MEMORANDUM DATE: January 20, 2017 TO: Ronald Gagnon, P.E. – RI Department of Environmental Management CC: Chris Walusiak, P.E. – RI Department of Environmental Management Gregg M. Giasson, P.E. – Providence Water David Tikoian – Providence Water Stephen Soito, P.E. – Providence Water Peter J. Pallozzi – Providence Water Shane P. Driscoll, P.E. – Pare Corporation FROM: Timothy P. Thies, P.E. RE: For Review and Approval

Providence Police Firing Range –Project Work Plan Providence Water Scituate, Rhode Island Pare Project No. 14256.06 The purpose of this memorandum is to provide a Project Work Plan for the area surrounding the Providence Police Department Firing Range located on Battey Meeting House Fire Lane in Scituate, RI. This work plan will include a field screening program to identify if the firing range activity has had an adverse impact on the soil, and possibly groundwater, at the range, a spent ballistic reclamation and maintenance program, and new upgrades to the firing range that will mitigate any potential future lead impacts to soil and groundwater. Previous studies performed by Fuss and O’Neill, which are described below indicate that the firing range has had only a minimal impact on sediment in the adjacent Scituate Reservoir and no discernible impact on surface water quality. As such, the focus of this Work Plan is the firing range property and not the Reservoir. Background The Providence Police Department Firing Range occupies approximately 1.3 acres in Scituate on a parcel of land owned by the City of Providence. The site is bordered by forest to the west, north, south, and east, with the Scituate Reservoir located approximately 260 feet to the east of the firing range. The Scituate Reservoir is a source designated for drinking water and is therefore classified by the Rhode Island Department of Environmental Management (RIDEM) as a Class AA waterbody. The firing range is currently in use as an active range and consists of 3 shooting ranges: informally designated as “the shotgun range”, “the handgun range”, and “the rifle range”, which are depicted on the attached Drawing No. C2.1 Excavation Plan. The handgun range is flat and paved with 2 lateral side berms (running west to east) and an impact berm at the west end extending across the length of the handgun range. The shotgun range is located north of the handgun range, with an impact berm on the west end of the range, which is connected to the impact berm for the handgun range. The rifle

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range has 2 impact berms, a short-range berm and a long-range berm. The short-range berm is located on the west end of the range, also connected to the handgun range. The long-range berm is a small, isolated berm located in the southwesternmost area of the site. At the east end of the site is a small building and parking area. Based on information gathered during a site visit performed on April 7, 2016, during which it was raining significantly, stormwater at the site appears to flow from the firing range toward a washout area on the eastern side of Battey Meeting House Fire Lane. The washout appears to transition into a channel, approximately 12 inches wide by 12 inches deep. This channel appears to be the primary stormwater flow path, which was observed to contain stormwater runoff flowing from west to east toward the Scituate Reservoir. While significant flow was observed entering the washout area from the parking lot, no flow was observed in the channel approximately 30 feet downstream of the parking lot; it appears as though most of the water had infiltrated into the ground at that point. No runoff was observed discharging directly into the reservoir. A manmade swale was observed, which follows a north-to-south direction on the eastern side of Battey Meeting House Fire Lane, meeting with a stone culvert that crosses under the roadway from a wooded area south of the firing range with an outlet toward the reservoir. No flow was observed in these manmade drainage structures. Ponding water was observed at the base of the primary impact berm, at the easternmost section of the shotgun range, and south of the firing range building (see attached Field Report). Previous Environmental Investigations Fuss and O’Neill performed sediment and surface water quality sampling in the vicinity of the firing range in 2009, 2012, and 2016. The purpose of the sampling program was to evaluate whether the contaminants of concern (i.e., metals and volatile organic compounds “VOCs” associated with spent bullets and weapon cleaning agents) were present in nearby surface water and sediment. Based on the data they collected, Fuss and O’Neill concluded;

“These results indicate that firing range operations do not appear to [sic] degrading sediment and surface water quality in a manner that would warrant short-term action to protect this resource.”

They further concluded;

“It is likely that firing range operations are contributing, in part, to the presence of these metals in sediments, particularly within the cove adjacent to the firing range. Given the sensitive use of the Reservoir as a major public water supply, efforts to mitigate migration of metals from the firing range through implementation of engineered controls or relocation of the facility should be considered.”

In general, Pare agrees with the conclusions Fuss and O’Neill drew from their data – the firing range is likely contributing, in part, to the presence of lead in sediment within the cove, albeit only marginally. While metals and VOCs were detected in sediment in the vicinity of the site, it is important to note that the primary contaminant of concern – dissolved lead – was not reported at concentrations exceeding laboratory detection limits in the surface water samples. Nonetheless, Providence Water is being proactive given the use of the reservoir as a public water supply, a work plan should be initiated as described herein to prevent the potential migration of metals from the firing range to the Reservoir.

Mr. Ronald Gagnon, P.E. Page 3 January 20, 2017

It appears as though the data collected by Fuss and O’Neill over 3 separate sampling events has largely answered the question as to how significantly, if at all, the firing range has impacted the Reservoir. The firing range appears to have had a minor impact on sediment and no discernible impact on surface water. Even though the range does not appear to be impacting the Reservoir, there is a significant amount of lead deposited at the firing range that, if left unattended, could impact the Reservoir in the future. Therefore, the Providence Police Department and Providence Water are being proactive about mitigating potential future lead migration from the site. The purpose of the following sections is to outline a work plan for capturing spent ballistics and investigating the firing range site. Work Plan This work plan has been divided into 6 sequential phases, which include:

1. Preliminary Soil Screening; 2. Spent Ballistic Reclamation; 3. Cement-Soil Mixture Development; 4. Range Maintenance and Lead Encapsulation; 5. Range Upgrades; and 6. Supplemental Site Characterization (if necessary)

The overall plan is summarized as follows, with each phase described in detail below. In general, the work includes delineating lead impacts on-site, reclaiming spent lead fragments, blending contaminated soil with concrete to stabilize lead, and the upgrades to the range. Phase 1 will produce a lead impact map of the project site to illustrate areas of excessive lead concentrations utilizing a handheld XRF analyzer. Phase 2 involves the visual inspection of the project site and reclaiming spent ballistic through the use of handheld tools by individuals wearing appropriate PPE (i.e., boots, gloves, dust masks, and long sleeves). To determine the optimal cement-soil mixture for the encapsulation of excavated soil and create a durable end product, Phase 3 will include a pilot study to test the compression strength of concrete cylinders made with different binder-to-soil ratios. After the reclamation and pilot testing, Phase 4 will begin with the excavation of the site as specified in the project drawings. This excavated soil will be used by the contractor to create cement-soil blocks and flowable fill on-site and placed as indicated in the project drawings. Once the concrete has been placed, Phase 5 involves the construction of a new granular rubber bullet trap and associated concrete support pad. As a result of new impervious surface, this phase will also consist of minor site grading to convey and manage stormwater. Finally, at the discretion of Providence Water, additional soil screening and laboratory analysis will be conducted based on the result of the XRF analysis as part of Phase 6. These phases are described in the following sections. Phase 1: Preliminary Soil Screening Plan The objective of this phase is to evaluate which areas of the firing range have been most impacted by firing range activity. It is assumed that the primary impact berms and the areas immediately surrounding those berms have been most significantly impacted, but the areal extent of lead is unknown. A carefully planned soil screening program will indicate the extent of impact around the primary impact berms and what other areas might also be impacted. A grid will be established on-site and lead measurements will be taken utilizing a handheld X-ray fluorescence (XRF) analyzer.

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This device emits a signal that reflects off certain elements that can be detected by the analyzer’s CPU. The scanner will be able to determine the concentration of lead in the soil without disturbing or sampling soil. Coordinates will be collected at each screening location using a handheld global position system (GPS) unit. Using this information, a lead impact map for on-site lead will be generated. Phase 2: Spent Ballistic Reclamation Program It is presumed that the area with the highest concentration of lead will be the primary impact berms at the west end of the site where the majority of the lead bullets and fragments land after being shot. During Pare’s April 7, 2016 site visit and subsequent site visits, a significant amount of spent ballistics was observed on and at the bottom of the impact berms. It is also suspected that the side berms and shooting lanes have some lead concentrations, although those concentrations are suspected to be much lower than the primary impact berms. Phase 2 of this work plan will be the implementation of a spent ballistic reclamation program. Prior to excavation of existing on-site soil, visual screening and hand selection of spent ballistics will be performed. Reclamation will be done with handheld tools by individuals wearing appropriate PPE (gloves, long sleeve shirts, and dust mask). No mechanical screening of spent ballistics is proposed at this time. These reclaimed bullets and bullet fragments will be collected in closed containers and transported to a Rhode Island-licensed metal recycling facility. Upon completion of the reclamation program, a copy of the bill of lading for the recycled bullets will be sent to the RIDEM. Visual screening and hand selection of spent ballistics that fall outside of the proposed granular rubber bullet trap (see Phase 5) shall be collected in closed containers and transported to a Rhode Island-licensed metal recycling facility on an annual basis. The recycled bullets are considered a scrap metal, pursuant to 40 Code of Federal Regulations (CRF) 261.6(a)(3)(ii), and therefore are exempt from Resource Conservation and Recovery Act (RCRA) regulations. However, the Providence Police Department will retain bill of lading documentation to demonstrate that the lead was recycled. Phase 3: Cement-Soil Mix Development Before any excavation activities take place, Pare proposes a brief pilot study to determine the optimum ratio of cement and soil to achieve an appropriate concrete mix for this project. The appropriate mix will be one that provides a durable long-lasting concrete product, and one that provides a stable lead encapsulation mechanism. Pare will collect soil samples from 3 areas on-site; the primary impact berm, the side berms, and the range lanes. Several discrete soil samples will be collected from each area and composited into three samples for laboratory analysis. These samples will be submitted to a Rhode Island material lab to determine the soil’s moisture and organic content, and grain size distribution. This information and soil samples will then be provided to the selected site contractor. The contractor will use this data to determine the appropriate mix design for each area of the range. Upon establishing a mix design, the contactor will generate a number of test cylinders for each mix design, with a target compressive strength of 2,500 psi.

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Phase 4: Range Maintenance and Lead Encapsulation Program Following completion of spent ballistic reclamation activities and the cement-soil mixture pilot, the range maintenance and lead encapsulation program will include excavation of the top 2 feet of the impact berms and side berms over their entire face, excavation of at least 3 feet of soil at the base of the primary impact berms, and excavation of the top 6 inches of soil in the shotgun and rifle shooting lanes. The handgun shooting lanes are paved and therefore no excavation is proposed within this area. The top 2 feet of the washout area and channel that appear to be the primary stormwater flow path from the firing range will also be excavated as part of Phase 4 (see Drawing No. C2.1, Excavation Plan). These limits, as described above, are subject to change based on the findings of the preliminary screening program. Per conversations with RIDEM, the area of soil disturbance calculated to assess compliance with the RIPDES Construction General Permit, will exclude excavation performed on the primary impact berms and side berms. These berms are considered to be features above the firing range and not soil, and therefore maintenance work performed on these features is not considered a site disturbance. As a result, the total area of disturbance proposed at the site, including the 2 proposed stormwater controls, will be approximately 38,000± square feet (0.87± acres). The excavation regions that are considered areas of disturbance are specified in the following table. For a review of all excavation regions proposed as part of this maintenance program, see Drawing No. C2.1, Excavation Plan. The proposed stormwater control areas at the site are found on Drawing No. C2.2, Proposed Site Plan.

Excavation Region Area (sq. ft.) 5 4,424

10 648 11 17,687 12 10,874

Stormwater Controls 4,195 Total 37,828

Soil from the excavated areas will be temporarily stockpiled before processing. Excavated soil will be mixed with Portland cement in a concrete batch operation area to create flowable fill and concrete blocks. Blocks are anticipated to be 5 feet by 2 feet by 2 feet, or comparable dimensions. Encapsulating the soil in cement will provide solidification and stabilization (S/S) of the soil as well as prevent lead from leaching off site. The cement-soil mixture to be used for S/S of the soil will be determined during Phase 3: Cement-Soil Mixture Pilot. The cement-soil mixture made into blocks will be stacked as shown on Drawing No. C2.2, Proposed Site Plan. Concrete blocks will be stacked and arranged in a rectangular shape surrounding the 2 side berms and flowable fill from the cement-soil mixture will be poured over the berms to the stack height. Concrete blocks will also be stacked on the primary impact berms, with flowable fill placed behind the blocks to match the berm slope and provide sufficient support for the blocks. Flowable fill will also be poured at the base of the primary impact berms and brought to grade.

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Phase 5: Range Upgrades To decrease the potential migration of lead-impacted soil to off-site receptors resulting from firearm activities at the site, a granular rubber bullet trap will be installed at each primary impact berm. Each trap will be equipped with a concrete pad composed of the cement-soil mixture and made to the dimensions as shown on Drawing No. C4.0, Bullet Trap Detail. This pad will be constructed at the base of the concrete blocks stacked on the primary impact berms. The RIDEM has determined that the berms are not part of the site, but are features above the firing range; the only new impervious surface proposed by this project is from the concrete pads. The current dimensions of the proposed pad will create approximately 6,972± square feet of new impervious surface. The project work plan includes upgrading the stormwater management features across the site to provide conveyance for the slight increase in impervious area at the site as well as to mitigate potential lead migration through stormwater runoff. The stormwater conveyed from the site toward the existing drainage swale south of the site will be enhanced through the installation of a 1-foot wide by 1-foot deep swale of 1½-inch limestone as shown on Drawing No. C2.2, Proposed Site Plan. The purpose of the limestone is to raise the pH of the stormwater runoff, which make dissolved lead insoluble and cause lead to come out of suspension before it makes its way to the reservoir. The stormwater conveyed from the majority of the site toward the existing washout area and channel east of the site will be enhanced through the installation of a detention pond lined with 12 inches of 1½-inch limestone. This will be accompanied by a 15-foot wide by 12-inch deep spillway constructed of 6-12 inch riprap to capture overflow. Construction activities resulting from this work plan will be performed outside jurisdictional freshwater wetlands and will include less than 1 acre of land disturbance, thereby excluding the project from the permitting requirements of the RIDEM Freshwater Wetland Program and the Rhode Island Pollutant Discharge Elimination System (RIPDES) Program, respectively. Lead removal and grooming of the granular rubber bullet trap shall be performed by a qualified lead reclamation contractor every 3 years. Reclaimed lead bullets resulting from the bullet trap maintenance program shall be collected in closed containers and transported to a Rhode Island-licensed metal recycling facility. Phase 6: Supplemental Site Characterization At the discretion of Providence Water, verification of the results of the XRF analyzer may be performed through soil sampling and laboratory analysis. In addition, should groundwater be encountered during the Maintenance Program or the Preliminary Screening, Providence Water may consider performing groundwater sampling and analysis. Soil and groundwater samples would be collected in laboratory-provided glassware and submitted with chain-of-custody documentation to New England Testing Laboratory (NETLAB) of West Warwick, Rhode Island for chemical analysis. The samples would be analyzed for total lead using EPA Test Method 6010. Upon completion of this supplemental site characterization, a report of the findings would be prepared including comparison of sampling analytical results to applicable RIDEM regulatory criteria and would address the proposed remedial actions and RIDEM reporting requirements, if applicable.

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Mr. Ronald Gagnon, P.E. Page 7 January 20, 2017

When you’ve had an opportunity to review this information, please give me a call to discuss. -TPT Attachments: Firing Range Maintenance Plan Drawing Set Field Report Sources: Best Management Practices for Lead at Outdoor Shooting Ranges. United States Environmental Protection Agency. EPA-902-B-01-001. Revised June 2005. Korte, A.C.J. de and Brouwers, H.J.H. Production of non-constructive concrete blocks using contaminated soil. Construction and Building Materials, 23 (12). pp. 3564-3578. 2009. Yin, Chun-Yang, Ghazaly Shaaban, and Hilmi Bin Mahmud. Chemical Stabilization of Scrap Metal Yard Contaminated Soil Using Ordinary Portland Cement: Strength and Leachability Aspects. ScienceDirect. 5 Dec. 2005.

Scituate, Rhode IslandPare Project 14256.06

January 2017

Providence Police DepartmentFiring Range Maintenance Plan

Providence Water Supply BoardProvidence, Rhode Island

PREPARED BY:

PREPARED FOR:

ENGINEERS - SCIENTISTS - PLANNERS

8 BLACKSTONE VALLEY PLACE

LINCOLN, RI 02865

401-334-4100

PARE CORPORATION

LIST OF DRAWINGS:

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FIELD REPORT NO. 001

Page 1 of 3

PROJECT TITLE: Providence Police Firing Range DATE: 4/7/2016

Preliminary Project Work Plan

Providence Water

LOCATION: Scituate, Rhode Island TEMP: 50s °F

PARE JOB NO: 14256.06 WEATHER: Rain

CONTRACTOR: None

SUBCONTRACTOR: None

PARE OBSERVER: Shane P. Driscoll, PE, LEED AP

EQUIPMENT ONSITE: None

MATERIALS USED: None

PERSONNEL ONSITE: Stephen Soito, PE

Timothy P. Thies, PE

SITE VISITORS NOTED: None

DISCUSSIONS AND COMMENTS: (NOTE INJURIES IF ANY)

The undersigned arrived at the site at approximately 11:45 AM. The following was noted while onsite:

Upon arrival, Tim, Stephen, and I walked the area to observe the stormwater flow path between the firing range

and the Scituate Reservoir. The stormwater at the site appears to flow from the firing range toward a washout on

the eastern side of Battey Meeting House Fire Lane. The washout appears to transition into a channel,

approximately 12 inches wide by 12 inches deep. This channel appears to be the primary stormwater flow path,

which was observed to contain stormwater runoff flowing from west to east toward the Scituate Reservoir. While

significant flow was observed entering the washout from the parking lot, no flow was observed in the channel

approximately 30 feet downstream of the parking lot; it appears as though most of the water had infiltrated into

the ground at that point. No runoff was observed discharging directly into the reservoir.

A manmade swale was observed following a north-to-south direction on the eastern side of Battey Meeting

House Fire Lane, meeting with a stone culvert that crosses under the roadway from a wooded area south of the

firing range with an outlet toward the reservoir. No flow was observed in these manmade drainage structures.

Ponding water was observed at the base of the primary impact berm, at the easternmost section of the shotgun

range, and south of the firing range building.

See attached site photography.

The undersigned left the site at approximately 12:30 PM.

Shane P. Driscoll, PE, LEED AP

Project Engineer

FIELD REPORT NO. 001

Page 2 of 3

Photo 1: Washout on eastern side of Battey Meeting House Fire Lane

Photo 2: Stone culvert crossing under Battey Meeting House Fire Lane

FIELD REPORT NO. 001

Page 3 of 3

Photo 3: Manmade swale on eastern side of Battey Meeting House Fire Lane

Photo 4: Ponding water at base of impact berm