565363 Superfund Records CenterSDMS DocID SITE: BREAK: CTOER: 5 k S 2 6 ?

aw/amiFINAL

Davis SifcriinjSite

teitefield, Rnb Tei—*

H*Hn* AfiBigrvent No.: 200-111.7 H Dxaent Control No.: U7-GR3-CP-CBBD-1

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Kepared lytee HHt U Project Team under EA i No. 68-01-6939

SOTBBER 1387

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TABLE CP GCNXBIXS 0 ? » i : s '

Hap? l * * : l PREFACE. •I I. RESPONSIVENESS SUMARY OVERVHW

A. Proposed Alternatives and Preferred Alternative 2 B. Public Consents an the Remedial Alternatives 2 y f F

< *H. BACKSOUND CN GOMCBOTY INVQUUEMDfr AND OCNm*N5 4

§1B M«/>XXX. SIM9VKY OF COWgNBS RECEIVED DURING THE KJHLXC OCM4ENT

AND EPA RESPONSES TO naw GOMDIIS r 3 a A. Remedial Alternatives . . . . . . . . . . 6

K 1. Ranedial Alternative References 2. TeOmical Concerns Regarding Rasedial

Alternatives 3 a. Air Eknissicns fron Soil Excavation

and Incineration

b. Design .1.11 c. Tire Pile "!!!!!!!l2 d. Off-site Wastes e. RRA rwrifiii ...Il5 f. Residential Wells 9- Miscellaneous Questions il6

B. Public Participation and Availability of Infatuation. .17

C. Misoelle o.20

toetioe

rc*6 Bwlzamental Protection Agency (LEA) recently held a p'̂ 1 i-~ "'V PerAO(i for interested parties to ommaiL cn ERA's July 1987 draft

Feasibxlity Study (FS) and preferred alternative for the Davis Liquid Superfund site. He FS examines and evaluates various options «n«H renu. alternative, ror addressing contamination at the site. At the of the

^"'"'.L,per̂ oci; anncwnoed its preferred remedy for the cleans)of the Davis tiijnrt site.

Ihe purpose of this responsiveness suanary is to ^EA to the q«i.ir-TiLs and questions raised during the public cuimaiL period. All of the cxments sumarized in this document will be factored into EPA's selection of a final remedial alternative for the Davis site.

This responsiveness sumnary is divided into thefollowing section:

z* Samarv Qvgrvipw - mis section briefly outlines the pr̂ osed .̂n l̂ial alternatives as presented in the draft FS, including the preferred alternative , and provides a general overview of public aomnents cn the alternatives.

n- BavWvUnd cn PrnmnitY Involvement and OonaafflB - mis section tiLwfides i brief history of cconunity interests and concerns regarding the Davis site.

m* 9f the Public on--*- p°ri~* rr* ™to — Blis 'ii'i I iii> QIHMHMC both written and oral ocmnents received ftmi the pi*1ir during the public ocement period and provides ERA iTTim-.r-; to These "••••"- •' • arc uigttr.i 7jpt\ by subject area.

IV. P»7»-intnq ~ This section describes conoerns that were not directly addressed during the RI/TS. ERA needs to these concerns during the design and iaplementation of foe remedial alternative.

ftttafomepfc_A - This attachment includes a list of foe aenmunityrelations activities conducted atfoe Devis T.iijiii) site *" "»j H9V's i site program.

I. HESPOB1VHBSS SENARY tmiawiw

A. Pn |nad Alternatives and Ftefened Alternative

The draft FS identifies and evaluates several iHmmiini alternatives that are judged by EPA to be the most effective for dealing with contamination at

site. The remedial alternatives are organized into two cat-gories: soiree control and w>arv"jiii'iil of migration. The purpose of soiree control medial alternatives is to address contaminated and raw wastes. draft FS for the Davis Liquid site evaluated four source control alternatives. These were:

(1) no action (2) on-site low toiperature thermal treabnent (3) ca» site high taiperature thermal destruction (4) off-site high teaperature thermal destruction

In addition, the FS evaluated six alternatives for addressing contaminated ground water, r̂rfaoe water and sediments (i.e., of migration.)These were: '

(5) no action ground water (6) no action surfaae water (7) no action sediments (8) on-site traataent of ground water (9) oenxmed treatment of surfaae water with ground water (10) dredge and treat off-site sedirents

EPA'S preferred alternative is a oenbination of source control alternative #3 and imnwjwnpfW. of migration alternatives #7, #8, ard #9. ortglte high tWP^ratu-« thenaal (#3) will entail excavatingcontaminated soils anc vmstes for treatment in an incinerator that will

site far proximately three years. No action (#7) will entail a thirty-year program to monitor nearby Latham Brook for the presenceNNEFE>4 *- M 1 ». . _ ... _of cxritaminated sediments. On-site treatment of ground water (#8) will entail oontirually pumping, treating, and recharging ground water until ei mmm standards are attained (proximately ten years). Ocwbined treatment of ^yyaoe watey w.**ind (#9) will entail treating water frim an en* site stream in the ground water treatment facility.

B. Rhl lr CCmsnts cn the Remedial Alternatives

®ffee parties admitted both formal oral and written oenments to EPA duringthe public CIIIIIIHIIL period: the Rhode Island Department of Biyirornnental Management (RHXM), the Rhode Island Sierra Club, and the Smithfleld Town Ctuncil. The Oxford Tire Recycling, Inc. submitted a formal written eminent and one citizen submitted oral ooajerts during the public

in wtiitiai to the formal coxnents, many questions and *'* i*w e r e raised at the August 6, 1987 public hearing during the question-and-answer period that followed the submission of the formal oral commnts.

general, those ocnnenters that Bufanitted formal written and/OCT mni consents supported ERA'S preferred alternative for the Davis Liquid site. Hmever, nost acranenters had major conoerns regarding the safety of air emissions froa the incineration process. In addition, a few dtizers at the piblic hearing and at the public informational meeting that was held prior to the public 11 ihmhuL period, expressed oonuein that the excavation arri incineration of contaminated soils and wests might more serious risks than alternatives suehas capping or no action that would leave the and wstes undisturbed. Ooanentexs were very interested in having an opportunity to ocmment cn the design of -he incinerator. CU-ama iters were intexsted in hew EPA wwld monitor missions froa incineration as well as from the excavation of soils. Use Staithfield Town Council and citizers at the — hearing were very tummim! that the tire pile at the site may inre hazardous wastes than have yet been detected, ani in addition, say be a potential fire hazard. Citizens of smithfield and the mode Island Sierra Club requested that ERA facilitate increased public p«i-*"irripa»iffn of Town

IX. BMSSaSXMD (Si OCM8KIT¥ XNVDCVBtBKT AMD OCMOBWS

Ground %rater and surface water acntaminaticn and the potential health effects from this contamination have been the principle oonoerTs of the community surrounding the Davis site t~r mn» than tot years. The possibility of a second tire fixe and delays cleanup have »i«n been aoncerns. Recent ooncerns center an the safety of the proposed incineration process, and the enissions resultingfin its operation.

The Davis T.iquid site was used as a disposal site far various hazardous liquid and solid wastes during the 1970s. Drusmsd wastes and H«JI

5

Oantaminants were detected in several of these tells at aonoentratiara above OA health and safety criteria far drinking water, since discovery of this contamination, RmM has applied bottled water to those residents **•>» M>iie have shown contaminant levels above EPA criteria. Residoits who are not beingapplied with bottled water continue to fear that their wells ney oartaminated and are hopeful that EPA will approve the installation of a permanent later apply to serve the area around the site. Itasidaits also remain -very concerned about potentie' heal . effects stenning from the cmLamination at the site. Haste have bee a nunber of censer asong residents living imnediately arourd the site, and residents feel that »*«

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SBEQGES TO '""M* OOMBRS

,®r̂ s. *®^»»iveness arnmary addresses both oral and written qcbbbics raoeivBdby EPA oonaerning the draft PS for the Davis liquid Superfund site, me oaanent period %as held from JUly 22, 1987 to Augist 11, 1987 and was

attended to August 17, 1987 at the request of several acamenters. EPA hoiri a

hfiMing at the Snithfield Itun Hall on August 6, 1987 as an opportunityfar the public and other interested parties to present oral '•*•••••»«•»«• to EPA and ask questions of Agency staff. Formal oral cements aid the question-ateanswer period chat followed are recanted in a transcript of the hearing. Oc^ues of thetearing transcript are available at die information repositories located at the East Snithfield Public Library, the Greenville Public Library,and at the ERA Region I offioe in Boston, Massachusetts. EPA «t«-> zaceived

wnfctgi ochhbhî s on the PS. Ihe written and "^1 * • •'•••miii g oze «•»•••"» i ate organized into the following categories: (A) remedial alternatives, (B)public participation and availability of information, ate (C) *r EPA responses are provided for each ccanent, or set of Ufa*

A. BBran&L AI2BMKEXVS

. .E. ̂ ^C1C ' * ••i""r"vLs tiMjArding the various alternatives discussal in the mart IS are suosnarized below. They are organized in the following secticss: (1) icmwlial alternative preferences, ate (2) technical "•••- reoardira remedial alternatives.

Alternative

a. CUu«unnfc:

tee ""'nuniter (The Sierra Club) had objections to several of the control alternatives, it felt that the no action alternative (SC-1) waiid not be acceptable because, if the toxic materials at the Davis Liijiid site were to be left in place, the ground water quality would

deteiimale. The conmenter 00 objected to low-tenperoture dfcat-LUCtion (SC-2) hwviuse it would be more costly and less effective than high taperature treatment. The ocBmenter objected to off-site hightaiperataire thermal destruction (SC-B) because it is very ccsrly, ate because of the danger of transporting toacic materials. In addition, the ^uu-a.ier objected to the no-action alternatives (GW-1, sw-1) for managaumiL of m>jtaticn. It acemented that these alternatives do not provide acceptable protection fruit the tcocic at the Davis T'ifjnd site. The acomenter favors. treatment of ground ate surface water

the site (GW-2, SW-2) ate noted that these tediniques have proveneffective at many otter sites. The aomaenter itieagmac with ESA's assetsiitf-iiL that the best solution to sediment oontamination in Latham Brook is to ta.1 a no action (SD—1). it urged that ERA should aonsider the possible adverse effects on wildlife as well as on human health. It »icr» ®1Wested that if no cleanup action such as dredging (SC-2) is planned, thai at the very lost the location and toxicity of the sedirents should be nmnitored.

*** with the oomnenter that hî i toperatute incineration, alongwith ground and oarface voter treatment would be the most effective alternative. With respect to sediments, EEA believe thatraement and ie mymcn of the ser. -ment is potentially more harmful than leavingthe aadiimaiL undiaturhwr. Ncne of the data collected indicates release! from sediment that would be harmful. EPA will orw*g4A»- a amitorang program £o wifpl"""1ths ocistin ̂dafcs.

ffiffllHTilli'

The Rhode island Department of Bwiroraental Management (RUBS) urged that the proposed on-site RCRA landfill be replaced by an off-site disposal option.

BEft Respqngg:

oaoidered and evaluated this option during the FS by aceparing on-site land disposal for treatment residuals to off-site land disposal. An ® site landfill was ettmcn based an the criteria of cost-effectiveness and feasibility. At the estimated volume which "-"i* require (anarcocim t̂ely 15,000 cubic yards), the oast of on-site H4^pr«ai is estimated to be less then off-sire disposal. Also, the feasibility of finding a permitted landfill that would be willing to a large Quantity of residual wastes is beaming both more difficult and expensive.

Cement:

Ore citizen asked why ERA did not choose simply to r-Mp the site, divert Latham Brook into a treatment facility, and treat the sediments in Tat-ham Brook.

EPA Response:

This is a technically feasible option mn congress it very clear when it amended the Superfund statute that ERA should attempt to destroy a"* treat hazardous waste at the site, rather than aontain the contamination source. Therefore, Dft prefers to incinerate the gmirfp soils present at the site instead of cap them. EPA's preferred alternative wall reeve the source of contamination, and then treat the residual aom..mination present in the ground water. This will greatly 14% limp the volume and toxicity of hazardous wastes. Remaining wastes that can be treated no further will be kept on site in a tighrt-ly controlled landfill. The goal of this approach is to "'"'"'M the threat of future problem at the site.

2. Technical QIMJUUM. Regarding Remedial Alternatives

a. Air Bnlssions from Soil Excavation and Incineratioi

1.

Cne citizen asked what action m would take if a pressurized drum wre to break open during excavation.

EPA Response:

lhe procedures for dealing with this kind of situation will be qaelled ait in the health and safety plans that will be developed for the site before nanedial action occurs. The plan «

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EPft Response

"sixnmne" destruction moval effecien ̂is a minimum performance standard which missions are required to meet at the point of stadc exit if FCBe are present in source areas. At the ttwis site, a "fcur-nine", or 99.99%, destructionramsval efficiencyis required since K3s are rot present in somue areas. Health-

criteria are used in assessing risks frrrrl toreceptorslocated at ground level and at specified distances from the stack. HA will ensure that the incinerator is designed aikl that both the retpiired technical performance standards and health-based criteria are set. This can be accomplished by establishing various design and operational criteria, such as altering stack dimensiois (e.g., height), blending material as it enters the incinerator, or limiting the amount of soil i into the incinerator at one tins.

At thetevis site, PR's principal cnivni is missiara. Metals are not destroyed in the incineration pr» and therefore are notiiiRhrind then discussing the "six-nine" destruction removal efficiency. Bartioilate controls will be osployed to remove metals from the exhaust gases.

4. OlIMHliLi

The Sierra Club oozroented that a thorough prc-ram to monitor missions from the incineration p* • • is esi-antial of the variability of the materials at the site, aoupled with the preswimo f b o t h o r g a n i c m a t e r i a l s a n d m e t a l s . I t e x p r e s s e d H i e * * ™ w i t h EPA's assertion that metals in the emissions would be safely within 1/5 mile. It does not believe that this system will always dilute a»-t al oxides sufficiently given unusual weather conditions or

_ air circulation probiaas. A citizen acimH if additional monitoring points could be set up at people's hemes.

Qb_BsaSQsg:

EPA conducted an missions analysis that took into account a full range of atmospheric conditions and included both metal and organicmaterials regulated by the State of Rhode Island. Assisting a 40foot stack height, the analysis showed that maxminum ground level

'I-1-"Liars during varst-case atmospheric conditions would be If rated a distance of 0.261 kilometers (approximately 1/5 mile) frtxn the stack. For this scenario, none of the health-based srapptaKia ambient levels proposed by the State of Rhode Island were exceeded. However, an important factor which has not yet been introduced to the emissions analysis is the actual variation in the site terrain. A more detailed analysis to determine the effect of the site terrain will be required during remedial design.

Althcxigh the public has expressed the desire for air monitoring to

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be conducted at nearty zesidences, EPA does not believe that this is * method far nxutarinj the incineration pcoaess.Insteadof monitoring at residences, ESA will monitor stack. WTii RSi directly. Additional dispersion modeling during design wi31 determine what emission limits Bust be established in order to assMr̂ that the health-based ambient air quality criteria are not exceeded. Stack and acaabustian monitoring will be «»»*»•»«< to assare that incinerator emissions do not exceed these limits.

A citizen asked if air monitoring would involve aonstant monitoring individual ampcunds on ERA'S Hazardous substance List, or

whether it would monitor far total oonpounds present. The citizen

asked thether the portable G.C. is operated by a person.

A acnprehensive air monitoring piuyiam will be conducted at the site curing operation of the incinerator. Ibis will include ccntinuous monitoring at the stack exit, point of excavation, ard at tte site perimeter. At the stack exit, the destruction removal efficiency(110) will be monitored based on the ccncentraticre of a few designated ocapcunds thich are known to be prevalent at the site aid are the most difficult to destroy. During the test bum EPA or its contractor will test missions for all acapounds on the Hazardous Sibstanoe List to confirm that, then the designated ctmpourds are destroyed, all che other ccnpaunds are dK r̂cyed.

Monitaring at the point of excavation will be vsing handneld instruments t register total organic ""t present. Momtoring at the ; z& perimeters can be a oasbinatian of sanpling far total argam-_ oaqpamds present and all Hazardous Substance List acmpamds. A portable GC is a piece of laboratory equipment which

us* 5 analyze sanples. it is generally housed witnin the on-

site trailer and it can toe run by one person.

A citizen was uu mined how EPA would decide when to shut down the incinerator or step excavation, i.e. what concentrations of what chariretls waild constitute a limit at which the systan would be shutdown.

EPA Response:

llie vimaiLratiup of 1fic ompounds that would trigger r.n incinerator shut dwn or a steppage of excavation will be determined among design. These aoncentzations are referred to as action levels.

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toe citizen ws >« J about passible air emissions during the txiin. He noted that since ocDbusticn phawirt-wig îrie »m not

yet >naa, *"stes nay only aoi-incinerate, and nay pass through the carbcn filtration and beoone airborne.

EE?. Response:

A test burn is ouikrted very gradually, beginning with very snail loads, in order to determine the rate at which soil can be »m«h to the incinerator. There are a dozen aontrol points throughout the i"'* * w»ich are nonitcred, and if one of these indicates a problan, the systan can be shut down. A secondary ocnbustion ?""***' will destroy organic material idiioh has beoi volatilized '• the soil in the pruoary diaober. He scrubber* and afo filter will move additional materials. If a or hiaoan error were to occur during the incineration process, the systen

be shut don at any time. If a release were to occur, the fliik«»iL that could be released and dispersed w»pw]̂ i*- the envircnaent waild be limited to the amount of nn ml in the ocDbustian chambers.

Design

1. "TTf

Several ocmmoiters were oonoerned about the design (base of the incineration process. KXEEM and the smithfield Ttawn Council both argueo that the preferred alternative should be designed to all applicable State and local standards. In addition, the DepartmentwculdliJce the systan to be designed with the goal of obtaining treatment levels in the shortest time passible, not to nn-iml tai years.

gft Response;

BA has provided infarmaticn to the Town of smithfield on the types of incinerators that are being used today at various sites, and the kind of material these incinerators have been burning. The exact specifications of the design which will be isplsnented at the Davis Tiifjnd site will depend an the information gathered during the test burn. The systsn will be designed to achieve all applicable, relevant, and appropriate Federal and State technical and health-based mission standards and criteria. standards ani requirements wall be considered for relevance and appropriateness,ttioe the incinerator Km i «iri> operational, it is expected to operatefor two years to treat soils to protective levels.

0

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c. Tire Bile

1. OUmwiL:

Smithfield Town Council noted that residents .who have been following the site situation consistently know fixe naps aid other soirees tliat Kr. Davis has altered the location of the tire pile, waste pits, and access roads. The Town believes that EPA studies substantiate the fact that dnins and hazardous lave been fomd underneath scne of the tires, and is concerned that hazardous %astes are present underneath none of the tires. The Town expressed ran,mm about the health effects of the mosquitoes ani insects that breed in the tires.

EPA

The tires west of the unnamed stream which runs through the sits will be moved in order to facilitate the cleanup operation. Any water or run-off free the tires trill be contained on site. »»«»" the tires are moved frcan this area, EPA will conduct additional analytical testing on the newly TTwpnnnr! anil* ani will treat the s®8 as appropriate. OA has found no contamination in the part of the tire pile east of the unnamed stream (outside the wetland), ani tires in this area are not scheduled to be moved.' EPA believes that it has been able to delineate the outer extent of contamination in the tire pile using aerial photos. However, if further contamination is found within unsuspected tire pile areas, B>A trill re-evaluate the sccpe of the remedial action to see if clmrsp of these areas can be included in the p-innnri action.

EPA expects to find sane contamination of the tires which are buried in contaminated soils. Tires that are within soil-contaminated regiois will be incinerated or ty washing with water to rmoove soil. Hotever, EPA does ncr. own the tires, and has authority only to relocate the tires out of the wetland and staging areasto a location of Mr. Davis' choosing, so that the randy saybe conducted. The health effects of mosquitoes which may breed within the tire pile if not within the scope of EEA's site evaluation. This oonoern should be directed to the appropriatepublic health agencies.

2. O iiiinnt:

Oie citizen was very ujnueined about the possibility of the incinerator exploding, emitting aontaminants into the air, ani causing a fire in the tire pile. This resident was very that the Town of Smithfield and the section of the state in which it is located would not have the capabilities to contain a tire fixe,if it began.

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The chances of a failure within the mobile incinerator system that waild result in an explosion and fire outside of the chazhers are practically non-existent. An explosion aould only be by loading a large giantity of highly volatile (such as gasoline or benzene) into the incinerator. Drums of waste are never lowrtBil into an incinerator. Instead, drums are opened, the contents are analyzed, and then the material is slowly fed into the incinerator, in general, the material that will be incinerated is soil contaminated with low levels or organic acepounls. There are insufficient giantities of arganics present, in the ««->•) 1 in concentrated farm tora"™ any explosions.

Hcwever, if the incinerator were to ejgilode, a danger may exist if

the incinerator was located in close proximity to the tire pile,

a^JK3b could catch on fire. The incinerator *rin nob begin

v^n. the tires are moved. Also, under the authority of has set up the Emergency Rpspcnse Operation which is

a qaecially trained ^1«up that can respond izasdiately to eneroencvsituations such « »

The anithfield Twn Oouncil believes that the Remedial Investigation(RI) minimizes the threat of the tire pile, and urged that- the ES be expanded to include ranoval of the tires, anl treating and capping

Tires are categorized as a non-hazardous waste. Since ERA neither cwnsthe tires nor has the authority to regulate tires under Sgperfund, EPA cannot remove the tires from the site unless given permission to do so by Mr. Davis. EPA does have the authority to move tines out of wetland and staging areas to »nrM the remedy to be conducted.

O nii**nfc2

The Ttwn was concerned that rain may cause contaminants in the tire pile to flew over the site after it has been cleaned up, causingraoontamination of the site.

ERA Response:

Tires will be removed from the site treatment areas and will not be replaced in those areas. The surface water and ground water in the acntaminated areas will be isolated from other parts of the site by the treatment system. Any contaminated ground or surface water that

14

enters the treatment zone will pass through the tnatzent system and will not leave the treabent zone until cleanup standards are acheived.

B* believes that there are no aontaninants in the tires themselves. After the remediation of soil, ground water and surface water is < xii|>leted, no contamination levels above the health criteria will be left to recontaminate the site.

d. r>ff-«Hfr*» ihBiw.

1. O •

Several 11IIIIIHI iters requested that only contaminants >*»•— the site be treated, incinerated, or buried at tte site, ltefimithfioiH Town Ocamcil also requested that, when EPA remediates the GSR landfill, only on-site contaminants be in the GSR landfill.

EPA RESPONSE;

Under the Superfund program, EPA is not required to obtain a RCRA permit to store, treat, car dispose of hazardous "»

»

I

15

a» citizen asked what responsibilities BAhasattte Davis site after the 30-year monitoring period for the on-site ROW landfill is ccnpiete.

Pie statute requires that for 30 yearsfollowing — of the ZBBedial action, ERA mist review the status of remedial actiora (inwhich taste is left on site) in five year intervals. Ihe effectiveness of the technology nust be impr-nri in relation to new technologies that might be more effective at the site. However, after thirty years, the site beocnes the (replete respcreibility of the State.

1. CCment:

Che citizen was cumiel that residential wells counter the effects of the grand voter extraction wells that will be installed by ERA during the ranedial action, and that the residential uaHe night draw in contaminated water as a result.

Residential wells axe too distant and do not punp sufficient of water to affect the ground-water extraction operation,

ttie cyiality of water in the residential wells will not be by the grand vater extraction prooess.

2. CUuiftaiL;

Qm citizen questioned whether the installation of iniividual carbon filters at affected residences would be more efficient than installing water lines through the entire area.

ffift ppsprrrv*:

Targeting specific hones in the area for installation of carbon filters would not sufficiently protect residents in the area because the nature of the fractured bedrock in the region ' < nit-te a large diversity in residential well contamination aroum the site. In addition, individual hone systoos are generally operation and

16

maintenance intensive.

Sierra Club argued that all incineration operations be Airing the tines when local residents would have narnal ««« to Federal, State and local health officials. Therefore, incineration during weekends, holidays and at night should he prohibited.

EE* Resnensa;

incineration is a 24-hour-a-day operation. This ir due to the 1-to3 day fire-up time required to bring tte incinerator

17

«g»leyae, State employee, contractor, consultant or U.S. Any corpsof Engineer official).

4. O imnput;

One txmmtailer asked why B>A had not constructed a slurry wall around the contaminated waste.

EBA Response:

&ie to the site's hydrrryaological features,tills method cannot be used because a slurry tallrould not be constructed deep enough to prevent contaminated ground water from moving off site.

5* Qmmmnt:

RXEEM encouraged EPA to take into consideration the fact that there exists a State Supreme tluil judgment against the Davis's requiring the restoration of the wetlands at the site. The Department arguedthat the pi. t.«,od remedy should be selected and designed to allow the State to pii i.tul with actions to ccnpietely restore »n wetlands at the site.

EPA Rpm-u^e:

Where EBA Stpeifuul ranadies do not impact wetlands directly EPA cannot expand SuperfUnd monies to restore wetlands. However, EEA is currently investigating the legal »

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ERA Response:

local citizens that are interested inreviewing data r»-»i i«A to obtain expert assistance in

interpreting technical information regarding the nature of the hazard at the site, the RI/PS, the Record of Decision, the remedial design arc re.-edial action, and other Siperfund activities. AR îcants rust meet the reguireeents of grantregulations in 40 CFR rart 30 and proairement regulations under 40 OR Bart 33.

*be Snithfield Town Council expressed that

neater torn and piblic participation be permitted by EPA in the

future. The Town Comcil felt that they could have had greater

ixgwt into the plan for mediation. The Council further argued

that the public shoild be given the opportunity to on the

design of the remedial action, specifically the design of the

Incinerator*

EPA Response;

After deciding which incineration system seasrest praising, EPA will conduct a test burn to determine whether the systan is capableof meeting health and safety criteria. Us data miipH-pH during ***% "ill be available far public review. In addition, ERA wi-il hold a public meeting on the design of the mondial action. Hcwever, this meeting will not be held until therasmdial design is near ocxpleticn. if town officials and local citizen desire y-riitfr ugwt into the ininlial design process, they may tosh to form a citizen's advisory ammittee that would meet periodicallywith EPA to diwniss specific aspects of the remedial design and

actaon- Also- at the town's request, ERA can brief town officials on the status of the remedial design during Bound of Selectmen or Tawn Cornell meetings, or other town meetings.

http:iirfotmnti.cn

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QJHIIMIL:

Citizens of Smithfield urged that EPA fund a town representativethat would have wrnpsB to the site at all tines, art would be responsible far notifying Smithfield residents in the event of an wnrnjenuy during the IMHHHI action. The Town requested that the trial turn results as well as the monitoring results be marie available to this representative as soon as they are generated. The Totm argued that insurance provided to EEA personnel "iild »!«» be provided far this person.

EPA Response;

EPA does not feel that it is necessary to provide funding for a town representative that would have to the site at all »iwoe and that -xxild be responsible to the town during an emergency. EPA will develop a thorough site-spr̂ ific health and safety plan before any wor* 81 th6 site < i •IMP!lues. This plan will designate the peopleresponsible in case of ai emergency and will spell out exactly EPA will ooartlinate with the local fire art police departments art

hospital in case of an emergency. EPA will insure that a responsible official, either from EPA itself, from the Array corps of Engineers, trco a consulting-engineering firm, or from the State, has ̂respcnsihi1 ity for the cleanup operation. Furthermore, an EPA Af.Jii ipmawi will be present at all during the iwimiiai action.

O IIIIIMMI.;

Oie citizen us very oimial that he receive a copy of the time

recording that EPA had mde at the hearing before he his

written ccmnents.

EPA Response;

The transcript of the hearing requires ten to eleven days to prepareend thus will not be reacy for use by the »• »mm it-ar before the aniifiiL period deadline. However, the transcript is esfeail.ml1y for use by EPA. EPA needs the transcript in order to uaeider and respond to all consents in making its final decision an the IHUH lint alternatives. Copies of the typed transcript will be placed in the information respositaries far the benefit of the public as soon as they hH'» inn available, but acpies of the will not be made available.

ccsmenter asked whether art how often »''• monitoring *"uL-1 would be available to the public.

http:esfeail.ml

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EPA Response:

Test data will be available to the public roughly every two weeks.

MtSCXEUNKXB ISSUES

Health and ftifotv

a. OumwiLr

One citizen aamnented that there appears to be a high incidence of fatalities and malignant timrns in residents living within a niu mile radius of the site. He wondered whether EPA had done anyhealth studies linking the Davis T.iijii

I

21

ERA woild only buy people's areperty and relocate them to a new area if there was no other- alternative which would allow EPA to protect

's health. EPA is satisfied that the different alternatives that have been acnsidered for the Davis site will allow EPA to clean IQ> the site and ensure that health is aiequatelyprotected.

3. Srherhile of Qaamp and of Funds for Cleamm

a. OnuenL:

One citizen asked then the f-i turnip would begin.

ERA Response:

ERA plane to sake a final decision regarding the preferred alternative far the Davis Iliquid site before Septsrcer 30, 1987. QA is hopeful that the design work will be sustantially

the winter, and the initial stages of operation will beoin tav the Sunmer of 1988.

b. OjmuenL:

ttie citizen was cmuexned whether EFA will definitely the cleanup, or whether the ocnpletion of the cleanup will depend on Ocngress for yearly funds. The citizen asked whether, if an otergercy situation were to develop at another site, funds oould be taken ait of the ludget for the Davis site for use at that site.

ERA Response:

Oangress has allocated funds for the Superfund piujiam through 1991. These funds are oblî rted on a site-specific hacic each year. EPA Region I will sufcmit yearly requests to ERA Heackjuarters far funis to clean up the Levis Liquid site. However, the ground-water treatment process will require approximately ten years to ccnplete ̂it is conceivable, although not probable, that Congress would

not appropriate more funds far the St̂ ierfund -ip after 1991.

c«

One resident asked if EPA action would be dependent on the number of people living in the area, i.e., would ERA delay at the Ifevis Liquid site because fewer families are affected than at

22

another site.

EBA Response;

OnoB the Record of Desicision (ROD) has been signed, EPA is required to ensure that the site is cleaned up according to the nandial action plan specified in the ROD.

4. Exfeengim rv—pc ̂ Period

a. CXumaiL:

Ihe Saithfield Item council requested that the por-irvi be extended so that it aould review a report by the engineer hired by the torn to study ERA's reocmnendations for the reosdiaticn of the Davis Liquid site.

ERA Rpsnmse;

In response to the acnaenter's request, the acnnent periodextended fran August U, 1987 to August 17, 1987.

5. Tire Recycling

a. Olmm.il •

aneaannenter (Oxford Tire Recycling, Inc.) noted that it is in the pL>» r-.-. of developing a teste tire iwarv»ijuwm..i network to serve mxdi

Nes"' England. As oxrrently planned, the network will aonsist of cne ar more state-of-the-art tire-to-energy facilities and, in addition, severalregional tirerecycling and processing centers. The acmnenter noted that it owns an option to take control of the tires at the Davis Licyiid site, manage them, and utilize then for purposesof recycling or energy recovery. It might establish a tore shredding and recycling operation at the site to accept are! Ins used tires not oirrently on the site. The »• mumii-nr is (Xiuanai that the PS does not take into consideration its proposedplan and the significant environoental Benefits of the plan. It rpryy-rted that EPA give full consideration to the measure that would be needed to preserve sufficient to the tire pile for its proposed plan far the tires. In addition, it requested that EPA state that the bulk of the tire pile does not contain contamination, and the use of such tires would not raise Superfund or related liability issues.

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EPA Response;

Bie 'tires are a non-hazardous waste and therefore EPA does not have authority to regulate them under Super-fund. EPA acknowledges that there are benefits to a plan that would utilize the tires for the purposesofrecycling or energy recovery. EPA does not plan to block arness roads during the remedial action. Also, EPA believes

the hulk of the tires do not aontain hazardous contamination.

b.

asked whether any ompanies were interested in purchasingliie tires; and if an aynmmaiL had been reacted.

TV* jhiise the tires are a non-hazardous waste, EPA has no authority to regulate tires that trill not be handled during the cleanup.

6. Posts;

a. O iinnit:

RHEM revested a more detailed breakdown of the costs that the State wculd incur as part of the Superfund remedial and postimfilial activities pa>|w,eod at the site.

EPA has held a meeting with RXEEM to present and the costs ^ State will incur as part of the remediation.

7. site_AesE3

a. CmtifcaiL:

a* citizen asked if the area would be fenoed off to prevent or disraiarie tampering or sabfaotage. He also asked whether Mr. Davis would have aonpss to the site.

Q&_B^sn§e:

ERA will maintain a high level of security at the Davis T.irpiiH site. Die legal issue of Mr. Davis' annpss to areas of remediation is

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XV. ASSUMING 020006

wriB seifanl ifflups and concerns raised «*••»• ̂ "j the • MUJI • leiumnce sunmary that EPA Should address during the remedial design and remedial action. Obese issues and concerns inclixie the following:

(A) Availability Of ffipmprltal Design Information

There is rmsirterable nimtn that new information gathered prior to IIHIÎ HHI action be available for p*]if* review and osnxnt. Particularly, citizens are ooroemed abort the design specifications of the incinerator, and the puiinunu method of monitoring air emissions resulting from incineration and excavation of soils, etn will continue to meet periodically with interested parties (hiring theremedial design to new information and design plans. EB&'s Health and Safety Plan will be available for piNi«review prior to the remedial action. This will specify the.details °f the air monitoring program, health-based action levels, and emergency procedures. In addition, an informational meeting «in be held when the design is near

(B) Avail ability of Air- ̂

Residents are wary conaeumd about potential of the air in the area of the Davis I.iiyiid siteresulting frnn incineration and excavation of scils. Some citizens have requested »

26

A

Amman® ams uyuio sns

Qoamaiity relations activities conducts at the Davis T.4yM site to data haw

included:

o At a Tan Council meeting in October 1984, EPA announced it had

*wwnwul tte leadfor clearag) activities at the site,

o EEft cmirtnrtiBd oassramity interviews as part of the acnnunity

relations plan in January 1985.

o OA mailed information igdates, fact Assets, and press releases to

the site acnmmity in July 1985, August 1985, Sqstafcer 1985,

February 1986, June 1986, hRnptniwif 1986, January 1987, May 1987 and

JUly 1987. „ fe-

o BA held a public inserting to discuss the results of the remedial

investigation in January 1987.

o EXA held a public meeting and * • ••••"« •