.
3-1
1972 Peterson-Puritan Inc. discontinued using their front and
back yard septic systems and hooked into the Blackstone
Valley Sewer District (BVSD) Commission sewer line, which is
connected to the Blackstone River Valley Treatment plant in
Rumford, RI.
1974-1977 Sampling of wells in the Quinnville Wellfield by the RIDOH
showed dieldrin concentrations frequently exceeding 100 ppt.
(Dieldrin, known as a pesticide, was used for moth proofing
of wool in scouring and dyeing plants on the Blackstone
River from 1958-1979).
1975 The Town of Lincoln installed well No. 9 or LW-421 (see
Figure 3 for location).
1975 The Peterson-Puritan plant discontinued the discharge of
process wastewater to a pipe which led to Brook A (see
Figure 3) on the west side of the plant.
Mid 1970s The Peterson-Puritan plant substituted gaseous hydrocarbons
and carbon dioxide for fluorocarbons as aerosols. This was
due to a federal ban on the use of fluorocarbons as aerosols.
The wastewater disposal system beneath the chemical
warehouse at the Peterson-Puritan plant was discontinued.
Discharge of trichloroethylene contaminated wastewater
(from the C0? saturator) down a manhole was discontinued.
The manhole led to the Brook A on the west side of the
Peterson-Puritan plant.
1976 A large fire destroyed the Peterson-Puritan plant. During
the plant's reconstruction a new tank farm/drum storage
area was designed and the can compacter was moved to a
concrete pad with diking.
3-2
1976 The Town of Lincoln applied to the Economic Development
Administration as well as the Department of Housing and
Urban Development for a federal grant to construct three
municipal water treatment plants for manganese removal.
Both grants were denied.
Oct. 1979 Organic contamination was detected in three supply wells
for the town of Lincoln (Quinnville Uellfield) and one
supply well for the town of Cumberland (Lenox Street). A
statewide testing of municipal wells showed the presence of
1,1,1-trichloroethane and tetrachloroethylene in these
wells. All five wells were closed because their organic
concentrations exceeded EPA guidance for drinking water.
Oct. 1979- The Lincoln Water Department tried to flush organic
June 1980 contaminants from their wells by pumping them. Only
temporary decreases in organic concentrations occurred
however. Nevertheless, periodic use of some of these wells
occurred when contaminant levels were acceptable.
1980-81 EPA contracted Goldberg Zoino and Associates (GZA) to study
a portion of the aquifer underlying and adjacent to the
Blackstone River in Lincoln and Cumberland. (Ref. No. 1,
Attachment F.) GZA concluded that the most probable source
for contamination of the Lincoln supply wells was the
upgradient industrial area, specifically the Peterson-
Puritan plant.
Feb. 2, 1981 The Okonite production well (SV-1 on Figure 3) was closed
due to the presence of volatile organic contamination.
March 1981 The Peterson-Puritan facility was inspected by EPA and GZA
personnel. They discovered discharges of wastes from floor
drains (i.e., vacuum pump flush water) onto the paved area
west of the plant. These wastes could then flow into two
corrugated steel pipes which discharged into Brook A.
3-3
Sampling of pipe discharge revealed the presence of methylene
chloride and 1,1,1-trichloroethane. This practice was then
altered and the vastewater was routed to the BVSD sewer.
July 24, 1981 A RCRA inspection of the Lonza plant was conducted by EPA.
The inspection revealed the existence of on-site waste
disposal facilities (septic tanks with leaching fields).
Oct. 6, 1981 Lonza's on-site disposal facilities were sampled by EPA.
Results of the analyses indicated that Lonza's wastewater
and non-contact cooling water, which is discharged to Brook
A, did not contain halogenated volatile compounds. Only
oil-related compounds were found. These disposal
activities did not involve RCRA wastes. In fact, Lonza
Inc. was not considered as a hazardous waste generator at
the time of inspection. (The RCRA permit was considered
unnecessary.)
1981-83 The following remedial actions were conducted at the
Peterson-Puritan facility:
the aerosol can dumpster and can puncturing unit were
placed on concrete with diking, and
- piping both in the plant and in the new tank farm/drum
storage location was relocated overhead for easier visual
inspection and sump pumps were added to reconstructed
floor drains for sewer discharge.
April 2, 1982 EPA notified Peterson-Puritan in writing of GZA's finding
that their company was the source of a groundwater
contamination problem that lead to closure of the public
water supply wells in Lincoln and Cumberland.
1982 Peterson-Puritan Inc. retained Malcolm Pirnie Inc. (MP) to
evaluate the organic contamination of groundwater in the
3-4
vicinity of their plant (Ref. No. 2, Attachment F). The
resultant study concluded that the Peterson-Puritan plant
was probably responsible for contamination of Lincoln's
supply veils, but not Cumberland's Lenox Street well.
May 1982 The Town of Lincoln hired GZA to study the usefulness of the
Quinnville wells via modeling techniques. The study report
ed that organic contamination was gradually decreasing and
15 million gallons could be safely pumped from well No. 1
for up to 60 days.
Oct. 29, 1982 The Town of Lincoln filed suit against Peterson-Puritan
Inc.
1982-83 Peterson-Puritan Inc. conducted an in-pipe television survey
of the BVSD sewer main. Results showed no structural
defects or leaks. The company hired Versar Inc. to conduct
a Remedial Investigation/Feasibility Study for the study
area (Ref. No. 3, Attachment F).
July 19, 1984 Peterson-Puritan Inc. began operating a recovery well which
they had installed on their property (in 1983) 200 feet
southwest of the nearest plant structure. The 6" diameter
well pumps at 40 gpm in an effort to collect contaminated
groundwater and prevent its migration off-site. The pumped
water continues to be discharged to the BVSD sewer today.
The Town of Lincoln settled with Peterson-Puritan for
$750,000 for costs associated with the construction of 2 new
wells and the purchase of water from a neighboring community.
3.2 History of Known Public Concerns
The quality of the drinking water supplied by the Quinnville wells has been
a public concern since their installation in the late 1950s. This concern
centers not on volatile organic contamination, however, but on excessive
3-5
iron and manganese concentrations. These contaminants, though not a health
hazard, are an aesthetic hazard which can result in water use problems.
The Rhode Island Department of Health has received many complaints from
Lincoln citizens beginning in 1961 relative to, sediments, staining of
plumbing fixtures, and discoloration when bleach was added to laundry.
This deterioration of water quality was believed to be due to induced
infiltration of water from the Blackstone River. (The Blackstone River has
been consistently classified as unsuitable as a public water supply
regardless of treatment and has received municipal sewage and various small
industrial discharges.)
In 1961 and 1965, Whitman and Howard suggested the use of chemical injection
wells to reduce bacteria (which normally accompanies high manganese levels)
and manganese levels-(Ref. No. 9, Attachment F). However, in 1973 the
manganese levels in all six Lincoln supply wells were so excessive that
removal rather than chemical sequestering was recommended. They proposed
the construction of three green sand filtration plants, one for each well-
field (i.e., Londsdale, Manville, and Quinnville). However, construction of
these plants was pending federal funding which was requested in 1975 through
the U.S. Department of Housing and Urban Development and the Economic
Development Administration. Both grants were denied and to date no plants
have been constructed though reapplication for federal funds has been made.
3.3 History of and Need for Response Actions at the Site
Steps taken to date at this site include the following:
replacement of 45% of the Town of Lincoln's water formerly supplied
by the Quinnville wells;
attempts to flush contaminants from the aquifer by pumping the
Quinnville wells;
plant improvements and changes in plant operations and maintenance
procedures at the Peterson-Puritan plant; and
3-6
the installation of a groundwater recovery well system on the
Peterson-Puritan property.
The first two actions were undertaken by the Town of Lincoln and the last
two by Peterson-Puritan Inc. The Town of Cumberland did not have to obtain
additional water supplies because the Lenox Street well supplied only 4% of
their supply needs and their other wells were able to make up the
difference. The loss of the Martin Street well output was also not
significant to the Town of Cumberland.
The Town of Lincoln replaced the three Quinnville production wells by
constructing two additional wells; one in the Manville wellfield (Lincoln
Veil No. 10), which is three miles to the north of the Quinnville Wellfield
along the Blackstone River, and one in the Lonsdale wellfield (Lincoln Well
No. 11), which is one mile to the south of the Quinnville Wellfield along
the Blackstone River (see Figure 5). A connection to a supplemental
potable water supply of a neighboring community was also made. Peterson-
Puritan Inc. later settled with the Town for the costs involved in these
actions. Various attempts were also made by the Lincoln Water Department
from October 1979 through June 1980 to flush contaminants from its wells by
pumping them heavily and discharging the water to the river. Although some
short-term reductions were observed at times, long-term pumping of the
wells usually resulted in an increase in contaminant levels (Ref. No. 2,
Attachment F).
According to Peterson-Puritan, over the last 10 to 12 years the company has
engineered plant improvements and changes to plant operations and
maintenance procedures in three phases. The first phase, which occurred
during the early to mid 1970s, primarily involved wastewater disposal
improvements. The second phase, which occurred during the mid to late
1970s, included construction to contain spills and leaks. The third phase,
which occurred after 1980, included major engineering changes to the plant
chemical and wastewater piping systems, improvements of spill containment
structures, and implementation of inspection and maintenance procedures
(Ref. No. 3, Attachment F).
3-7
/T) , - Manvillt Wtllfitld *-X!< Two Cumt*rlind Wtllt
Manvillt Wtllfilld / Lincoln Wtlli 3. 5,10
V
TOWN OF CUMBERLAND MANVILLE
0LACKSTONE MIVER
Production Wtll
TOWN OF LINCOLN MinmStrtit W»tl* Cumbtrland Will '''
1 SP \ ' Qumnvilli Wtllfitld Lincoln Willi 1.6.9
(doMd)
SCALE 1MILE Lenox S'.ritt Wf II Cumberland Wtll
(eloi«d! ALoouon of Production Wtlll
Lontdalc Wtllfitld Lincoln Wtlli 2. 4, 11
Figure 5 Location of Production Wells in Lincoln and Cumberland
Ref. Versar, 1984
3-8
Peterson-Puritan Inc. installed a recovery well on its property to collect
contaminated groundwater, thereby reducing migration of VOCs off of their
property. A six-inch diameter well, installed to a depth of 50 feet and
screened from 25-45 feet, was installed approximately 200 feet southwest of
the nearest plant structure. In November of 1983 a pump test was conducted
to obtain values of aquifer transmissivity and storage coefficient. These
values were used in an analytical model to determine a suitable pumping
rate (35 gpm). Peterson-Puritan then began operating the recovery well on
July 18, 1984 at a rate of 40 gpm. Contaminated groundwater is discharged
to the BVSD sewer under permit. In sampling done prior to an initial pump
test, total VOC concentration in the discharged groundwater ranged from 247
ppm to 348 ppm.
The need for remedial action can be determined by assessing the following
factors:
the existence of continued releases from other potential sources to
the currently contaminated medium i.e., groundwater;
the extent to which the actions taken to date controls continued
release of contaminants from the Peterson-Puritan property;
the extent to which the existing contamination is affecting the
public health, welfare, and the environment; and
the potential for further migration of the existing contamination
i.e., to new supply wells in the downgradient Lonsdale Uellfield.
The steps taken by Peterson-Puritan were aimed at preventing continued
infiltration from the plant area, but can only control the movement of
groundwater to the limit of the recovery well's influence. Beyond this
limit, there is still a volume of groundwater contaminated with VOCs at
lower concentrations. This groundwater is also expected to discharge to
the Blackstone River.
3-9
According to the Endangerment Assessment done by NUS in May of 1984, the
major risk associated with this site concerns the consumption of
contaminated groundwater (Ref. No. 4, Attachment F). In the study done by
Versar Inc. in 1984, however, it was stated that noticeable contributions
of VOCs to the Blackstone River could theoretically occur under worst case
conditions. The possibility exists for exposure of some population to
these chemicals by direct ingestion of water or through consumption of
biota in the river. Therefore, removal and/or containment of the VOC
groundwater plume may be necessary to prevent downstream contamination of
drinking water wells and of the Blackstone River. (Note that no public
supply wells in the area are currently being used).
It is difficult at this time to evaluate the need for remedial actions
without more information on the uses of the river, a better definition of
plume boundaries and rate(s) of movement (Ref. No. 10, Attachment F), and
the possible presence of contamination from other sources requiring
control.
3-10
4.0 DISCUSSION OF EXISTING DATA BASE AND DATA GAPS
The existing information on the Peterson-Puritan site is composed of
analytical data from the sampling efforts of the Rhode Island Department of
Public Health (RIDOH), the EPA, GZA, and MP. See references No. 1, 2, 3
and 11, Attachment F. A brief description of these sampling efforts is
provided below:
o RIDOH has routinely sampled and analyzed the municipal supply wells
in this area. They also obtained split samples of the 1980-1982 GZA
sampling program. Data reported in the GZA and MP reports dates
back to the 1979 sampling of the Lincoln Supply Well No. 6 and
Cumberland's Lenox Street Well (CW-405). (Note that this data
represents the only water quality information for the period during
which the supply wells were pumped.)
o EPA collected samples of the soils, tanks, and discharges at the
Lonza Chemical Plant in October of 1981 and also analyzed several
split samples from GZA's sampling program when they were under
contract to EPA.
o GZA completed a sampling program in 1980-1981 for their March 1982
report (Ref. No. 1, Attachment F) to EPA concerning the source of VOC
contamination in the Quinnville Wellfield. They installed 5 moni
toring wells and sampled these, as well as existing monitoring and
production wells in the study area for a total of 27 wells. Fourteen
surface water samples were also taken in the Blackstone Canal, the
Blackstone River and the brooks and discharges to that river. Also,
one sample was taken of the sewer line leaving the Peterson-Puritan
plant.
o Malcolm Pirnie, Inc. completed a sampling program for their client,
Peterson-Puritan Inc., in 1983 (Ref. No. 2, Attachment F). The
results of this sampling effort are contained in their report of
June 1983 and cover the sampling of 38 wells (27 new well installa
4-1
tions), 3 surface water sampling points (in Brook A flowing from the
Peterson-Puritan plant to the river), and soil samples from three of
the four in-plant borings installed by Clarence Welti Associates at
Peterson-Puritan, as well as the front and back septic tanks. Also,
biological testing of soils and groundwater from several shallow
monitoring wells (MH series wells shown in Figure 3) located along
the sewer was done to assess leakage in the BVSD sewer line. Since
this study MP has continued to sample some of these monitoring wells
as well as surface water at six locations in the Blackstone River.
Most of the samples collected have been analyzed for priority pollutant
volatile organics because VOC contamination was the cause of the closing of
the Quinnville supply wells and the Lenox Street supply well. See
Attachment Tables B-3, B-4, B-5, B-6, C-3, C-4, C-5, C-6, C-8, C-9, C-10,
C-ll, C-12, D-2 and E-2. Other types of analyses were conducted by EPA and
MP however and they are listed below.
o Soils
- Fecal coliform and streptococci testing on soils around the BVSD
sewer line by Malcolm Pirnie, Inc. (see Attachment Table C-17);
o Surface Water
- Non-specific parameter analysis, i.e. pH, temperature, specific
conductance, dissolved oxygen, total organic carbon, BOD,., COD, and
total organic halogen, on surface water from the Blackstone River by
Malcolm Pirnie Inc. (see Attachment Table B-6);
o Groundwater
Priority pollutant metals analysis on J.M. Mills Landfill monitoring
wells by EPA (see Attachment Table C-13), and on selected wells
sampled by Malcolm Pirnie Inc. (see Attachment Table C-14);
4-2
- 84 priority pollutants analysis including base/neutral extractables,
acid extractables, pesticides, PCBs, cyanide and phenols on selected
wells sampled by Malcolm Pirnie Inc. (See Attachment Table C-14 for
cyanide and phenol concentrations and Attachment Table C-15 for
results of base/neutral and acid extractables, pesticides and PCBs).
Note that though none of the 84 priority pollutants were detected,
not shown on these tables is a second, more sensitive (ppt rather
than ppb) analysis of MW A-l for pesticides. This analysis revealed
a concentration of 12.5 ppt of dieldrin in that well sample.
Non-priority pollutant peak analysis on selected wells sampled by
Malcolm Pirnie Inc. (see Attachment Table C-16);
- Lonza and Syntron source parameter analysis on selected wells sampled
by Malcolm Pirnie Inc., (refer to Table 2 for a listing of parameters
which can be linked to the respective plants i.e. source specific and
Attachment Table E-2 for analytical results);
- Nitrate-nitrite and other inorganic anlayses (i.e. total dissolved
solids, bromide, chloride, iodine, formaldehyde, acrylates, iron,
ammonia, sodium, potassium, bicarbonate, etc.) on selected wells
sampled by Malcolm Pirnie Inc., (see Attachment Table C-14);
- Fecal and streptococci testing on groundwater wells around the BVSD
sewer line (MH series) sampled by Malcolm Pirnie Inc. (see Attachment
Table C-17); and
Non-specific parameter analysis, i.e. pH, temperature and specific
conductance for selected wells sampled by Malcolm Pirnie Inc., (See
Attachment Table C-15).
COM has reviewed the raw analytical data in the 1982 GZA report, as well as
the 1983 Malcolm Pirnie Inc. report and three updated sampling reports from
Malcolm Pirnie Inc. (dated August 18, 1983, July 24, 1984, and August 8,
1984). The data was compiled into a data base which is amenable to further
4-3
TABLE 2
LONZA AND SYNTRON PARAMETERS
Lonza Parameters
Acetone (volatile) 2-Propanol (volatile) C-6 to C-10 alkanes (volatileand base-neutral) Methyl ethyl ketone (volatile) 1,4-Dioxane (base-neutral) Xylene (volatile)
Syntron Parameters
Dimethylamine (base-neutral) Phenols Formaldehyde Gross acrylates
Refer to Attachment Tables E-l and E-2 for a description of the locations of sampling points at the Lonza plant and the analytical results corresponding to the samples collected at those locations. Note that the parameters listed are source-specific to the respective plants.
4-4
additions and updates. See Table A-l thru D-2 for analytical data
associated with sampling locations noted in Figure 3.
The data shows that GZA found Brook A, which flows along the western side
of the Providence and Worcester Railroad across the Peterson-Puritan site
to the Blackstone River, was contaminated by volatile organics (60 ppb
trichloroethylene, 20 ppb vinyl chloride, and 30 ppb 1,1,1-trichloroethane,
among others) in 1981. Analyses by Malcolm Pirnie in 1984 determined that
the Blackstone River contained low (0.5-1.5 ppb) concentrations of volatile
organics. Both the Lincoln Supply Well No. 6 in the Quinnville Wellfield
and Lenox Street Supply well have volatile organic contamination. The
total volatile organic concentrations found in these wells range from 1 to
242 ppb and 13 to 76 ppb, respectively. (Refer to Attachment C Tables C-3
through C-5.)
Other areas of contamination documented by the data include the southwest
ern section of the Peterson-Puritan property. The total volatile organic
concentrations found in the groundwater sampled from wells Malcolm Pirnie
Inc.-8, Malcolm Pirnie Inc.-4A, Malcolm Pirnie Inc.-4B, Malcolm Pirnie
Inc.-5, Malcolm Pirnie Inc.-6A, and Malcolm Pirnie Inc.-6B were from 57 to
186,700 ppb. (Refer to Attachment Table C-ll.)
The groundwater sampled in wells Malcolm Pirnie Inc.-lOA, 10B and IOC and
Malcolm Pirnie Inc.-llA, 11B and 11C which are located between the
Healthtex facility and the Blackstone River was found to contain total
volatile organic concentrations ranging from 118 to 18,254 ppb. (Refer to
Attachment Table C-ll.)
A careful review of the existing data base has resulted in the identifica
tion of several data gaps which need to be assessed. As it concerns the
remedial investigation, they are listed below:
o A better definition of the current extent of the VOC plume emanating
from the Peterson-Puritan facility:
4-5
- Malcolm Pirnie (Ref. No. 2, Attachment F) and Versar (Ref. No. 3,
Attachment F) state that the plume does not extend to the south
enough to include the J.M. Mills landfill and the leading edge is
the Blackstone River. Therefore, the plume does not currently
include the Lenox Street well or the Quinnville wellfield (the
Lenox Street well was never in the plume).
GZA states that the plume extends south along the river beyond
the Lenox Street well paralleling the river with little
transverse spreading east and west of the river's floodplain.
o A better definition of the plume emanating from the Peterson-Puritan
facility versus that from other sources:
- GZA, Malcolm Pirnie and Versar (Ref. Nos. 1, 2 and 3, Attachment
F) acknowledge the potential for multiple plumes emanating from
various sources, i.e. Dexter Quarry, J.M. Mills Landfill and a
potential upgradient plume near TW-3.
o A better definition of the hydrogeology of the site (given that flow
patterns are the key to the fate and transport of contaminants in
the aquifer which was concluded in all previous studies) especially
the river as a discharge point for the contaminated groundwater, the
potential for a parallel component of flow along and underneath the
river, the relative contribution of the river to the supply wells
during pumping and the direction of flow lines adjacent to the
river:
- GZA states there is a parallel component of flow along the river.
- Malcolm Pirnie states that there is no flow parallel to the river
but that complete discharge to the river occurs.
- The contribution of the river to the supply wells during pumping
was estimated to be high (>50%) by GZA however the actual amount
versus flow from the aquifer under the river and on the other
4-6
side of the river would be dependent upon the assumed
permeability of the river sediments (a high value of
gal/foot/day was assumed).
1000
The flow lines generated by Malcolm Pirnie based on the water
level measurements bend more closely around the river then those .
generated by GZA's model indicating a shorter travel time of
groundwater flow prior to discharging to the river.
o A definition of the area of influence of the Quinnville wells and
the Lenox Street well under the pumping rates used to obtain water
supplies prior to their closure to definitively identify potential
sources for further investigation.
o A definitive assessment of the potential contribution of the BVSD
line, J.M. Mills Landfill, and Dexter quarry:
- Though evidence for releases from each of these sources has been
presented, no definitive assessments have been made.
o Investigation into the upgradient contamination found in well TW-3
including potential releases from the H&H Screw Co.:
- This contamination was detected during the Malcolm Pirnie study
and attributed to "background contamination".
o Delineation of soil source areas at the Peterson-Puritan plant:
Malcolm Pirnie sampled three onsite borings and found no VOC
contamination, however, this is not indicative of a comprehensive
soil investigation and strong odors indicating organic
contamination were noted in two borings.
o An assessment of the contamination of surface water and sediment
onsite and the resulting wetland and floodplain impacts:
4-7
- Although GZA sampled the river and the canal and found low to
nondetected levels of VOCs, their sampling technique called for
collecting samples 1-2 inches below the water surface where
volatilization would be expected to occur.
No sediment samples have been collected. (These samples would be
important because sediments are the medium through which flow
between the river and aquifer occurs and impacts to aquatic life
in the stream can be assessed based on this).
o An assessment of the potential impacts of the contaminated
groundwater on downgradient aquifer usage for drinking water
supplies.
o An assessment of the potential impacts of the site on the proposed
linear park planned to pass through the site.
o Pump tests for recovery well operations to cleanup the contaminated
groundwater.
o Treatability field tests concerning implementation of remedial
cleanup activities (e.g. air stripping of groundwater or aeration of
soils).
4-8
5.0 SCOPE OP WORK
Introduction
The purpose of the RI/FS is to execute a series of tasks that will lead to
the identification and conceptual design of the remedial alternative
selected for implementation at the Peterson-Puritan site. This Work Plan
(Task 1 of the scope of work) describes in detail the activities required
to complete this RI/FS.
The Work Plan consists of fifteen tasks as follows:
.TASK 0: Work Plan Memorandum
TASK 1: Development of Work Plan
TASK 2: Screening of Preliminary Remedial Technologies
TASK 3: Remedial Investigation Scope of Work
TASK 4: Identification of Preliminary Remedial Technologies
TASK 5: Baseline Risk Assessment
TASK 6: Preparation of Remedial Investigation Report
TASK 7: Remedial Investigation Support
TASK 8: Development of Alternatives
TASK 9: Initial Screening of Alternatives
TASK 10: Detailed Evaluation of Remaining Alternatives
TASK 11: Preparation of Draft Feasibility Study Report
TASK 12: Conceptual Design of Selected Remedial Alternative
TASK 13: Final Feasibility Study Report
TASK 14: Feasibility Study Support
Tasks 2 through 7 encompass the Remedial Investigation and Tasks 8 through
14 encompass the Feasibility Study. Each of these tasks is described in
the remainder of this section.
5-1
5.1 TASK 0 - WORK PLAN MEMORANDUM
OBJECTIVE:
The Work Plan Memorandum was developed to establish a schedule and level of
effort estimate for the development of the Work Plan.
DELIVERABLE: A Work Plan Memorandum.
5.2 TASK 1 - DEVELOPMENT OF WORK PLAN
OBJECTIVE:
Prepare a draft Work Plan for the activities to be performed under the
subject work assignment.
APPROACH:
The work plan includes the following:
1. A description of site with a review of the remedial history of the
site,
2. A review and summary of known hydrogeologic data pertinent to the
site,
3. A discussion of existing data base with a summary of known data
gaps,
4. A scope of work which will direct the RI/FS phases of the project,
and
5. A detailed schedule and budget information.
The draft work plan will be finalized by incorporating EPA comments on the
draft work plan.
5-2
DELIVERABLES: A Draft Work Plan.
A Final Work Plan.
5.3 TASK 2 - SCREENING OF PRELIMINARY REMEDIAL TECHNOLOGIES
OBJECTIVE:
Identify possible response actions, and remedial technologies which could
be mixed and matched to enact responses with the primary objective of
protecting the public health and minimizing adverse environmental effects.
Also, the applicable or relevant and appropriate requirements which will be
applied to the remediation of this site will be identified as well as other
Federal criteria, advisories, and guidance and State standards which will
be considered.
APPROACH:
Table 3 represents the first cut of applicable response actions and Table
4 represents the first cut of applicable remedial technologies using
existing information. Note that the response action categories and
technology lists were developed using the 1985 issue of "Guidance on
Feasibility Studies Under CERCLA." (Ref. No. 12, Attachment F.) As the
information and data base is expanded during the RI, other applicable
technologies may be identified and this list will be modified as discussed
under Task 4. The technologies will be screened based on the following:
- Waste limiting characteristics,
- Site limiting characteristics, and
- Level of technology development.
Note that special consideration will be given to technologies that
permanently contain, immobilize, destroy, or recycle contaminants, and
technologies that promote energy recovery. The feasibility of mixing and
matching these technologies into alternatives will be considered.
5-3
TABLE 3
PRELIMINARY ASSESSMENT OF GENERAL RESPONSE ACTIONS
Blackstone River General Response Actions Valley Aquifer
No Action Yes Containment Yes Pumping Yes Collection Yes Diversion Yes Complete Removal Yes Partial Removal Yes Onsite Treatment Yes Offsite Treatment Yes Insitu Treatment Yes Storage No Onsite Disposal Yes Offsite Disposal Yes. Alternative Water Supply No Relocation No
Note that aside from contaminated groundwater no soil source areas or contaminated surface water or sediment requiring remediation have been identified as yet.
9 The contaminated groundwater found onsite is in the Blackstone River Valley Aquifer which is an overburden sand and gravel (with silt and clay) aquifer.
o An alternative water supply has already been arranged for the Town of Lincoln and the Town of Cumberland.
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TABLE 4
PRELIMINARY ASSESSMENT OP REMEDIAL TECHNOLOGIES1
Blackstone River Remedial Technologies Valley Aquifer
A. Air Pollution Controls No B. Surface Water Controls No C. Leachate and Ground Water Controls Yes D. Gas Migration Controls No E. Excavation and Removal of Waste
and Soil No F. Removal and Containment of
Contaminated Sediments No G. Insitu Treatment Yes H. Direct Waste Treatment Yes I. Land Disposal Storage Yes J. Contaminated Water Supplies and
Sever Lines Yes
C. Leachate and Groundwater Controls
Capping No Containment Barriers Yes Pumping Yes Subsurface Collection Drains Yes
G. Insitu Treatment
Hydrolysis Yes Oxidation Yes Reduction Yes Soil Aeration Yes Solvent Flushing No Neutralization No Sulfide Precipitation No Bioreclamation Yes Permeable Treatment Beds Yes Chemical Dechlorination No
H. Direct Waste Treatment
Incineration No Gaseous Waste Treatment No Treatment of Aqueous and Liquid Waste Streams No
5-5'
TABLE 4 (Cont'd)
PRELIMINARY ASSESSMENT OF REMEDIAL TECHNOLOGIES FOR THE PETERSON-PURITAN SITE
Blackstone River Remedial Technologies Valley Aquifer
H. Direct Waste Treatment (Cont'd)
Biological Treatment Yes Chemical Treatment Yes Physical Treatment Yes Discharge to POTW Yes
Solids Handling and Treatment No Solidification, Stabilization, of Fixation No
I. Land Disposal Storage
Landfills No Surface Impoundments No Land Application Yes Waste Piles No Deep Well Injection Yes Temporary Storage No
J. Contaminated Water Supplies and Sewer Lines
Insitu Cleaning Yes Removal and Replacement Yes? Alternative Drinking Water Supplies No Individual Treatment Units No
The technologies noted as applicable are primary technologies not those associated with residuals from the primary technologies i.e. primary technology of soil aeration not secondary technology of air pollution control of residual gaseous emissions from aeration.
As previously stated, an alternative water supply has already been arranged for both the Town of Lincoln and the Town of Cumberland.
5-6
2
The screening will result in technologies which will be used to develop
remedial alternatives for the site in Task 8. Note that the EPA Guidance
Document for Feasibility Studies published in June of 1985 (Ref. No. 12,
Attachment F) states that, at a minimum one alternative be developed for
each of the following categories:
o No Action,
o Off-site treatment or disposal,
o An alternative which does not meet full compliance with applicable
or relevant and appropriate federal and public health or
environmental standards but will reduce the present and future
threat from hazardous substances,
o An alternative that complies with all applicable or relevant and
appropriate federal public health or environmental standards, and
o An alternative that exceeds the requirements of all applicable
or relevant and appropriate federal public health or environmental
standards.
DELIVERABLE: Preliminary list of technologies applicable to the site.
5.4 TASK 3 - REMEDIAL INVESTIGATION SCOPE OF WORK
OBJECTIVE:
Evaluate the nature and extent of contamination on the Peterson-Puritan NPL
site providing sufficient detail to properly evaluate remedial alternatives
which might be implemented to mitigate the existing contamination.
5-7
APPROACH:
The field investigation phase of the remedial investigation will be divided
into two phases. This multi-phased approach will provide an evaluation of
ongoing field investigations in an attempt to direct activities in the most,
technically feasible and cost effective manner.
Phase I of the field investigation will focus on defining the hydrogeologic
framework and characterizing the lateral and vertical extent of groundwater
and soil contamination. Surface waters and sediments will be sampled to
determine potential contaminant migration pathways. Seasonal groundwater
quality will be determined by periodic sampling in selected wells to
establish a reliable data base for remediation. Environmental impacts of
contamination will be evaluated with respect to onsite wetland and flood
plain areas. Potential contaminant sources and pathways will be identified
by evaluating the potentiometric surface, aquifer geometry and water
quality information derived from seismic data and the installation and
sampling of groundwater monitoring wells. The currently identified source
of contamination, Peterson-Puritan, Inc., will be investigated for areas of
potential soil contamination. Phase I of the field investigation will
include:
Subtask 3A Projection Operations Plan
Subtask 3B Site Base Map
Subtask 3C Surface Water and Sediment Sampling
Subtask 3D Determination of Status of Existing Wells
Subtask 3E Seismic Refraction
Subtask 3F Monitoring Well and Piezometer Installation
Subtask 3G Groundwater Sampling (Including Water Level Measurements)
Subtask 3H Wetlands/Floodplain Evaluation
Subtask 31 Peterson-Puritan Plant Visit
Subtask 3J Identification of Soil Source Areas at Peterson-Puritan
Phase II of the field investigation will provide an assessment of sources
responsible for the contamination in the Quinnville wellfield and Lenox
Street well. Additional activities may be selected subsequent to
5-8'
evaluation of data obtained from Phase I of the field investigation.
Potential tasks will include: pumping tests conducted on the municipal
supply wells, additional monitoring well installation and groundwater
sampling, and an exfiltration study of the BVSD line. Contaminated soil
source areas associated with each source will be delineated via field
screening techniques. Also, any further characterization of the existing
surface water and sediment contamination will be delineated based on biota
sampling. Phase II includes:
Subtask 3K Biota Sampling
Subtask 3L Pump Test(s) (Lenox Street and Quinnville Wellfield)
Subtask 3M Exfiltration Study
Subtask 3N Soil Sampling of Source Areas (not limited to
Peterson-Puritan)
Subtask 30 Additional Monitoring Well and Piezometer Installation
Subtask 3P Additional Groundwater Sampling
As proposed, Phase II of the field investigation will be used to fill any
data gaps remaining after Phase I and would only be initiated upon
receiving written notification from EPA to proceed with each individual
subtask. Note that a third phase or an expansion of activities in Phase
II may be required to investigate newly identified sources. However these
activities cannot be planned or budgeted for at this time.
PHASE I FIELD PROGRAM
Subtask 3A - Project Operations Plan
OBJECTIVE:
Develop a Project Operations Plan (POP) prior to initiating the field
program to identify the individuals responsible for conducting the field
activities, the sampling procedures and frequency, health and safety
procedures, and Quality Assurance procedures.
5-9
APPROACH:
The plan will consist of the following four components:
1. Field Activities Quality Assurance/Quality Control;
2. Site Specific Health and Safety;
3. Sampling and Analysis; and
4. Site Management.
A general description of each component follows:
1. Field Activities Quality Assurance/Quality Control (QA/QC)
The QA/QC components will address issues related to sampling and
analyses, auditing provisions, and reports to management. The
following topics will be addressed in the QA/QC section:
a. Quality control objectives for measurement data, in terms of precision, accuracy, completeness, representativess, correctness and comparability;
b. Sampling procedures;
c. Sample chain-of-custody;
d. Calibration procedures, references, and frequency;
e. Internal quality control checks and frequency;
f. Quality assurance performance audits, system audits and frequency of implementation and non-conformance reports;
g. Quality assurance reports to management;
h. Preventive maintenance procedures and schedule;
i. Specific data validation procedures to be used to routinely assess data precision, representativeness, comparability, accuracy, and completeness of specific measurement parameters involved; and
j. Procedures for corrective actions.
2. Site Specific Health and Safety
As part of the POP, a site specific health and safety section will be
prepared prior to initiating the field investigation program. It is
expected that Level D protection will be required for all site
5-10
activities except possible Level C for sampling in the BVSD
interceptor. This section will be consistent with the following:
a. Section 111 (c) (6) of CERCLA;
b. EPA Order 1440.1 - Respiratory Protection;
c. EPA Order 1440.3 - Health and Safety Requirements for Employees Engaged in Field Activities;
d. OSHA Safety and Health Standards (29 CFR 1910);
e. EPA Occupational Health and Safety Manual;
f. Other EPA Guidance Health and Safety Manuals;
g. CDM's Draft Health and Safety Assurance Manual;
h. State safety and health statutes; and
i. Site conditions.
The Health and Safety section will include the following items:
o Medical Surveillance program;
o Personal Protective Equipment Needs and Protocol;
o On-Site Monitoring Equipment Requirements;
o Safe Working Procedures Specification;
o Training Protocols;
o Ancillary Support Procedures;
o Emergency Procedures;
o Evacuation Procedures Contingency Plan;
o Decontamination Procedures for Equipment;
o Decontamination Procedures for Personnel; and
o Compliance with Full Disclosure/Right to Know Requirement.
3. Sampling and Analysis
COM will prepare and submit to EPA as part of the POP a detailed samp
ling and analytical section for the site. The sampling and analytical
component shall include a description of and support justification for:
1. Type, quantity and location of samples to be collected;
2. Sampling methods to be used;
5-11
3. Sample shipping procedures; and
4. Type of test(s) to be run on each sample.
The Quality Assurance, Health and Safety, and Sampling and Analytical
components for the site will be incorporated into a single document, the
Project Operations Plan (POP). This site-specific document provides a
single reference for all site activities conducted during this program.
4. Site Management
The Site Management component of the POP will govern all operations at
the site, including site access, site security, disposal or decontami
nation of field equipment, obtaining public utilities for use as
needed, contingency plans for non-site personnel, and the general
coordination of all activities planned for the site.
The POP will be prepared after the Work Plan is complete but prior to the
beginning of the field activities. Any revisions required to the POP as a
result of previously completed field activities will be completed prior to
initiating the particular field activity of concern.
DELIVERABLE: A Draft Project Operations Plan.
A Final Project Operations Plan.
Subtask 3B - Site Base Map
OBJECTIVE:
Develop an updated detailed site base map.
APPROACH:
A detailed site base map will be constructed prior to initiating any field
work. The base map will be a more detailed version of the existing map
shown in Figure 3. It will show the location of major physical structures
5-12
in the area, the existing road network, the Blackstone River and canal,
wetland areas, existing monitoring and supply wells, high voltage utility
lines, BVSD interceptor sewer, location of previous sampling points for
both surface water and river sediments, proposed sampling points and the
site orientation. The site base map will be drawn at a scale of 1 inch
equals 100 feet. COM will input all base map data onto a digital computer
for ease of map generation at different scales and added flexibility in
generation of maps with different data and areas of focus.
Currently, the Environmental Photographic Interpretation Center (EPIC) in
Warrenton, Virginia is developing an aerial photographic analysis of this
site. Aerial photographic coverage of the area surrounding this site from
1939 through 1986 was obtained. Of note is a fracture trace analysis
(linement study) which may lend support to identifying preferential
pathways of contaminated groundwater flow in bedrock. This regional
overview will be compared to the limited fracture trace analysis performed
by Ecology and Environment Inc. in the Dexter Quarry area. EPIC will also
incorporate a wetlands and drainage analysis in their report which will
delineate surface water pathways. This information will be incorporated
onto the site base map.
The site base map will be finalized after being field checked against the
location of existing monitoring wells and other points of reference (i.e.
high voltage lines etc.). The final site base map will include site
topography (2 foot contour intervals below an elevation of 120 feet and 5
foot contour intervals above this elevation), property lines, easements,
rights-of-way or detailed information specific to each industrial property
within the site. The site base map will cover an area approximately 2
miles long by 1 mile wide centered around the Blackstone River from a point
approximately 2500 feet upstream of the Martin Street bridge to a point
approximately 300 feet downstream of the Lenox Street Well.
Upon completion of the first phase of Task 3, the site base map will be
revised and updated to show the actual sampling locations, seismic
traverses, depths to bedrock, bedrock outcrops, and affected wetlands. A
5-13
second revision may be required after implementation of any subtasks during
the second phase of Task 3.
DELIVERABLES: An existing conditions site base map as described above.
An updated site base map showing new sampling locations.
Subtask 3C - Surface Vater and Sediment Sampling
OBJECTIVE:
Define the existing nature and extent of contamination of surface waters
and sediments onsite, i.e. 5,500 feet upstream of the Quinnville wellfield,
and .4,500 feet downstream of the Quinnville wellfield (which is about 500
feet downstream of the Lenox Street well).
This allows an assessment of the impact of contaminated groundwater on
local surface water and vice versa (note that the Blackstone River, Canal
and BSVD line are potential sources of the groundwater contamination).
Sediment sampling gives an indication of the cumulative impacts of the
site. The data will be used to determine the need for remedial action and
will provide the basis upon which to assess what appropriate remedial
actions could be implemented and the extent of those actions.
APPROACH:
A total of nineteen (19) surface water/sediment sampling locations are
identified on Figure 6. These locations include:
o The Blackstone River and Canal (9 locations adjacent to contaminated
supply wells and upgradient and downgradient of the site i.e. SV-1,
SW-2, SW-5 Stf-6, SW-9, SW-10, SW-11, SV-18, and SW-19);
o All outlets of tributaries flowing into and out of the Blackstone
River and Canal (five locations including two in Brook A, one in
Dexter Quarry Brook one in the discharge pipe to the Sand and Gravel
5-14
Operations due east of Healthtex, and one in the stream flowing into
the river from the marshy area southwest of the Lenox Street well
SV-3, SV-4, SU-7, SW-8, and SV-13);
o The wetland areas north of the Providence and Worcester Railroad and
northwest of the Lenox Street well (three locations i.e. SW-14,
SV-16, and SV-17); and
o Several ponded water locations between the landfill perimeter and
the river which may constitute leachate breakouts (two composite
samples i.e. SV-11 and SW-12).
All surface water samples will be analyzed for Volatile Organics (VOAs) on
the Hazardous Substance List (HSL) by a Contractor Laboratory Program (CLP)
laboratory. In addition, samples SV-1, SW-2, SU-11, and SW-12, SW-18 and
SW-19 will be analyzed for Extractable Organics (HSL), Priority Pollutant
Metals (Task 1 and 2) and Total Cyanide (Task 3). (Note that a special
request for a one part per trillion detection limit will be requested for
dieldrin when extractable organics are analyzed for; and trichlorofluoro
methane will be analyzed for when VGA samples are collected because it is
not on the HSL. These locations were selected to provide an indication of
any Extractable Organics or metals contamination contribution from the site
i.e. samples in the river both upgradient and downgradient of the site and
around the landfill. All sediment samples will be anayzed for the full HSL
list (VOAs and Extractable Organics, Priority Pollutant Metals, Tasks 1 and
2, and Total Cyanide, Task 3).
Sampling will occur in October during the period of seasonal low flow
during which the groundwater contribution to stream flow to the river is at
its maximum. All samples are to be collected after a three to four day
period during which no rainfall has occurred. Surface water samples taken
at SV-3, SW-4, SW-7, SW-8, SV-11,SW-12, SV-13, SW-14, SW-16 and SV-17 will
be grab samples. These locations correspond to samples collected in Brook
A, the Sand and Gravel Pit outlet to the river, Dexter Quarry Brook, ponded
water around the J.M. Mills Landfill, and the stream flowing into the river
from the wetlands northwest of the Lenox Street well, and wetlands and
5-16
associated surface waters. Surface water samples taken at SW-1, SW-2,
SW-5, SW-6, SW-9, SW-10, SW-15, SW-18 and SW-19 will also be grab samples
but attention will be taken to collect these samples at a point one third
the distance of the depth of the river from the river bottom, all at a
mid-channel location. These sample locations are all taken in the
Blackstone River and canal where it is felt that a representative sample of
river water quality necessitates sampling in the zone of complete mixing.
Discharge flow rates will be measured at representative locations in the
river, canal and brooks, or streams associated with the Blackstone River and
Canal. Staff gauges will be established at selected locations and will be
surveyed to determine the relative water level differences of the river in
comparison with water levels in nearby wells and piezometers.
A sediment sample will be taken in the vicinity of each surface water and
sewer sampling location. Sediment samples will be collected in a local eddy
where deposition of fine-grained material occurs, as opposed to the scouring
patterns which typically occur at mid-stream or on the outside bend of the
river. Sediment samples will be collected as grab samples to be composited
from depths of 0-12 inches. An attempt will be made to test for the
hydraulic conductivity of these materials as to their role as a barrier to or
medium of contaminant transport between the river and the aquifer.
(Procedures will be described further in the Project Operations Plan.)
The analytical results will be used to develop a wetlands/floodplain
assessment (see Subtask 3F) and will provide information on potential
sources. Background information in the form of upstream NPDES discharges
will be reviewed as an aid in estimating river water quality impacts from
the industries upstream. Further environmental impacts may require an
assessment via biota sampling in Phase II if sediment contamination is
found to be significant. Also further investigation of the river, canal
and sewer line may be conducted in Phase II under the proposed pump tests
and sewer exfiltration study.
5-17
Note that additional surface water and sediment sampling is not planned for
in this Work Plan and would require a work plan amendment for Phase III
task(s).
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results, and an
interpretation of the data.
A map showing graphical representation(s) of analytical
results.
Subtask 3D - Determination of Status of Existing Veils
OBJECTIVE:
Determine the status/condition of existing wells within the site boundaries
for the purpose of their potential use as monitoring wells for groundwater
sampling.
APPROACH:
Well logs for all existing wells within site boundaries will be obtained.
Access to all public supply wells and private monitoring wells, i.e. J.M.
Mills Landfill wells, wells Malcolm Pirnie installed for Peterson-Puritan
Inc., will be obtained for inspection and possibly sampling of these wells.
The wells will then be located in the field (an activity which may require
the help of the consultants who installed them i.e. GZA or Malcolm Pirnie.)
The integrity of each well will be evaluated in terms of its hydraulic
communication with the aquifer. The construction of the well will be
verified. The suitability of each well as a sampling point for groundwater
will then be concluded. (Note that for wells determined to be suitable and
designated for sampling, protective casings, if necessary, will be
installed by the drilling contractor selected to install the new COM
wells.)
5-18
DELIVERABLES: A memo report containing the well logs, and an evaluation of
the usefulness/condition of each well for sampling.
Subtask 3E - Seismic Refraction
OBJECTIVE:
Obtain information on the shape of the valley to determine whether there is
enough evidence to warrant further investigation of a deeper component of
groundwater flow parallel to the Blackstone River.
APPROACH:
Three seismic refraction traverses will be performed to provide additional
information regarding the bedrock surface under the river. Seismic data
will be used to map the bedrock topography and to establish wave velocities
for consolidated and unconsolidated materials. A multi-channel unit with
explosives are expected to be needed due to the expected depth to bedrock
(approximately 100 feet in the vicinity of monitoring well GZ-1) and the
glacial till layer which appears to run along the top of the bedrock.
Seismic data will be confirmed using the existing and proposed monitoring
well boring data. It is estimated that a total of 6,000 linear feet of
seismic refraction profiling will be conducted and will consist of three
traverses, 2,000 linear feet each. The proposed locations are shown on
Figure 6. These locations were selected to provide information on the area
between the Peterson-Puritan facility and the Quinnville wellfield, the
Quinnville wellfield, and the Lenox Street well. The area of primary
concern for a preferential pathway linking the Peterson-Puritan plant and
other potential upgradient sources on the east side of the river with the
Lenox Street well will thus be investigated. The information obtained
during this survey will be used to assist in determining well locations and
will be used in conjunction with well data to develop a bedrock contour
map.
DELIVERABLE: A memo report with seismic data, profiles and corresponding
locations with interpretation of results.
5-19
Subtask 3F - Monitoring Well and Piezometer Installation
OBJECTIVE:
Install monitoring wells in order to define the nature and extent of
groundvater contamination surrounding the Quinnville and Lenox Street
wells. Install piezometers to determine the potentiometric head
differences across the site, especially in the vicinity of the Blackstone
River and Canal, to aid in the understanding of contaminant transport
across the site.
APPROACH:
Additional groundwater monitoring wells are needed to supplement the use of
several existing wells. As shown on Figure 6, a total of ten (10) well
cluster locations are proposed, MW-101 through MU-110, and one singular
well location, MW-111. Each cluster will consist of three (3) monitoring
wells, one at mid-depth in the overburden, one at the sand and
gravel/glacial till interface and one approximately thirty (30) feet into
the bedrock. Monitoring well MW-111 will be drilled into bedrock. It is
assumed that the existing wells targeted for sampling are useable. If
during Subtask 3D this proves otherwise, then additional wells will be
installed as needed. (Preliminary site inspections have revealed that some
of these wells are under water during part of the year due to river
flooding and some of the wells have been vandalized.)
A background well cluster, upgradient of the Peterson-Puritan facility and
the septic leachfield in the back part of the property, is needed (well
cluster MV-101). The overburden pinches out in this area and therefore the
placement will be close to well clusters to MP-1 and MP-7 (See Figure 3).
Well clusters MP-2 and MP-3 are upgradient wells which represent discharges
to the river and are probably not in the plume as defined as emanating from
the Peterson-Puritan facility. Well clusters MW-102 and MW-103 will be
placed to locate the upgradient boundary of the plume near the river.
5-20
Well clusters MW-104 and MV-106 are needed to define aquifer geometry and
water quality south of the canal where no wells are currently located.
Well cluster MU-105 is needed to determine water quality in the area near
the sand and gravel operations and the sewer.
Veil cluster MW-107 is located between the J.M. Mills Landfill and the
Lenox Street well. Well cluster MW-110 will monitor water quality south of
the Lenox Street supply well and in the vicinity of the solid waste
transfer station. Well cluster HW-108 will monitor water quality near the
river. Well cluster MW-109 will be located northeast of the Lenox Street
well to determine background water quality of the groundwater component to
the well's total production.
MW-111 will be a single well installed in alignment with the fractures
delineated in the fracture trace analysis performed by E & E to determine
potential bedrock contamination near the Dexter Quarry.
In addition to well installations, ten (10) piezometers will be installed
in the locations shown on Figure 6. Six piezometers (P-l, P-3, P-5, P-6,
P-8 and P-10) will be installed in or on the banks of the Blackstone River
at locations near existing or proposed monitoring wells (in which water
level measurements will be taken). These piezometers will help determine
whether the groundwater is recharging the river or visa versa. Three
piezometers (P-2, P-4 and P-9) will be installed just to the southwest of
the canal. (Because the canal is clay lined,, no piezometers will be
installed in the canal.) In addition, one piezometer (P-7) will be
installed to the northeast of J.M. Mills landfill to define the
potentiometric surface in this area (mounding effects) when coupled with
other existing or new wells in their vicinity. These piezometers will be
used to obtain information on the complex hydrogeology of the site and
define groundwater flow patterns particularly near the river. (Piezometers
will be constructed similar to monitoring wells. However, groundwater
samples will not be collected unless Phase I results indicate the need for
sampling information from these locations.)
5-21
The new well cluster installations entail drilling one well into the
bedrock in order to help define the bedrock elevations especially near the
supply wells. (This information combined with seismic refraction will be
used to develop a bedrock contour map.) Other hydrogeologic information
which will be obtained during well installation will include complete well
logs containing groundwater elevations, split spoon samples at 5 foot
intervals and at major changes in strata, and a physical description of the
overburden.
A drill rig capable of auger, drive and wash, and rock core drilling
capabilities, will be used to install the monitoring wells. The bedrock
wells will be drilled by an air rotary rig with the bedrock aquifer sealed
from the overlying surficial aquifer.
During drilling operations, observations and complete boring logs will be
made by an experienced geologist in accordance with the Burmister soil
classification system, using the description definitions based on the
modified Wentworth Scale. All borings in unconsolidated material will be
sampled at 5 foot intervals using split spoons or other samplers in
accordance with ASTM D 1586-67 (1974). The samples will be field screened
with an OVA or HNu to identify contaminated zones. Continuous rock cores
will be recovered and percent core recovery shall be recorded according to
standard practice. Soil samples and rock cores will be retained as
directed by the site engineer/geologist and collected in accordance with
ASTM D 2113-70 (1976) Vol. 19.
Well and Piezometer Design and Construction
All wells will be 2 inch ID Schedule 40 PVC casing with 10 feet of screen.
The screen will be a 0.010 inch machine slotted continuous wire wound
screen. All connections will be flush joint threaded PVC.
Intermediate level overburden wells will not have the boring advanced to
bedrock but will be stopped at a depth of approximately 30 feet below the
ground surface or immediately above the first confining layer. Bedrock/
till interface wells will have the boring advanced approximately 5 feet
5-22
into rock. The hole will be backfilled to above the bedrock/till interface
to an elevation determined by the on-site geologist. The setting of the
screen will be determined by an on-site field geologist on-site after
reviewing OVA screening data collected from the soil cores for the zone of
maximum contamination and evaluating stratigraphy changes for the most
permeable zone. The casing will be set and then backfilled with clean
sands, (60/40 Ottawa Silica Sand or a comparable substitute) to a level of
no less than one foot above the well screen. Two feet of bentonite pellets
will be used to isolate the screened zone, and the remainder shall be
filled with grout. Upon completion, a 5 foot long 4-inch diameter steel
casing will be grouted 3 feet into the ground for protection, security and
to stop infiltration from the surface flow down into the well casing. The
actual length of casing needed above the ground surface will be a field
decision by COM and EPA based on the known probability of reoccurring flood
waters which could over top the casing. The inner casing will be fitted
with water tight caps to prevent floodwaters from innundating the well in
areas where flooding is likely to occur. The protective steel casing will
be fitted with locking covers keyed alike.
The bedrock wells will be drilled approximately 30 feet into rock. A steel
casing will be advanced a minimum of 5 feet into rock or until competent
rock is reached. The drilling will stop at this point and the casing will
be grouted in. After the grout sets for 24 hours, the boring will be
advanced through the grout to the specified depth into rock, leaving the
rock hole open. The steel casing and water tight caps will be installed as
described above. (The well casing may be substituted for the protective
casing, provided locking covers are installed and secured.)
Upon completion of the well installation a professional surveying
subcontractor will survey the site to determine the elevation (using the
National Vertical 1929 datum) of the wells installed and existing wells
slated for sampling and/or Blackstone River water level observation. All
well installations will be leveled in with an accuracy of +0.01 feet (sea
level). The elevations will be used in subsequent tasks to determine the
groundwater and stratigraphic elevations at the wells.
5-23
DELIVERABLE: Complete Well logs.
Subtask 3G - Groundvater Sampling (including Water Level Measurements)
OBJECTIVE:
Collect samples from 58 new and existing wells using QA/QC procedures for
field screening prior to selection of some samples for analysis by a CLP
laboratory.
APPROACH:
The wells to be sampled during the Phase I program include:
Existing Wells
TW-3A, 3B MW-B1, B2
SW-1 (Okonite Well) MW-C1, C2
MP-9A, 9B, 9C (Martin Street) MW-D
MP-11A, B, C Lincoln Well #6
GZ-1-1, 1-2, 1-3 Lincoln Well #9
GZ-3-1, 3-2, 3-3 Lincoln Well #1
GZ-4-1, 4-2, 4-3 Lenox Street Well
New Wells (CDM wells will be numbered consecutively with a letter following
it designating the cluster location)
MW-101A, 101B, 101C
MW-102A, 102B, 102C
MW-103A, 103B, 103C
MW-104A, 104B, 104C
MW-105A, 105B, 105C
MW-106A, 106B, 106C
MW-107A, 107B, 107C
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MU-108A, 108B, 108C
MW-109A, 109B, 109C
MW-110A, 110B, HOC
MW-111
Existing wells were selected for sampling based on their location with
respect to the plume, potential migration pathways based on water level
contours developed by GZA and Malcolm Pirnie and potential sources. (Note
that Subtask 3D will allow COM to make a more accurate determination of the
condition of these wells for sampling purposes.) Well clusters MP-9 and
MP-11 are in the pathway of the previously defined plume emanating from the
Peterson-Puritan property to the Quinnville Vellfield. Veils GZ-1 and GZ-4
with multi-level Barcad samplers provide data throughout the depth of the
overburden in the Quinnville Wellfield, near the plume and J.M. Mills
Landfill, respectively. Wells GZ-3, MW-B1, MW-B2, MW-C1, MW-C2 and MW-D
provide information on the groundwater quality surrounding the landfill.
Well SW-1, the Okonite production well, is proposed for sampling to help
delineate the upgradient boundary of the plume. Well cluster TW-3 will be
sampled because previous sampling rounds showed high VOC levels which
indicate potential upgradient sources on the west side of the river.
Finally all previously contaminated public supply wells (Lincoln No. 1, 6,
and 9, Lenox Street and Martin Street (MP-9C) will be sampled to determine
current contaminant levels. If any of these wells are deemed inaccessible
or unsuitable for sampling, additional monitoring wells may be installed.
Note that, in addition to collecting and analyzing samples from these
existing wells, the Rhode Island Department of Public Health and/or
Department of Environmental Management files will be reviewed for
additional data on nearby supply wells sampled during their sampling
program.
Sample analyses will be conducted as follows:
o Water level measurements will be taken for all fifty-eight (58)
monitoring wells and ten (10) piezometers.
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o Samples will be collected from all fifty-eight (58) wells for
analysis by a CLP laboratory for Volatile Organics (HSL). (This
will include special requests for analysis of trichlorofluoromethane
which is not on the HSL to help trace a potential distinct plume
from the Peterson-Puritan property.)
o Samples will be collected from twenty (20) wells for analysis by a
CLP laboratory for Extractable Organics (HSL), Priority Pollutant
Metals (Tasks 1 and 2), and Total Cyanide (Task 3). (This will
include a special request for a detection limit of one part per
trillion for analysis of dieldrin.) They are the following wells:
TW-3A, 3B
GZ-3-1, 3-2, 3-3
MW-C2
MW-B1, B2
MW-D
*MV-107A, 107B, 107C
*MW-111
MP-9A, 9B, 9C
Lincoln Well Nos. 1, 6, 9
Lenox Street Well
*New COM wells
These wells were selected to identify and link sources with distinct
plumes (i.e. upgradient Sources, the J.M Mills Landfill, the Dexter
Quarry, abd the Peterson-Puritan facility) to the municipal supply
wells. (Note that although historic data does not indicate any
health hazards with compounds other than volatile organics, the
presence of these compounds may help distinguish the contribution of
potential sources to the groundwater contamination found onsite.)
o A minimum of ten (10) key monitoring wells will be selected, based
on the results of the wells sampled above, to be sampled every two
months for the remainder of the RI to monitor seasonal variations in
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water quality. (This will amount to at least three (3) sampling
rounds of the key monitoring wells.) These key wells will be field
screened using the Photovac 10S50 for Volatile Organics. Water
level measurements will also be taken in these wells and each
piezometer for each sampling round.
o Other parameters which will be measured in the field at each sample
round will be water temperature, pH, and specific conductance.
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results, and an interpreta
tion of the data.
A map showing graphical representation of analytical results
and water level measurements.
Subtask 3H - Wetlands/Floodplain Evaluation
OBJECTIVE:
Conduct a floodplain/wetland assessment to comply with the substantive
requirements of the Floodplain Management Executive Order (E.O. 11988)
(Ref. No. 13, Attachment F) and the Protection of Wetlands Executive Order
(E.O. 11990) (Ref. No. 14, Attachment F).
APPROACH:
Prior to a site visit, all existing background information will be
collected to determine the additional data required to carry out a wetlands
and floodplain assessment. The National Wetlands Inventory Mapping for
this site will be obtained from the U.S. Fish and Wildlife Service (U.S.
FWS). Local town officials will be contacted to determine if local mapping
has been performed and to determine whether local ordinances relating to
wetlands exist. The U.S. Department of Interior (U.S. FWS), the Rhode
Island Natural Heritage Program, and local conservation commissioners will
be contacted to determine the presence of any rare or endangered species
5 27
including aquatic life associated with the wetlands onsite. The Soil
Conservation Service will be contacted for soil maps for the site area.
The EPIC aerial photographic report will also be utilized to discern
changes to and development of wetland areas and drainage patterns.
A site visit will be conducted to assess current conditions and perform
field verification of background information. Vetland boundaries will be
mapped on a U.S.G.S. 7-1/2 minute quadrangle map or a detailed site base
map. A list of dominant plant species, as well as a list of usual or
unusual species (including endangered or rare species) observed onsite will
be compiled. Soil types will be verified where necessary.
The wetland assessment will relate pertinent characteristics which help to
define the impact of contamination on wetland areas. Wetlands will be
referred to by type, according to the U.S. Fish and Wildlife Service
Classification scheme. An estimate of the size of the wetland areas will
be made. The wetlands will be related to the overall ecosystem of the
site. Soils in the wetlands will be characterized based on background data
for the site and analytical sample results. The hydrology of the site will
be described i.e. seasonal fluctuations in the water table or surface water
elevations, the history of flood events and hydraulic connections between
wetlands, surface water and groundwater. The water quality of all these
onsite waters will also be discussed.
Functional values of the wetland include water quality (including the
impact of contamination determined by either analytical sampling data or
visual observation), fauna and flora, flood storage capacity (recharge,
discharge and low flow modulation) and any aesthetic recreational or
educational values of the wetlands (as well as the uniqueness of the type
of wetland in its geographic area.)
The floodplain will be delineated using Flood Insurance Rate Maps
(developed under FEMA - The Federal Emergency Management Act) or Flood
Hazard Boundary Maps if available, or estimated using aerial photography.
Mapping includes floodplain boundaries and elevations and indicates the
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level of the 100 year floodplain. Also, the characteristics of flooding to
the extent that it occurs onsite will be discussed.
According to Appendix A of 40 CFR Part 6 entitled "Statement of Procedures
on Floodplain Management and Wetland Protection," (Ref. No. 15, Attachment
F), this assessment must evaluate the impacts of any proposed alternative
on floodplains and/or wetlands. It includes a description of the proposed
alternative (including the no action alternative) and a discussion of its
effect including adverse impacts and a description of the measures to
minimize potential adverse impacts to these areas. The floodplain/vetland
assessment vill be incorporated into the FS as an appendix as veil as
referred to under the environmental impacts for the no action alternative
and all subsequent alternatives which are developed and evaluated.
Conformance of each alternative with Executive Order 11990 (Ref. No. 14,
Attachment F) to minimize the destruction loss or degradation of wetlands
and to preserve and enhance the natural and beneficial values of the
wetlands identified will be assessed. Also compliance with the December
24, 1980, Federal Register using the U.S. FUS Habitat Evaluation Procedure
(Ref. No. 16, Attachment F) will be evaluated.
If the proposed action will alter floodplains or wetland resources, public
notification will be performed in accordance with EPA policy on CERCLA
actions, including an initial Fact Sheet to satisfy the early public notice
requirement, a Statement of Findings and an updated Fact Sheet summarizing
EPA's Record of Decision.
The Rhode Island Department of Environmental Management Fresh Water
Wetlands Section will be notified if any proposed action will alter a
floodplain or wetlands. The "Rules and Regulations Governing the
Enforcement of the Fresh Water Wetlands Act" will be complied with to the
greatest extent possible.
DELIVERABLE: A memo report on Floodplain/Wetland Assessment
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Two maps-one outlining the floodplain of the Blackstone River
and one outlining the extent of wetlands identified within
the area of interest.
Subtask 31 - Peterson-Puritan Plant Visit
OBJECTIVE:
Document current waste handling practices; identify potential historic
handling problems in terms of potential existing soil source areas;
document the actions taken to remedy those problems; and determine the need
for further adjustments in plant operations.
APPROACH:
Peterson-Puritan has acknowledged that releases from their plant have
contributed to the Quinnville wellfield contamination and that past waste
handling practices were the cause of such releases. Therefore, the
documentation of current waste disposal practices is warranted to assure
protection from future releases.
A site inspection will be conducted by COM, EPA and RIDEM personnel. This
will include an in-plant tour and a site reconnaissance of the plant
property outside the buildings including the recovery well operation.
Prior to the site visit all information in the Versar and Malcolm Pirnie
reports as well as RIDEM (RCRA permit, NPDES permit) files on current and
past plant operations will be reviewed.
Pending the results of this visit, split water samples of the recovery well
and monitoring well data may be requested from Peterson-Puritan to aid in
the evaluation of the recovery well program.
Note that it may be necessary to visit other facilities in the area as well
if those facilities are identified as potential sources of contamination.
These visits are not covered in this Work Plan and would require a work
plan amendment(s) as a Phase III task(s).
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DELIVERABLE: A memo report documenting the findings of the visit.
Subtask 3J - Identification of Soil Source Areas at Peterson-Puritan
OBJECTIVE:
Determine the existence of soil source areas at the Peterson-Puritan plant.
APPROACH:
The Peterson-Puritan facility has been identified as a source of
contamination for the Quinnville wellfield and possibly the Lenox Street
veil and therefore the need exists to delineate soil source areas within
plant boundaries. Onsite waste disposal practices and highly contaminated
groundwater near the ground surface, i.e. well GZ-2 lend support to the
potential for soil source areas nearby. Field activities conducted by
Malcolm Pirnie included the installation of three in-plant borings.
Although sampling of soils in these boreholes revealed no VOC
contamination, strong odors were noted in two of the three borings
indicating organic contamination.
This part of the investigation of soil source areas entails to delineating
areas of contamination on the Peterson-Puritan property. This will consist
of soil augering outside the buildings in the vadose zone, followed by
in-hole gas sampling using two portable gas sampling field instruments, the
Foxboro Century OVA 128 and the HNu PI 101. These instruments will be used
in the total survey mode and will enable a three man crew to move quickly
over the Peterson-Puritan property to delineate the lateral extent of
volatile organic contamination in soils above the water table. Based on
the results of this effort, further investigation consists of collecting
soil samples for analysis using field analytical equipment (GC) and/or a
CLP laboratory (GC/MS). This will consist of collecting soil samples by
hand augering and mixing them with methanol to desorb contaminants. The
methanol is then injected into the field gas chromatography, HNu 301.
(Exact procedures will be given in the Project Operations Plan.) This
instrument has a heated oven and is equipped with a heated 10.2 eV
5-31
Photoionization detector. Samples will also be collected for CLP
laboratory analysis to verify the results of the field GC analyses and to
provide a measure of extractable organics and volatile organics not
measured with the HNu 301. This effort will quantitatively confirm the
presence of volatile organic compounds in the contaminated areas
delineated. Also, if deemed necessary, in-plant borings may be installed
For sampling of soils beneath the buildings.
Note that other potential soil source areas (outside of the Peterson-
Puritan facility) identified by any Phase I activities will be investigated
and sampled in Phase II.
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results and an
interpretation of the data.
A map showing a graphical representation of analytical
results.
PHASE II
As proposed, one or more of the subtasks discussed herein under the Phase
II program would be initiated only upon receiving written notification from
EPA to proceed on a task by task basis.
Subtask K - Biota Sampling
OBJECTIVE:
Determine the impact of groundwater contamination on the biota of the
Blackstone River.
APPROACH:
If contaminants are found, in surface waters and/or sediments, which are
likely to bioaccumulate in aquatic organisms, fish or turtle samples will
5-32
be collected and analyzed for these compounds. The appropriate sampling
plan will be determined at that time, in consultation with the U.S. Fish
and Wildlife Service, EPA, and the appropriate state agencies.
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results and an
interpretation of the data.
Subtask L - Pump Test(s) (Lenox Street and Quinnville Wellfield)
OBJECTIVE:
Define the origin(s) of water which would be drawn into the public supply
wells if they were operated again and relate this to what occurred in the
past, prior to their closing in 1979. Aquifer parameters in the vicinity
of the Lenox Street well would be determined. Also information on the
zones of influence, hydraulic conductivity and any interconnection between
the Quinnville Wellfield and the Lenox Street well would be obtained. The
concentrations of contaminants which would be drawn into these wells if
they were put into use again would be illustrated as well.
APPROACH:
An analysis of all historic pump test data, i.e. from the USGS or from the
towns of Lincoln or Cumberland, will be made. If needed, COM will design
new pump tests on the municipal supply wells describing the pumping
duration, discharge rate(s), observation well placement, surface water
measurements, instrumentation and sampling. Note that all supply wells
would be sampled before and after extended pumping of the wells. Analysis
of the samples would be for volatile organics (HSL).
DELIVERABLE: A summary report of an analysis of historic pump test data.
A memo report with water level measurements, drawdown curves
and a summary of results.
5^33
A map shoving water level contours during pumping.
Subtask M - Exfiltration Test
OBJECTIVE:
Determine the magnitude and extent of contamination emanating from the BVSD
line, it's relationship to the contamination of the public supply wells,
and the need for remediation of the BVSD line. The BVSD line is above the
water table throughout most of the site and previous testing of the water
and soil surrounding the sewer indicates that leakage from.the sewer is
possible.
APPROACH:
The most appropriate test to determine leakage is dye testing. Engineering
plans for the sewer line will be required and the line will be divided into
segments for testing between one or more manholes at a time. At each
designated location, the sewer will be plugged in the downstream manhole
using an inflatable sewer plug and compressed air tank. Dye will then be
introduced in an upstream manhole and the wastewater will be allowed to
surcharge the sewer line. Plugging and surcharging the sewer line produces
an increased water pressure (head) in the sewer pipe joints. This condition
is expected to occur during severe storm conditions when wastewater flows
are generally highest.
The nine existing shallow monitoring wells located along the sewer line
will be evaluated for their potential use and designated for sampling
during the dye test. Additional shallow monitoring wells may be required
beyond MH-25 (see Figure 6) if the sewer line is determined to be above the
water table to the southeast of this well. If the dye is detected in
samples in these monitoring well(s), then it can be concluded that the
sewer line is leaking in the vicinity of the monitoring well(s). If the
flow backs upon in the upstream manhole near to the surcharge height, the
wastewater may have to be diverted around the section being tested with
temporary hosing and a pump.
5-34
If leakage is assessed to be a problem then sampling of the sewer water and
sludge will be necessary. Sampling will be done in manholes along the
sewer line in the vicinity of the suspected leak as well as upgradient and
downgradient of the leak. Sample analyses will be for the full HSL list
(VOAs and Extractable Organics as well as Priority Pollutant Metals (Tasks
1 and 2 and Total Cyanide, Task 3).
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results and an
interpretation of the data.
A map showing graphical representation of analytical results.
Subtask N - Soil Sampling of Source Areas (not limited to Peterson-Puritan)
OBJECTIVE:
Characterize and quantify the contaminants present in source areas other
than the Peterson-Puritan plant identified during Phase I field activities.
Further delineation of the areal extent and depth of source areas on the
Peterson-Puritan property may also be accomplished in this phase however.
APPROACH:
This work will be performed according to the same procedures described
under Subtask 3J which entail soil gas sampling, analysis of samples with
field GC equipment and collection of CLP samples.
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results and an
interpretation of the data.
A map showing graphical representation of analytical results.
5-35
Subtask 0 - Additional Monitoring Well and Piezometer Installation
OBJECTIVE:
Fill data gaps from Phase I concerning water quality and groundwater flow
patterns with additional monitoring wells or piezometers.
APPROACH:
Installation of up to three additional three-level groundwater monitoring
well clusters as described under Subtask 3F.
DELIVERABLE: Complete Well Logs
Subtask P - Additional Groundvater Sampling
OBJECTIVE:
Fill data gaps from Phase I concerning water quality and groundwater flow
patterns or obtain data from Phase II well or piezometer installations
(Subtask N) with additional monitoring well sampling or water level
measurements in wells or piezometers.
APPROACH:
Sampling and analysis of up to fifteen (15) additional groundwater
monitoring wells for Volatile Organics (HSL) will be done. Also up to six
(6) additional groundwater samples will be analyzed for ABN Extractable
Organics (HSL), Inorganics (Task 1 and 2), and Total Cyanide (Task 3).
DELIVERABLE: A memo report containing a description of the field sampling
activities, tabulated analytical results and an
interpretation of the data.
A map showing graphical representation of analytical results
and water level measurements.
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5.5 TASK 4 - IDENTIFICATION OF PRELIMINARY REMEDIAL TECHNOLOGIES
OBJECTIVE:
Modify the initial list of preliminary remedial technologies developed
under Task 2 based upon information obtained in the ongoing field
investigation. These technologies will be defined in sufficient detail to
ensure that the ongoing site investigation is properly focused to derive a
data base adequate for the development and evaluation of alternatives
during the feasibility study.
APPROACH:
Either during or following the site investigations, COM in conjunction with
EPA and the State of Rhode Island, will assess the investigation results
and recommend preliminary remedial technologies likely to be applied to the
identified source(s) and contaminant plume(s). These technologies should be
a refinement of the options considered in the pre-investigation phase under
Task 2. They will provide the basis for developing detailed alternatives
and conducting the cost-effectiveness analysis during the Feasibility
Study. The factors used to screen technologies as well as the list of
alternatives which require development listed in Task 2 will be used here
as well.
DELIVERABLE: A letter report with suggested technologies for consideration
and identifying any additional data needs.
5.6 TASK 5 - BASELINE RISK ASSESSMENT
OBJECTIVE:
A Baseline Assessment will be conducted to establish the extent to which
contaminants present at the Peterson-Puritan site are released from the site
and may present a danger to the public health, welfare, or the environment.
5-37
APPROACH:
This baseline risk assessment evaluates conditions at the site in the absence
of any further remedial actions, i.e, it constitutes an assessment of the no
action remedial alternative. The assessment will be in accordance with
proposed guidelines for risk assessment developed by EPA (Federal Register,
Vol. 49, No. 227, November 23, 1984) (Ref. No. 17, Attachment F).
The EA consists of the following five steps:
o Selection of contaminants of concern (indicator chemicals);
o Identification of migration pathways;
o Estimation of concentrations of chemicals at exposure points;
o Comparison of projected concentrations to applicable or relevant and appropriate requirements; and if required
o Quantification of risk.
5.6.1 Selection of Indicator Chemicals
The first task in the indicator chemical selection process is a review of
environmental monitoring data. Sampling was performed in groundwater,
surface water and soil, and among other contaminants vinyl chloride,
tetrachloroethylene, trichloroethylene, 1,1,1-trichloroethane,
trans-l,2-dichloroethylene, 1,1-dichloroethane, 1,1-dichloroethylene,
trichlorofluromethane, dieldrin and some priority pollutant metals were
found. These and any additional chemicals detected at the site above local
background levels are considered. The two most important factors used in
selecting indicator chemicals are concentration and toxicity. Additional
factors that will be considered include physical and chemical parameters
related to environmental mobility and persistence.
The indicator chemicals selected for the no action alternative will be
reviewed later for applicability to the remedial alternatives. Because of
concerns over treatability, additional chemicals may need to be assessed in
these analyses.
5-38
If fewer than 10 chemicals are actually identifed at the site, the
selection procedure vill not be necessary, and all 'chemicals at the site
will be evaluated.
5.6.2 Identificaton of Exposure Pathways
In this step of the evaluation, activity patterns near the Peterson-Puritan
site will be qualitatively defined and combined with chemical release
source and transport media information to identify possible exposure
pathways.
An exposure pathway is defined by four elements: (1) a source and
mechanism of chemical release to the environment; (2) an environmental
transport medium (e.g., air, groundwater) for the released chemical; (3) a
point of potential contact of humans or biota with the contaminated medium
(the exposure point); and (4) an exposure route (e.g., drinking water
ingestion) at the exposure point.
Based on available site descriptions the identified potential sources of
contamination are the Peterson-Puritan facility, Dexter Quarry, J.M. Mills
landfill, the Blackstone River and Canal, and the Blackstone Valley Sewer
District sewer line. Contaminants from potential sources appear to have
migrated via surface water discharges and infiltration through the over
burden and into the groundwater. For example, the redistribution of river
water via discharge to the sand and gravel pit operations on the northeast
side of the river and perhaps the leaching fields at the Peterson-Puritan
plant. For each combination of source release and transport medium, the
location of the point at which the highest individual exposure takes place
will be identified. The number of people potentially exposed will also be
estimated. Both short-term and long-term exposures will be considered.
Available information indicates that the following points of exposure are
the most likely to be significant at this site: nearby residents using well
water; flora and fauna in the Blackstone River, Canal, and ponds;
recreational users of surface water i.e. dermal contact or ingestion of
fish; potential bikers or visitors to the historic park (linear park and tow
path) currently planned for the area between the river and canal.
5-39
5.6.3 Estimation of Exposure Point Concentrations
After potential exposure pathways have been determined, environmental
concentrations for each indicator chemical will be estimated at each of the
exposure point locations. Concentrations of substances will be estimated
as a function of time (i.e., short-term and long-term) in each
environmental medium—air, surface water, groundwater, or soil—through
which potential exposure could occur.
Estimating environmental concentrations at each exposure point involves the
quantification of the amounts of chemicals that will be released to the
environment over time by the various sources identified in the exposure
pathway analysis, prediction of the environmental transport and fate of
each indicator substance in the identified medium of the exposure pathway,
and derivation of time-dependent concentrations at the point of exposure.
Deriving these concentrations may involve the modeling of percolation in
soils, and groundwater or surface water flow. For each chemical and each
exposure pathway, the outcome of this exercise will be a short-term and
long-term environmental concentration at the significant exposure point.
When appropriate, both the realistic and worst-case exposure point
concentrations will be evaluated using the mean and maximum concentrations.
5.6.4 Comparison to Standards and Criteria
EPA's guidelines (Ref. No. 17, Attachment F) indicate that the projected
concentrations of indicator chemicals at exposure points should be compared
to all federal applicable or relevant and appropriate ambient standards and
criteria to judge the degree and extent of risk to public health and the
environment (including plants, animals, and ecosystems).
Presently, EPA considers the Safe Drinking Water Act Maximum Contaminant
Levels (MCLs) and Clean Air Act National Ambient Air Quality Standards to be
the only applicable or relevant and appropriate Federal ambient concentra
tion standards (Ref. No. 17, Attachment F). In addition, for the purposes
of the Superfund public health evaluation/endangerment assessment process,
EPA considers the Clean Water Act water quality criteria and adjusted water
5-40
quality criteria appropriate for comparison to predicted concentrations if
they are for the same exposure route (Ref. No. 17, Attachment F). Other
guidelines that may be used to provide an indication of relative health
risks include U.S. EPA's Office of Drinking Water health advisories,
agency-vide reference doses, proposed and recommended MCLs health effects
assessment documents and State water quality standards.
At this stage of the assessment, any potential impacts of the site on
public welfare and natural resources will be identified. The welfare
impacts may include effects on public water supply, property values, or the
potential for future commercial or residential development. To evaluate
the potential environmental impacts on biota and the surface waters and
wetlands, surface water concentrations will be compared to the EPA ambient
water quality criteria when they are available. When appropriate criteria
are not available concentrations of the indicator compounds, will be
compared to available aquatic toxicity data.
5.6.5 Quantitative Risk Estimation
A quantitative risk estimate will be performed for all indicator chemicals
if any one of them lack applicable or relevant and appropriate public
health standards or criteria for the media of exposure.
To assess the potential adverse health effects associated with the site,
the amount of human or biota exposure to the selected contaminants must be
determined. Intakes of exposed populations will be calculated separately
for all reasonable pathways of exposure to chemical contaminants in each
environmental medium—air, groundwater, surface water, and soil as well as
through the food chain i.e. consumption of fish. When appropriate
assumptions will be varied to permit evaluation of both realistic and
worst-case exposure scenarios. Then, for each population-at-risk, the
total intake by each route of exposure will be calculated by adding the
intakes from each pathway. Total oral and inhalation exposures and (if
determined to be important) dermal exposure will be estimated separately.
Because short-term (subchronic) exposures to relatively high concentrations
of chemical contaminants may cause different toxic effects than those
5-41
caused by long-term (chronic) exposures to lower concentrations, two intake
levels will be calculated for each route of exposure to each chemical,
i.e., a subchronic daily intake (SDI) and a chronic daily intake (CDI).
Critical toxicity values (i.e., numerical values derived from
dose-response information for individual compounds) will be used in
conjunction with the intake determinations to characterize risk. Where
health effects assessments (HEAs) have been developed by EPA's Office of
Research and Development, these will be used as a source of critical
toxicity values. This requires interpretation of the applicability of
toxicity data to the specific exposure conditions expected to occur at the
site. Three different types of critical toxicity values may be used:
o The acceptable daily intake for subchronic exposure (AIS),
o The acceptable intake for chronic exposure (AIC), and
o The carcinogenic potency factor (for carcinogens only).
Noncarcinogenic Risks
The AIS and AIC values and other daily intake levels represent levels of
exposure below which adverse health effects are unlikely to occur. They
will be derived by applying safety factors to no-observed-effect levels
from animal studies and/or epidemiological studies.
To assess noncarcinogenic risks the SDI will be compared to the AIS and the
CDI will be compared to the AIC. Where the SDI exceeds the AIS or the CDI
exceeds the AIC, an unacceptable public health and risk will be assumed to
exist. Where there are exposures to more than one indicator chemical, a
hazard index developed by EPA will be used. This index sums the ratios of
the SDI to the AIS or the ratios of the CDI to the AIC over all the
indicator chemicals present. This assumes that the risks due to exposure
to multiple chemicals are additive. This assumption is probably valid for
compounds which have the same target organ or cause the same effect. If
the hazard index results in a value greater than unity, the compounds in
the mixture will be separated by critical effect and separate hazard
indices derived for each effect.
5-42
If any indicator chemicals with teratogenic effects are being assessed, a
separate subchronic hazard index will be calculated for them using the AIS
for teratogenic effects.
Throughout this entire risk assessment process, intakes and risks from oral
and inhalation exposure pathways will be estimated separately. However,
the possible effects of multimedia exposure will be evaluated by summing
the hazard indices for inhalation and oral exposures. This will assure
that acceptable levels are not being exceeded by combined intakes when
multiple exposure pathways exist.
Potential Carcinogens
For potential carcinogens (such as vinyl chloride) the carcinogenic potency
factor, defined as the slope of a calculated dose-response curve, will be
used to estimate cancer risks at low dose levels. This factor is estimated
from the upper 95% confidence limit of the slope of the dose-response curve
derived from a linearized extrapolation model. Risk is directly related to
intake at low levels of exposure. Expressed as an equation, the model for
a particular exposure route is:
Risk = CDI x Carcinogenic Potency Factor
_2 This equation is valid only for risks below 10 because of the assumption
of low-dose linearity. For sites where this model estimates carcinogenic _2
risks of 10 or higher, an alternative model may be considered. It is also
assumed that cancer risks from various exposure routes are additive, unless
information is available that suggests antagonism or synergism. Thus, the
result of the assessment will be an upper 95 percent confidence level of the
total carcinogenic risk for each significant exposure point.
DELIVERABLE: A Letter Report on Selection of Indicator Compounds.
A Baseline Risk Assessment Report.
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5.7 TASK 6 - PREPARATION OF REMEDIAL INVESTIGATION REPORT
OBJECTIVE:
Incorporate into a report for submittal to EPA all data and analyses of
data including earlier deliverables and comments, i.e. Tasks 2 through 5,
with a summary and all relevant conclusions.
APPROACH:
The work conducted under Task 3 will be described and the raw data will be
summarized. (Note that all raw data will be included in the appendices of
the report.) The report includes the preliminary list of technologies
addressed in Task 2 and the baseline endangerment assessment developed
under Tasks 4 and 5. This draft report also includes a listing of all
recognized sources of contamination together with the contamination which
has migrated way from these sources (management of migration problems).
Remediation of the site will be targeted for source control and management
of migration problems as identified in the RI. Upon compilation of agency
and public comments, a final RI report will be developed and submitted.
DELIVERABLES: A Draft RI report.
A Final RI report.
5.8 TASK 7 - REMEDIAL INVESTIGATION SUPPORT
OBJECTIVE:
Provide all necessary support for the Peterson-Puritan Remedial Investigation.
APPROACH:
Task 7 is divided into the following subtasks:
Subtask 7A - RI Management and Coordination
Subtask 7B - RI Community Relations
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Subtask 7C - RI Quality Control
Subtask 7D - RI Quality Assurance
SubtasK 7A - RI Management and Coordination
OBJECTIVE:
The objective of this subtask is provide for the necessary staffing,
subcontractors, equipment, and communication in support of the Remedial
Investigation.
APPROACH:
5.8.1 Staffing Plan
The following RI staffing plan is proposed for implementation at the
Peterson-Puritan Site.
David Newton - EPA Regional Site Project Officer
William Swanson - REM II (COM) Regional Manager
Theresa Murphy - REM II (C.C. Johnson & Associates) Site Manager
Judith Vreeland - REM II (Clement Assoc.) EA Engineer
Wendy Rundle - REM II (ICF) Community Relations Specialist
5.8.2 Subcontractor Procurement Plan
The following subcontractors will be utilized at the Peterson-Puritan Site.
o Goldberg Zoino, Inc. (sole source) - Review of existing monitoring
well locations.
o Seismic Subcontractor - Subcontractor to use seismic refraction with
explosives to locate bedrock (proposed Phase II if required).
o Drilling Subcontractor - Subcontractor to drill and develop
groundwater monitoring wells (including tamper proof casings).
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o Surveying Subcontractor - Subcontractor will provide exact location
measurements for existing and new groundwater monitoring wells
previously located in the field by COM personnel. Both horizontal
and vertical ties will be obtained for each of the wells.
o Pump Test Subcontractor - Subcontractor will supply equipment
necessary to complete a 10 day sustained pumping test at each of the
two wellfields of concern (i.e. Quinnville and Lenox Street wells).
5.8.3 Special Equipment Needed
There will be no special equipment used on the Peterson-Puritan Site other
than the equipment supplied by each of the subcontractors described in
Section 5.8.2.
5.8.4 RI Administration, Coordination and Management
To maintain effective communication with EPA, and the State, PRPs and the
public on the progress of the RI, COM will perform the following:
1. Prepare monthly progress reports to EPA;
2. Attend monthly progress meetings with EPA;
3. At the request of EPA:
- be available for discussion of any phase of site work;
- attend meetings between PRPs, EPA, State and/or the public;
assist in the planning, coordination and support for public meetings and hearings; and
assist in preparing public meeting summaries, fact sheets and a responsiveness summary.
COM will comply with the reporting requirement stated in this scope of work
and in the REM contract. In addition, provide milestone updates in terms
of report submittals and budget expenditures.
DELIVERABLE: Monthly progress reports.
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Subtask 7B - RI Community Relations Implementation Activities
OBJECTIVE:
The objective of community relations planning support at the Peterson-
Puritan site is to develop a site-specific community relations plan (CRP).
The objective of community relations implementation support at the
Peterson-Puritan site is to inform interested and affected individuals
about the progress of site activities during the RI and to provide an
opportunity for public participation in decisions about Superfund actions
at the site. REM II community relations staff will take the lead in
implementing the site-specific community relations plan for the
Peterson-Puritan site.
APPROACH:
REM II community relations staff will develop a site-specific CRP in
accordance with U.S. EPA policy and guidance. The CRP will be based on
discussions with Federal, State, and local officials as well as citizens
identified by EPA. Tasks in developing this CRP will include:
o Reviewing existing site information;
o Conducting on-site interviews to identify community concerns;
o Coordinating activities closely with the appropriate State
personnel; and
o Conducting REM II administrative tasks necessary for preparing the
community relations plan for this site.
Development of the CRP will be coordinated with the Region I Superfund
Community Relations Coordinator.
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Community relations implementation assistance during the RI at the
Peterson-Puritan site will be provided as specifically requested by EPA and
within approved budget levels. These activities may include, but are not
limited to, the following:
o Providing planning, coordination, and logistical support for the
public meetings on the work plan and on the RI; this includes the
preparation of slides, providing a list of "tough" questions that
might be asked at the meetings, and participating in the practice
runs of the meeting;
o Attending the work plan and RI public meetings;
o Preparing meeting summaries of the work plan and RI public
meetings;
o Preparing two fact sheets - one describing the work plan and the
Superfund process, and one summarizing the RI;
o Preparing and updating the site mailing list; and
o Conducting REM II administrative and managerial tasks necessary for
providing community relations assistance at the site (e.g. meeting
with REM II technical staff, attending EPA meetings, and preparing
monthly reports and budget updates for EPA).
The tasks identified above have been proposed based on conversations with
EPA staff. All work on these tasks will be initiated by the EPA Region I
Superfund Community Relations Coordinator and coordinated with the EPA
Regional Project Officer, the EPA Project Manager, the REM II Site Manager,
and the REM II Community Relations Manager.
REM II technical staff may support the community relations planning and
implementation efforts. This technical staff support may include providing
comment on and reviewing fact sheets, attending public meetings, and
preparing and developing presentations at public meetings. Technical staff
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support as required during the RI community relations program is included
in Subtask 7A.
DELIVERABLES: A draft community relations plan will be provided within six
weeks after on-site discussions are conducted.
A final community relations plan will be provided within
three weeks after EPA comments are received on the draft.
A draft and final fact sheet describing the work plan will
be provided prior to the public meeting on the work plan.
A draft and final fact sheet summarizing the RI will be
provided prior to the RI public meeting.
Draft summaries of the work plan and RI public meetings will
be provided two weeks after each respective meeting.
Final summaries of the work plan and RI public meetings will
be provided as soon as possible after EPA comments on the
draft are received.
Subtasks 7C and 7D - RI Quality Control/Quality Assurance
OBJECTIVE:
Review the sampling activities and the analytical data, as well as all
project deliverables, produced from the field investigation to ensure the
quality of the information obtained and to monitor conformance with EPA
established QC protocols.
APPROACH:
Quality control/quality assurance procedures address both sampling
activities and the analytical data which is produced. A set of field
blanks, trip blanks, and duplicates will be taken to check sampling
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procedures, sampling chain-of-custody, and analytical data for specific
quality control objectives. These objectives address precision, accuracy,
completeness, representativeness, correctness, and comparability.
Also, field performance and system audits will be conducted with the results
reported to management and documented in site files. Performance audits
entail checking the sampling protocol including sample collection
activities, equipment calibration, preventative maintenance, and all QA/QC
procedures to see if they are being conducted as they should. System audits
will be conducted to determine if a QA/QC plan has been implemented and the
results documented in a QA/QC file as well as reports to management.
5.9 TASK 8 - DEVELOPMENT OF ALTERNATIVES
OBJECTIVE:
Develop a limited number of alternatives using the remedial technologies
identified in Tasks 2 and 4, as well as response objectives and criteria.
5.9.1 Establishment of Remedial Response Objectives and Criteria
COM will establish site-specific objectives and criteria for the
development and evaluation of alternatives. These objectives shall be
based on public health and environmental concerns, information gathered
during the remedial investigation, Section 300.68 of the National
Contingency (NCP), EPA guidance, 40 CFR 264 (RCRA) and the requirements of
any other applicable federal, state or local statutes (Ref. No. 18,
Attachment F). Preliminary cleanup objectives shall be developed in
consultation with EPA and the State of Rhode Island. COM will conduct a
briefing for EPA and the State of Rhode Island in order to present
preliminary response objectives and cleanup criteria for each medium
requiring remedial action and to obtain input and concurrence.
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5.9.2 Identification Of Remedial Alternatives
Given the response objectives and criteria listed above, the remedial
technologies are expanded into remedial alternatives. These alternatives
can address source-control actions or management of migration actions.
Source control actions focus on eliminating or mitigating the contaminant
source, thereby preventing or minimizing migration of contaminants to
off-site areas. This is frequently achieved via removal or containment of
the source. Management of migration actions address hazardous substances
that have largely migrated from their original locations. Alternatives may
fall solely in either classification or may involve a combination of source
control and management of migration measures.
EPA Guidance states that at least one alternative for each of the following
must be developed and screened:
o No Action,
o Off-site treatment or disposal,
o An alternative which does not meet full compliance with applicable
and/or relevant federal and public health or environmental standards
but will reduce the present and future threat from hazardous
substances,
o An alternative that complies with all applicable and/or relevant
federal public health or environmental standards, and
o An alternative that exceeds the requirements of all applicable and/or
relevant federal public health or environmental standards.
DELIVERABLES: A memorandum report outlining a set of remedial alternatives
that incorporates the results of Task 8, response objectives
and other appropriate considerations.
5.10 TASK 9 - INITIAL SCREENING OF ALTERNATIVES
OBJECTIVE:
Eliminate alternatives that are clearly not feasible or appropriate prior
to undertaking detailed evaluation of the remaining alternatives.
APPROACH:
The alternatives will be screened based on environmental and public health
criteria, followed by an order of magnitude cost screening. Note that when
all of the alternatives from one of the five required categories are
eliminated, one alternative from that category must be included in the
summary of alternatives given on the Feasibility Study with an explanation
of why it was eliminated.
5.10.1 Environmental and Public Health Screening
Alternatives that may have significant adverse impacts or do not adequately
protect the environment and public health will be eliminated. Adequate
protection will be thought of as a comprehensive response that addresses
all pathways and points of exposure.
5.10.2 Cost Screening
Alternatives that have costs an order of magnitude greater than those of
other alternatives but do not provide greater environmental or public
health benefits or greater reliability should be eliminated.
The level of effort in developing costs for this phase of the Feasibility
Study will be defined by the guidelines listed below.
o Data sources should be limited to the "Remedial Action Cost
Compendium" Handbook (Ref. No. 19, Attachment F): Remedial Action
at Waste Disposal Sites (Ref. No. 20, Attachment F), the Remedial
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Investigation (for revising design assumptions where necessary),
standard cost indices, and other readily available information.
o The time for preparing screening cost estimates should be limited to
a few days.
o The objective in calculating the costs is to achieve an accuracy
within -50 to +100 percent.
DELIVERABLE: A letter report summarizing the screening process and results.
5.11 TASK 10 - DETAILED EVALUATON OF REMAINING ALTERNATIVES
OBJECTIVE:
Evaluate the viable alternatives remaining after Task 9 to provide EPA with
information with which to distinguish the advantages and disadvantages of
each alternative in both absolute terms and relative to one another.
APPROACH:
5.11.1 Detailed Development of Alternatives
The alternatives evaluation shall be preceded by a detailed development of
the alternatives remaining from Task 9. The detailed development of
remaining alternatives shall consider the factors found in 300.68 (f)
through (j) of the NCP and as a minimum shall include the following:
a. A description of appropriate treatment and disposal technologies
including the intent of the remedial alternative i.e. source
control or management of migration,
b. Special engineering considerations required to implement the
alternatives (e.g., pilot treatment facility, additional studies
needed to proceed with final remedial design),
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c. Environmental impacts i.e. the affect of the remedy on the
different uses of the Blackstone River, Blackstone Canal, wetlands
and other bodies of water within the site boundary as well as any
proposed methods and costs for mitigating any adverse effects,
d. Operation, maintenance, and monitoring requirements of the remedy,
e. Off-site disposal needs and transportation plans,
f. Temporary storage requirements,
g. Safety requirements for remedial implementation (including both
on-site and off-site health and safety considerations),
h. A description of how the alternatives could be phased into operable
units. The description includes a discussion of how various
operable units of the total remedy could be implemented indivi
dually or in groups, resulting in a significant improvement in the
quality of the environment or savings in cost,
i. A description of how the alternative could be segmented into areas
to allow implementation of different phases of the alternatives,
j. A review of any off-site facilities provided by the State to ensure
compliance with applicable RCRA requirements, both current and
proposed; the current EPA policy on off-site disposal must be
followed,
k. An assessment of local residents' perception of the impact of the
alternative, and
1. Aspects of the site problem that the alternative will or will not
control.
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5.11.2 Noncost Criteria Analysis
5.11.2.1 Technical Analysis
The applicable remedial alternatives will be evaluated for technical
feasibility. The major elements of technical feasibility are performance,
reliability, implementability and safety considerations.
Performance. The performance of a remedial alternative is based on its
effectiveness and usefull life. Effectiveness refers to the degree to
which an action prevents or minimizes substantial danger to public health,
welfare, or the environnment. This is usually accomplished via certain
functions i.e. containment, diversion, removal, destruction, or treatment.
The effectiveness of an alternative should be determined either through
design specifications or by performance evaluation. The useful life of an
alternative is the length of time this level of effectiveness can be
maintained. Each alternative should be evaluated in terms of the
projected service lives of its component technologies.
Reliability. Two aspects of remedial alternatives that provide information
about reliability are their operation and maintenance requirements and
their demonstrated reliability at similar sites. Operation and maintenance
(O&M) requirements should be assessed by the availability and cost of
necessary labor and materials, and the frequency and complexity of O&M
activities. The demonstrated performance of an alternative should include
an estimate of the probability of failure in qualitative or quantitative
terms for each component technology and for the complete alternative.
Although preference will be given to technologies previously demonstrated
under similar site and waste conditions, innovative or developmental
technologies should be evaluated as an alternative. Their evaluation will
be based on bench scale tests completed during the RI and researchers'
laboratory and field tests.
COM will conduct an analysis of whether recycle/reuse, waste minimization,
waste biodegradation, or destruction or other advanced, innovative, or
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alternative technologies are appropriate to reliably minimize present or
future threats to public health or welfare or the environment.
Implementability. A remedial alternative can be evaluated for its implemen
tability by its relative ease of installation or constructability and the
time required to achieve a given level of response. Constructability is
linked to on-site conditions affecting the actual construction of the
remedial technologies and offsite conditions such as the availability of
offsite disposal sites, equipment needed for construction, as well as public
sentiment and the ability to obtain the necessary permits. The time
required to achieve a given level of response consists of the time it takes
to implement an alternative and the time it takes to see beneficial results
(which is often delayed beyond the construction period). Beneficial results
should be defined as the reduction in levels of contamination necessary to
attain or exceed relevant or applicable standards. Emphasis will be on
quickly eliminating exposure to hazardous substances.
Safety. Safety is defined as the security and freedom from risk, loss,
injury, harm and danger. Each remedial action alternative will be evaluated
with regard to safety. Factors to be considered in this evaluation will
include short and long-term threats to the safety of the remedial workers,
the community living and working in the site vicinity and the environment
and facilities during implementation of the remedial measures.
5.11.2.2 Institutional/Legal Policy Analysis
The remaining feasible remedial alternatives shall be evaluated on the
basis of institutional concerns or factors that may impact implementation.
Compliance with all applicable or relevant and appropriate federal
requirements will be evaluated as well as other Federal criteria,
advisories, and guidance and State standards.
Note that there are three categories of required remedial alternatives
based on compliance with applicable or relevant and appropriate federal,
requirements: those that do not attain these requirements, those that
attain these requirements, and those that exceed these requirements.
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Applicable requirements are those which would be legally applicable to the
response or remedial action if that action was not undertaken pursuant to
CERCLA. Relevant and appropriate requirement standards are those designed
to apply to designed to apply to circumstances sufficiently similar to
those encountered at CERCLA sites in which their application would be
appropriate at a specific site although not legally required.
Onsite activities will be evaluated based on the applicable or relevant and
appropriate requirements with the understanding however that EPA does not
require permits for fund-financed or enforcement actions taken onsite.
Circumstances that make the alternatives which do not attain these
requirements acceptable are the following:
1. The selected alternative is not the final remedy and will become
part of a more comprehensive remedy;
2. All of the alternatives which meet applicable or relevant and
appropriate requirements fall into one or more of the following
categories:
(i) Fund-balancing - for Fund-financed actions only; exercise
the Fund-balancing provisions of CERCLA section 104(c)(4);
(ii) Technical impracticability - it is technically
impracticable from an engineering perspective to achieve
the standard at the specific site in question;
(iii) Unacceptable environmental impacts - All alternatives that
attain or exceed requirements would cause unacceptable
damage to the environment; or,
3. Where the remedy is to be carried out pursuant to CERCLA section
106; the Hazardous Response Trust Fund is unavailable, or would not
be used; there is a strong public interest in expedited cleanup;
and the litigation probably would not result in the desired remedy.
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The basis for not meeting the requirements must be fully documented.
Offsite activities will be evaluated based on the applicable or relevant
and appropriate requirements with the understanding that compliance with
environmental laws and permit requirements is required (as opposed to
onsite activities which are exempt from permits, etc... under CERCLA).
Note that offsite actions include underground injection, point source
discharges to U.S. waters, and air emissions. Hazardous wastes that are
moved offsite must be taken to a facility that is in compliance with
applicable standards as defined in EPA's offsite policy.
For each alternative, all the applicable or relevant and appropriate
requirements will be discussed and the degree of compliance of onsite
activities or the resulting permit requirements for offsite activities will
be stated. In general, it is expected that regulatory programs undre the
Resource Conservation and Recovery Act (RCRA), the Safe Drinking Water Act
(SDWA) and the Federal Water Pollution Control Act (Clean Water Act or CWA)
will have the broadest application to remedial alternatives. All guidance
or advisories such as the Groundwater Protection Strategy which will help
to evaluate an alternative will be mentioned. There are also many agencies
which can provide valuable assistance in the implementation of an
alternative. All agencies with which consultations will be needed will
thus be listed. A partial list may include the:
National Park Service,
Federal Emergency Management Agency,
Department of Health and Human Services,
U.S. Army Corps of Engineers,
U.S. Geological Survey,
Occupational Safety and Health Administration, and the
U.S. Fish and Wildlife Service
Finally assurance must be given that the community relations program is in
compliance with the National Environmental Policy Act (NEPA) by allowing
both the opportunity and time for the public to review the draft feasibili
ty study and that the necessary and appropriate investigation and analysis
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of environmental factors is considered. (Generally actions taken pursuant
to sections 104 and 106 of CERCLA are exempt from NEPA requirements.)
Of special concern for this site are the recent efforts by the Massachusetts
Department of Environmental Management and the Rhode Island Department of
Environmental Management to establish a linear park along the Blackstone
River. This park will consist of a tow path and possibly a bicycle path
which will each be located between the Blackstone River and canal. A total
of 19 miles are planned extending from Pawtucket to North Smithfield.
So far, plans to purchase two parcels of land totaling 31 acres in Lincoln
immediately upgradient of the Peterson-Puritan site have been announced.
However, a three mile stretch of land south of the planned land acquisition
was.donated for the park several years ago. This land may include the
Peterson-Puritan site. This will be investigated further in the RI/FS.
In 1983 the U.S. Congress asked the National Park Service to assess the
national significance of the entire river valley corridor. They have since
developed three conservation options emphasizing the educational, historic
and recreational values of the valley.
Therefore coordination with the Rhode Island and Massachusetts Department of
Environmental Management and the National Park Service will be important.
Local preservation societies, i.e. the Blackstone Valley Historical Society
will also be contacted. Also federal laws governing historic parks may be
applicable or relevant and appropriate requirements for this site.
5.11.2.3 Detailed Public Health Assessment
COM will evaluate each alternative to determine the alternative's public
health effects. Each alternative will be addressed in terms of the extent
to which it will mitigate damage to public health in comparison to the
other remedial alternatives.
The public health analysis consists of a baseline site assessment, an
exposure assessment, and a comparison of environmental concentrations to
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relevant and applicable standards. First, a baseline site evaluation is
conducted where all data on the extent of contamination, contaminant
mobility and migration, and types of alternatives are reviewed. The result
of the baseline evaluation is the determination of data required to conduct
an exposure assessment and the level of detail in this assessment.
Second, an exposure assessment will be conducted. A qualitative exposure
assessment is required for source control actions to evaluate the types,
amounts, and concentrations of chemicals at the site, their toxic effects,
the proximity of target populations, the likelihood of chemical release and
migration from the site, and the potential for exposure. A quantitative
exposure assessment is conducted for management of migration actions to
estimate the frequency, magnitude, and duration of human exposure to toxic
chemical contaminants released from a site.
Following the exposure assessment, estimated environmental concentrations
of the indicator chemicals selected for the site (if there are a large
number of chemicals present) are compared to applicable or relevant
environmental standards such as those found in RCRA regulations, National
Interim Primary Drinking Water Standards, Maximum Contaminant Levels,
National Ambient Air Quality Standards, etc. as well as EPA criteria for
noncarcinogens, carcinogens, and health advisories. When no applicable
standards exist, at least one alternative should be aimed at a 10" risk -A -7 level, and other alternatives in the 10 -10 risk level.
5.11.2.4 Environmental Assessment
An environmental assessment of each alternative will be conducted in terms of
the extent to which it will mitigate damage to the environment. It addresses
the value of contaminated or threatened areas; identifies the types of impacts
that are likely; and assesses the general significance of the impacts. All
alternatives including the no-action alternative will be evaluated, except
those determined during the screening to not result in any of the following:
o A substantial increase in airborne emissions,
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o A new discharge to surface or groundwaters,
o An increase in the volume of loading of a pollutant from existing
sources or a new facility to receiving waters,
o Known or expected significant adverse effects on the environment or
on human use of environmental resources, or
o Known or expected direct or indirect adverse effects on environment
ally sensitive resources or areas, such as wetlands, prime and
unique agriculatural lands, aquifer recharge zones, archeological
and historical sites, and endangered and threatened species.
In such cases, the reasoning for not doing so must be stated. The level of
detail is dependent on the degree of actual or potential damage to the
environment. The evaluation should discuss both adverse and beneficial
results associated with the remedial alternative. Beneficial effects
include improvements in final environmental conditions, improvements in the
environmental, and improvements in human use resource. Adverse effects can
result from construction/operation activities and mitigative measures.
5.11.3 Cost Analysis
The cost of each feasible remedial action alternative remaining after
initial screening will be evaluated and will include each phase or segment
of the alternative and consider cost and non-cost (i.e., loss of natural
resources) criteria. The cost of each alternative will be presented as a
present worth cost and includes the total cost of implementing the
alternative and the annual operating and maintenance costs. A distribution
of costs over time will also be provided. A table showing the above cost
information for each alternative should be included.
In developing detailed cost estimates, COM will perform the following
steps:
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Estimation of Costs. Determine capital and annual operating costs for
remedial alternatives.
Cost Analysis. Using estimated costs, calculate the stream of payments and
present worth for each remedial alternative.
Sensitivity Analysis. Evaluate risks and uncertainties in cost estimates;
cost estimates should be within +50 and -30 percent of the actual cost.
Input to Cost-Effective Analysis. Identify input data and reliability
necessary to evaluate cost effectiveness of remedial action strategies.
5.11.4 Summary Analysis and Recommendations of Cost-Effective Alternative
The purpose of this subtask will be to summarize in a comparative format the
results of the detailed evaluation of alternatives (based on technical, ins
titutional, public health, environmental and cost criteria). Based upon this
summary COM may recommend for EPA's consideration the most cost-effective
alternative which at a minimum comply with all applicable or relevant and
appropriate requirements (which in effect means it mitigates and minimizes
threats to and provides adequate protection of the public health, welfare and
the environment). In selecting the appropriate alternative however, EPA will
consider all cost, technological, and administrative limitations in achieving
different levels of protection of the public health and environment.
DELIVERABLES: A summary table consisting of each alternative and the
evaluation criteria. A narrative description of the
advantages and disadvantages of each alternative considered
shall be prepared.
A briefing for EPA and the State of Rhode Island to present
the results of the detailed evaluation of alternatives.
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5.12 TASK 11 - PREPARATION OF DRAFT FEASIBILITY STUDY REPORT
OBJECTIVE:
The objective of this task is to prepare a draft feasibility study report
for EPA and public review.
APPROACH:
This report describes the feasibility study and present the results of
Tasks 8-11. The report includes a detailed executive summary which can be
used to present the results of the RI/FS to the public.
Upon review of the draft report by EPA and the State of Rhode Island, a public
meeting will be held during which COM will describe the results of the RI/FS
and present the recommended cost-effective alternative. A second public
meeting will be held approximately two to three weeks later to respond to
public questions and solicit comments on the recommended alternative.
DELIVERABLES: A Draft FS report.
A Presentation to the public.
5.13 TASK 12 - FINAL FEASIBILITY STUDY REPORT
OBJECTIVE:
The objective of this task is to prepare a final feasibility study report.
APPROACH:
Incorporate comments received from the EPA, the State, and public, as
compiled by EPA, and make the necessary revisions on the Draft Feasibility
Study Report which includes a responsiveness summary.
DELIVERABLE: A Final Feasibility Study Report.
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5.14 TASK 13 - CONCEPTUAL DESIGN OF SELECTED REMEDIAL ALTERNATIVE
OBJECTIVE:
CDM will prepare a conceptual design of the remedial alternative selected
by EPA.
APPROACH:
The conceptual design includes, but is not limited to the following: the
engineering approach including implementation schedule, special
implementation requirements, institutional requirements, phasing and
segmenting considerations, preliminary design criteria, preliminary site
and facility layouts, budget cost estimate (including operation and
maintenance costs), operating and maintenance requirements and duration,
and an outline of the safety plan including cost impact on implementation.
Any additional information required as part of the basis for the completion
of the final remedial design will also be included.
DELIVERABLE: A conceptual design report.
5.15 TASK 14 - FEASIBILITY STUDY SUPPORT
OBJECTIVE:
Provide all necessary support for the Peterson-Puritan feasibility study.
APPROACH:
Task 14 is divided into the following subtasks:
Subtask 14A FS Management and Coordination
Subtask 14B FS Community Relations
Subtask 14C FS Quality Assurance/Quality Control
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Subtask 14A - FS Management and Coordination
OBJECTIVE:
Provide for the necessary staffing, and communication in support of the FS.
APPROACH:
5.15.1 Staffing Plan
t The following staffing plan is proposed for implementation during the FS at
the Peterson-Puritan site.
David Newton - EPA Regional Site Project Officer
William Swanson - REM II (COM) Regional Manager
Theresa Murphy - REM II (C.C. Johnson & Associates) Site Manager
Judith Vreeland - REM II (Clement Assoc.) EA Engineer
Wendy Rundle - REM II (ICF) Community Relations Specialist
5.15.2 FS Administration, Coordination and Management
In order to maintain effective communication with EPA, the State, PRPs and
the public on the progress of the project, COM will perform the following
during the FS:
1. Prepare monthly progress reports to EPA;
2. Attend monthly progress meetings with EPA and State;
3. At the request of EPA:
attend meetings between PRPs, EPA, State and/or the public;
- assist in the planning, coordination and support for public
meetings and hearings; and
- assist in preparing public meeting summaries, fact sheets and a
responsiveness summary.
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COM will comply with the reporting requirements stated in this scope of work
and in the REM contract. In addition, he/she will provide milestone updates
in terms of report submittals and budget expenditures.
DELIVERABLE: Monthly progress reports.
Subtask 14B - FS Community Relations Implementation Activities
OBJECTIVE:
The objective of community relations implementation support at the Peterson-
Puritan site is to inform interested and affected individuals about the
progress of site activities during the FS and to provide an opportunity for
public participation in decisions about Superfund actions at the site.
APPROACH:
REM II community relations staff will assist in the implementation of a
site-specific community relations plan. Community relations implementation
assistance during the FS will be provided as specifically requested by EPA
and within approved budget levels. These activities may include, but are not
limited to, the following:
o Providing planning, coordination and logistical support for the FS
public meeting; this includes the preparation of slides, providing
a list of "tough" questions that might be asked at the meeting, and
participating in the practice run of the meeting;
o Attending the FS public meeting;
o Preparing a meeting summary of the FS public meeting;
o Preparing two fact sheets - one summarizing the FS, and one
describing EPA's selected remedial alternative as announced in the
Record of Decisions;
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o Updating the site mailing list;
o Compiling and summarizing comments and responses as part of
preparing a responsiveness summary;
o Revising the community relations plan to address new and changing
community concerns regarding the remedial design and remedial
action; and
o Conducting REM II adminstrative and managerial tasks necessary for
providing community rlations assistance at the site (e.g. meeting
with REM II technical staff, attending EPA meetings, and preparing
monthly reports and budget updates for EPA).
The tasks identified above have been proposed based on conversations with
EPA staff. All work on these tasks will be initiated by the EPA Region I
Superfund Community Relations Coordinator and coordinated with the EPA
Regional Project Officer, the EPA Project Manager, the REM II Site Manager,
and the REM II Community Relations Manager.
REM.II technical staff may support the community relations implementation
effort. This technical staff support may include providing comment on and
reviewing fact sheets, attending public meetings and hearings, preparing
and delivering presentations at public meetings, and providing comment on
the responsiveness summary. Technical staff support as required during the
FS community relations program is included in Subtask 1AA.
DELIVERABLES: A draft and final fact sheet summarizing the FS will be
provided prior to the FS public meeting.
A draft summary of the FS public meeting will be provided
two weeks after the meeting.
A final summary of the FS public meeting will be provided as
soon as possible after EPA comments on the draft are
received and before the FS public hearing.
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A draft and final responsiveness summary will be provided
for incorporation in the draft and final Record of Decision.
A draft and final fact sheet describing the remedial
alternative will be provided within three weeks after the
Record of Decision.
A draft and final revised community relations plan will be
provided prior to the completion of the remedial design.
Subtask 14C - FS Quality Assurance/Quality Control
OBJECTIVE:
Ensure that all work products receive the sufficient technical review to
insure the accuracy of the information upon which decisions concerning
appropriate remedial actions will be made.
APPROACH:
The work includes technical review of all deliverables. Quality assurance
performed during the FS shall consist of audits to ensure that the
appropriate QC tasks have been completed within acceptable limits.
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