PROVIDENCE -The Department of Environmental Management today established a plan compelling the Rhode Island Resource Recovery Corporation, which runs the Central Landfill in Johnston, to correct problems involving erosion damage and continued emission of landfill gas, within the next two weeks.

A letter from DEM Director Jan H. Reitsma to the RRC Executive Director Sherry Mulhearn, outlining the plan, is attached.

October 1, 1999

Ms. Sherry Mulhearn, Executive Director
R.I. Resource Recovery Corporation
675 Shun Pike
Johnston, RI 02909

Dear Ms. Mulhearn:

This letter is a summary of actions and schedules discussed and agreed to at our meeting Wednesday, September 29, 1999. I convened that meeting in response to the serious erosion damage that has occurred at the landfill over the past few weeks and the continued uncontrolled emission of landfill gas, with unacceptable odor and sedimentation conditions resulting. My goal entering the meeting was to compel a more aggressive response to these problems and, with your cooperation, I believe we have set a course to correct these conditions over the next two weeks.

In summary, we discussed two critical areas requiring action.

First, with respect to the erosion damage and related sedimentation, we agreed to the following actions and timelines:

1. Immediately increase the repair effort on washed out areas. All washed out areas are to be repaired no later than October 8, 1999.
2. Immediately install temporary sedimentation and erosion control measures (silt fences, curtains, geotextiles, mats, Posi-shell, etc.) and complete the installation no later than October 8, 1999.
3. By October 6, 1999 submit a plan to DEM for stabilizing the site for the winter. This plan must include maximum efforts to revegetate the cap during the remaining fall growing season. ENSR's plan to address the erosion problems in the Areas III and IV of Phase I will be submitted to DEM no later than the close of business on October 1, 1999.
4. Stabilize the site for winter by October 15, 1999. It is understood that work will continue throughout the winter, weather permitting, in some active areas of the facility.
5. Excavation activities will be undertaken to restore the majority of the capacity of Sedimentation Pond 2. That excavation will be completed no later than October 29, 1999. Complete restoration of Ponds 2 and 3 will be undertaken in the Spring of 2000.

Second, with respect to the landfill gas control, we agreed to the following actions and timelines:

1. By September 30, 1999, submit a request to authorize increased gas flow from the landfill to one of the existing flares from 500 cfm to 2000 cfm subject to the design and operation specifications of the equipment and allowing the installation of additional flares. That request was submitted. DEM issued an emergency approval on September 30, 1999. RIRRC will immediately increase the flow to the existing flare.
2. By October 1, 1999 submit a plan to DEM for assessing the degree of gas emissions.
3. By October 4, 1999 begin implementing the assessment plan. Said assessment must include a network of test points throughout the facility measuring gas emissions.
4. Immediately begin installation of temporary flares in areas with known emissions.
5. Continue installing temporary flares in areas with gas emissions in areas identified as the assessment progresses.
6. By October 11, 1999, rebury all gas collection & transmission lines exposed by washouts or other means.
7. By October 22, 1999 complete installation of enhanced landfill gas control systems.
8. By October 29, 1999 complete installation of the "boulder field" gas collection & treatment system. Work on this system will commence on Monday, October 4, 1999 and will continue at an approximate rate of completion of 100 feet per day until completion.

As we explained in the meeting, DEM will be asking our Technical Assistance Contractor to oversee field activities and supplement our technical review of the plans and proposals required under this plan. The contractor will also be conducting an independent evaluation of the use of alternative cover materials including, but not limited to, Auto Shredder Residue and Recovermat. We are asking for an independent professional evaluation of the suitability of these materials as daily cover material and an analysis of the application and effectiveness of these materials at your facility.

With respect to the problems attributed to ENSR, please be advised that we are sympathetic to the timelines imposed by the Consent Order entered between EPA and RIRRC and the penalties associated with non-compliance with that agreement. We do, however, hold RIRRC ultimately responsible for the performance of your contractor, ENSR. We are also disappointed that EPA, and its on-site contractor Metcalf and Eddy, did not identify the potential problems created in the expedited efforts to meet these deadlines. We have communicated these issues to EPA and will continue to discuss the timelines with them. As discussed, we intend to have our technical assistance contractor, Fuss and O'Neil to coordinate its efforts with Metcalf & Eddy to avoid any duplication of oversight to the extent possible.

These are critical response measures that must be implemented under the timelines listed above. In addition, we expect the vegetation at the facility to be completely re-established during the spring of 2000. Also an assessment of the impacts of sedimentation to Cedar Swamp Brook and the Simmonsville Reservoirs must be conducted, a written report on that assessment must be submitted no later than January 15, 2000.

As I mentioned in my opening remarks at yesterday's meeting, we must make efforts to break the cycle of compliance followed by non-compliance at the facility. We are open to continued discussions on ways to establish a more productive and effective relationship between our two agencies that will result in meeting our mutual objectives of a safe facility operating on good terms with the surrounding community.

Please feel free to call me if you have any issues on this matter.

Sincerely,

Jan H. Reitsma
Director

cc: Lincoln Almond, Governor