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SDMS DocID 000222446 FEDERAL ON-SCENE COORDINATOR'S REPORT NOVEMBER 16, 1995 Hatheway & Patterson Company Site Mansfield, Bristol County, Massachusetts (December 1993 - September 1995) Frank Gardner On-Scene Coordinator (OSC) Site Evaluation and Response Section II
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Page 1: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

SDMS DocID 000222446

FEDERAL ON-SCENE COORDINATORS REPORT

NOVEMBER 16 1995

Hatheway amp Patterson Company Site

Mansfield Bristol County Massachusetts

(December 1993 - September 1995)

Frank Gardner

On-Scene Coordinator (OSC)

Site Evaluation and Response Section II

I EXECUTIVE SUMMARY

The Hatheway amp Patterson Company Inc Site (Site) is a former wood treating facility located in Mansfield Massachusetts Wood treatment processes at the facility used various hazardous substances including arsenic chromium copper and pentachlorophenol (PCP) Historical practices of storing treated lumber on bare ground caused soils to be contaminated with these constituents When the company ceased operations due to bankruptcy in 1993 tanks vessels and pipelines containing hazardous substances were abandoned at the Site

Activities conducted during the removal action primarily consisted of the removal of bulk chemicals for off-site disposal and addressing soil contamination Disposal options used included re-use neutralization treatment incineration and landfilling Extensive surface soil sampling was conducted to determine the lateral extent of contamination Contact threats associated with contaminated surface soils were eliminated by the installation of a gravelasphalt cover

In August 1995 EPA issued a press release to the media summarizing the work completed at the Site and future plans In response several articles appeared in area newspapers documenting EPAs accomplishments in cleaning up the Site Since subsurface contamination remains at the Site The Massachusetts Dept of Environmental Protection (MADEP) will continue to address the Site providing long-term monitoring and care

II SITE DESCRIPTION AND BACKGROUND

A Site Description

The Site is located at 15 County Street in Mansfield Massachusetts in a mixed residentialindustrial area Hatheway and Patterson Company Inc operated a wood treatment facility at the Site beginning in 1953 The company ceased operations in April 1993 after having filed for bankruptcy in February 1993

The Site is comprised of approximately 40 acres and is bisected by the Rumford River and a Consolidated Railways rail line Located on site are a number of process buildings a laboratory three drip pads and several support buildings The process buildings contained tanks vessels sumps drums and various small containers Most of the tanks vessels and pipelines contained wood-treating chemicals and sumps contained water and sludge from the former wood treatment processes Also located around the Site are several areas of bare ground formerly used for storage of treated lumber Aboveground tanks present at the Site included three tanks of pentachlorophenol (PCP) one tank of fuel oil and three tanks of a fire retardant solution Six underground tanks were found containing various process wastes

The Site Identifier is X3 and the CERCLIS ID is MAD001060805

B Background

According to historical information obtained at the time of mobilization Hatheway and Patterson Company Inc began wood treating operations at the Site in 1953 utilizing a solution of PCP in fuel oil as well as creosote to treat lumber However information gathered while on site suggests that the business has been in operation since 1927 From 1958 to 1974 solutions of PCP in fuel oil and fluoro-chromeshyarsenate-phenol salts in water were both employed From 1960 to 1984 PCP in mineral spirits was also used From 1974 to 1984 the treatment process used PCP in fuel oil and chromated copper-arsenate (CCA) salts in water Beginning in 1984 and continuing through closure in 1993 solutions of CCA salts in water and PCP in water were utilized at the Site

Prior to utilizing the pressure treatment process Hatheway and Patterson Company Inc allowed wood-treating chemicals to drip off treated lumber onto underlying soils This practice caused surface soils to be contaminated with copper chromium arsenic PCP and creosote constituents in various areas of the Site In 1992 EPAs RCRA Program personnel conducted inspections at Hatheway and Patterson Company Incs facility to determine compliance with RCRA drip pad standards It was observed during subsequent RCRA inspections that drip pads were not in compliance In addition Hatheway and Patterson Company Inc did not possess appropriate documentation and certification for the drip pads

The Massachusetts Dept of Environmental Protection (MADEP) has been involved with the Site since 1972 when oil seeping out of the ground at the Site formed a tar mat on the banks of the Rumford River MADEP required Hatheway and Patterson to conduct a series of interim remedial measures and subsurface investigations These efforts ceased in early 1993 when the facility shut down MADEP is now the lead agency for the long-term monitoring and care of the Site

On June 22 1993 EPA began a Preliminary AssessmentSite Investigation (PASI) at the Site The site investigation was conducted at the request of EPA personnel from the Resource Conservation and Recovery Act (RCRA) program subsequent to the companys declaration of bankruptcy and closure in April 1993 In addition the MADEP expressed concerns about the Site due to soil and ground water contamination and the potential release of wood treatment chemicals The Site was found to be abandoned and without electricity or heat Severe winter weather conditions capable of freezing the liquids stored on site posed a threat of release via bursting pipes and tanks The PASI was closed on August 5 1993 and a removal action was recommended Based on the results of the PASI EPA Acting Regional Administrator Paul Keough signed an Action Memorandum on December 3 1993 authorizing $1998000 to mitigate the threats to public health and the environment posed by the $ite The removal action was initiated on December 7 1993 Due to extreme weather conditions during the winter of 1993-1994 and difficulties

encountered (and eventually resolved) in properly disposing of dioxin-containing wastes the removal action took more than one year to complete Therefore a request for a 1-year exemption was approved by EPA Acting Regional Administrator Patricia Meaney on December 30 1994

HI CHRONOLOGY OF EVENTS

Tuesday 23 November 1993

EPA OSC Lisa Danek Burke EPA Enforcement Coordinator Mary Dever EPA Site Investigator (SI) Mary Ellen Stanton and Roy F Weston Inc TAT member Timothy Jones arrived at the Site and met with Lt Joseph Sarro (Mansfield Fire Department) Dick Lewis (Mansfield Conservation Committee) Scott Leite (Mansfield Health Department) and Andrea Papadopoulos Richard Packard Gregg Hunt Mark Begley and Len Pinaud of the MADEP Southeastern Region

A perimeter site walk and inspection was conducted by all personnel An entry into the buildings was conducted by OSC Danek Burke and TAT member Jones Air monitoring was conducted at that time and an inventory of tanks and drums located throughout the Site was performed

Tuesday 7 December 1993 through Friday 10 December 1993

OSC Danek Burke and TAT member Zoe Cordon arrived at the Mansfield Fire Station to pick up site keys OSC Danek Burke and TAT member Conlon met OHM Remediation Services Inc (OHM) Response Manager (RM) William Tallman and Foreman (FM) Patrick Ball at the Site A site walk and inspection was conducted OSC Danek Burke and RM Tallman decided to set up the command post in the Hatheway and Patterson Company Inc Office Building Plans for arranging electricity and phone service into the Office Building were discussed

The Emergency Response Cleanup Services (ERCS) contractor OHM personnel began cleaning out the office area An OHM decontamination trailer and portable toilets arrived on site Telephone jacks and electric meters were installed at the Site A subcontract was awarded to Burns Security Service to provide site security during all non-working hours

ERCS personnel began construction of the mobile contamination reduction zone (CRZ) trailer This unit would be transported to appropriate areas of the Site as work progressed TAT member Conlon reviewed the site health and safety plan (HASP) with OSC Danek Burke and RM Tallman and received comments to be incorporated into the HASP

Monday 13 December 1993 through Friday 17 December 1993

Construction of the mobile CRZ continued The former president of the Hatheway and Patterson Company Inc William Haynes was contacted with regard to the contents of different colored pipes as well as various tanks located throughout the Site On 13 December 1993 it was discovered that two pipes had cracked in the Cylinder No 03 Building and the contents of the pipes had leaked into a sump inside the building

OSC Danek Burke TAT member Conlon RM Tallman and FM Ball entered the Cylinder No 01 amp 02 Building to ensure that all valves were turned off

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrman developed an air monitoring program for work around the Site

William Haynes arrived on site and conducted a site walk of the facility with OSC Danek Burke RM Tallman TAT member Conlon and HSO Mohrman Mr Haynes provided information about the former wood treatment process as well as the contents of many of the tanks

The west side of the Cylinder No 03 Building was sealed up with plywood to reduce the wind chill factor in the building The building walls had been torn out by others to remove a pressure vessel prior to the removal action MADEP representatives Julie Hutcheson and Len Pinaud arrived on site for a site walk and an update of recent removal activities

Sampling of the bulk Dricon (a fire retardant) in Tank Nos 01 02 and 04 was completed The samples were packaged and shipped via Federal Express to the manufacturer (Hickson Corporation) in Conley Georgia The samples were submitted to evaluate the possible reuse of the Dricon by the Hickson Corporation

Monday 20 December 1993 through Wednesday 22 December 1993

Two Massachusetts wood treaters were contacted regarding the possibility of accepting the dilute CCA contained in Tank Nos 17 19 20 and 21 for use in their wood treatment processes

The ERCS crew cleaned out the Mill Building for future staging of miscellaneous drums and small containers Construction of a berm along the eastern side of the CCA drip pad was completed in an attempt to prevent rain water from entering into an outside sump The OHM sample technician (ST) continued to log in all remaining tanks and determine the volume of material contained in each

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

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labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

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IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

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Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

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Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 2: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

I EXECUTIVE SUMMARY

The Hatheway amp Patterson Company Inc Site (Site) is a former wood treating facility located in Mansfield Massachusetts Wood treatment processes at the facility used various hazardous substances including arsenic chromium copper and pentachlorophenol (PCP) Historical practices of storing treated lumber on bare ground caused soils to be contaminated with these constituents When the company ceased operations due to bankruptcy in 1993 tanks vessels and pipelines containing hazardous substances were abandoned at the Site

Activities conducted during the removal action primarily consisted of the removal of bulk chemicals for off-site disposal and addressing soil contamination Disposal options used included re-use neutralization treatment incineration and landfilling Extensive surface soil sampling was conducted to determine the lateral extent of contamination Contact threats associated with contaminated surface soils were eliminated by the installation of a gravelasphalt cover

In August 1995 EPA issued a press release to the media summarizing the work completed at the Site and future plans In response several articles appeared in area newspapers documenting EPAs accomplishments in cleaning up the Site Since subsurface contamination remains at the Site The Massachusetts Dept of Environmental Protection (MADEP) will continue to address the Site providing long-term monitoring and care

II SITE DESCRIPTION AND BACKGROUND

A Site Description

The Site is located at 15 County Street in Mansfield Massachusetts in a mixed residentialindustrial area Hatheway and Patterson Company Inc operated a wood treatment facility at the Site beginning in 1953 The company ceased operations in April 1993 after having filed for bankruptcy in February 1993

The Site is comprised of approximately 40 acres and is bisected by the Rumford River and a Consolidated Railways rail line Located on site are a number of process buildings a laboratory three drip pads and several support buildings The process buildings contained tanks vessels sumps drums and various small containers Most of the tanks vessels and pipelines contained wood-treating chemicals and sumps contained water and sludge from the former wood treatment processes Also located around the Site are several areas of bare ground formerly used for storage of treated lumber Aboveground tanks present at the Site included three tanks of pentachlorophenol (PCP) one tank of fuel oil and three tanks of a fire retardant solution Six underground tanks were found containing various process wastes

The Site Identifier is X3 and the CERCLIS ID is MAD001060805

B Background

According to historical information obtained at the time of mobilization Hatheway and Patterson Company Inc began wood treating operations at the Site in 1953 utilizing a solution of PCP in fuel oil as well as creosote to treat lumber However information gathered while on site suggests that the business has been in operation since 1927 From 1958 to 1974 solutions of PCP in fuel oil and fluoro-chromeshyarsenate-phenol salts in water were both employed From 1960 to 1984 PCP in mineral spirits was also used From 1974 to 1984 the treatment process used PCP in fuel oil and chromated copper-arsenate (CCA) salts in water Beginning in 1984 and continuing through closure in 1993 solutions of CCA salts in water and PCP in water were utilized at the Site

Prior to utilizing the pressure treatment process Hatheway and Patterson Company Inc allowed wood-treating chemicals to drip off treated lumber onto underlying soils This practice caused surface soils to be contaminated with copper chromium arsenic PCP and creosote constituents in various areas of the Site In 1992 EPAs RCRA Program personnel conducted inspections at Hatheway and Patterson Company Incs facility to determine compliance with RCRA drip pad standards It was observed during subsequent RCRA inspections that drip pads were not in compliance In addition Hatheway and Patterson Company Inc did not possess appropriate documentation and certification for the drip pads

The Massachusetts Dept of Environmental Protection (MADEP) has been involved with the Site since 1972 when oil seeping out of the ground at the Site formed a tar mat on the banks of the Rumford River MADEP required Hatheway and Patterson to conduct a series of interim remedial measures and subsurface investigations These efforts ceased in early 1993 when the facility shut down MADEP is now the lead agency for the long-term monitoring and care of the Site

On June 22 1993 EPA began a Preliminary AssessmentSite Investigation (PASI) at the Site The site investigation was conducted at the request of EPA personnel from the Resource Conservation and Recovery Act (RCRA) program subsequent to the companys declaration of bankruptcy and closure in April 1993 In addition the MADEP expressed concerns about the Site due to soil and ground water contamination and the potential release of wood treatment chemicals The Site was found to be abandoned and without electricity or heat Severe winter weather conditions capable of freezing the liquids stored on site posed a threat of release via bursting pipes and tanks The PASI was closed on August 5 1993 and a removal action was recommended Based on the results of the PASI EPA Acting Regional Administrator Paul Keough signed an Action Memorandum on December 3 1993 authorizing $1998000 to mitigate the threats to public health and the environment posed by the $ite The removal action was initiated on December 7 1993 Due to extreme weather conditions during the winter of 1993-1994 and difficulties

encountered (and eventually resolved) in properly disposing of dioxin-containing wastes the removal action took more than one year to complete Therefore a request for a 1-year exemption was approved by EPA Acting Regional Administrator Patricia Meaney on December 30 1994

HI CHRONOLOGY OF EVENTS

Tuesday 23 November 1993

EPA OSC Lisa Danek Burke EPA Enforcement Coordinator Mary Dever EPA Site Investigator (SI) Mary Ellen Stanton and Roy F Weston Inc TAT member Timothy Jones arrived at the Site and met with Lt Joseph Sarro (Mansfield Fire Department) Dick Lewis (Mansfield Conservation Committee) Scott Leite (Mansfield Health Department) and Andrea Papadopoulos Richard Packard Gregg Hunt Mark Begley and Len Pinaud of the MADEP Southeastern Region

A perimeter site walk and inspection was conducted by all personnel An entry into the buildings was conducted by OSC Danek Burke and TAT member Jones Air monitoring was conducted at that time and an inventory of tanks and drums located throughout the Site was performed

Tuesday 7 December 1993 through Friday 10 December 1993

OSC Danek Burke and TAT member Zoe Cordon arrived at the Mansfield Fire Station to pick up site keys OSC Danek Burke and TAT member Conlon met OHM Remediation Services Inc (OHM) Response Manager (RM) William Tallman and Foreman (FM) Patrick Ball at the Site A site walk and inspection was conducted OSC Danek Burke and RM Tallman decided to set up the command post in the Hatheway and Patterson Company Inc Office Building Plans for arranging electricity and phone service into the Office Building were discussed

The Emergency Response Cleanup Services (ERCS) contractor OHM personnel began cleaning out the office area An OHM decontamination trailer and portable toilets arrived on site Telephone jacks and electric meters were installed at the Site A subcontract was awarded to Burns Security Service to provide site security during all non-working hours

ERCS personnel began construction of the mobile contamination reduction zone (CRZ) trailer This unit would be transported to appropriate areas of the Site as work progressed TAT member Conlon reviewed the site health and safety plan (HASP) with OSC Danek Burke and RM Tallman and received comments to be incorporated into the HASP

Monday 13 December 1993 through Friday 17 December 1993

Construction of the mobile CRZ continued The former president of the Hatheway and Patterson Company Inc William Haynes was contacted with regard to the contents of different colored pipes as well as various tanks located throughout the Site On 13 December 1993 it was discovered that two pipes had cracked in the Cylinder No 03 Building and the contents of the pipes had leaked into a sump inside the building

OSC Danek Burke TAT member Conlon RM Tallman and FM Ball entered the Cylinder No 01 amp 02 Building to ensure that all valves were turned off

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrman developed an air monitoring program for work around the Site

William Haynes arrived on site and conducted a site walk of the facility with OSC Danek Burke RM Tallman TAT member Conlon and HSO Mohrman Mr Haynes provided information about the former wood treatment process as well as the contents of many of the tanks

The west side of the Cylinder No 03 Building was sealed up with plywood to reduce the wind chill factor in the building The building walls had been torn out by others to remove a pressure vessel prior to the removal action MADEP representatives Julie Hutcheson and Len Pinaud arrived on site for a site walk and an update of recent removal activities

Sampling of the bulk Dricon (a fire retardant) in Tank Nos 01 02 and 04 was completed The samples were packaged and shipped via Federal Express to the manufacturer (Hickson Corporation) in Conley Georgia The samples were submitted to evaluate the possible reuse of the Dricon by the Hickson Corporation

Monday 20 December 1993 through Wednesday 22 December 1993

Two Massachusetts wood treaters were contacted regarding the possibility of accepting the dilute CCA contained in Tank Nos 17 19 20 and 21 for use in their wood treatment processes

The ERCS crew cleaned out the Mill Building for future staging of miscellaneous drums and small containers Construction of a berm along the eastern side of the CCA drip pad was completed in an attempt to prevent rain water from entering into an outside sump The OHM sample technician (ST) continued to log in all remaining tanks and determine the volume of material contained in each

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

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labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

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IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

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Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

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Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 3: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

B Background

According to historical information obtained at the time of mobilization Hatheway and Patterson Company Inc began wood treating operations at the Site in 1953 utilizing a solution of PCP in fuel oil as well as creosote to treat lumber However information gathered while on site suggests that the business has been in operation since 1927 From 1958 to 1974 solutions of PCP in fuel oil and fluoro-chromeshyarsenate-phenol salts in water were both employed From 1960 to 1984 PCP in mineral spirits was also used From 1974 to 1984 the treatment process used PCP in fuel oil and chromated copper-arsenate (CCA) salts in water Beginning in 1984 and continuing through closure in 1993 solutions of CCA salts in water and PCP in water were utilized at the Site

Prior to utilizing the pressure treatment process Hatheway and Patterson Company Inc allowed wood-treating chemicals to drip off treated lumber onto underlying soils This practice caused surface soils to be contaminated with copper chromium arsenic PCP and creosote constituents in various areas of the Site In 1992 EPAs RCRA Program personnel conducted inspections at Hatheway and Patterson Company Incs facility to determine compliance with RCRA drip pad standards It was observed during subsequent RCRA inspections that drip pads were not in compliance In addition Hatheway and Patterson Company Inc did not possess appropriate documentation and certification for the drip pads

The Massachusetts Dept of Environmental Protection (MADEP) has been involved with the Site since 1972 when oil seeping out of the ground at the Site formed a tar mat on the banks of the Rumford River MADEP required Hatheway and Patterson to conduct a series of interim remedial measures and subsurface investigations These efforts ceased in early 1993 when the facility shut down MADEP is now the lead agency for the long-term monitoring and care of the Site

On June 22 1993 EPA began a Preliminary AssessmentSite Investigation (PASI) at the Site The site investigation was conducted at the request of EPA personnel from the Resource Conservation and Recovery Act (RCRA) program subsequent to the companys declaration of bankruptcy and closure in April 1993 In addition the MADEP expressed concerns about the Site due to soil and ground water contamination and the potential release of wood treatment chemicals The Site was found to be abandoned and without electricity or heat Severe winter weather conditions capable of freezing the liquids stored on site posed a threat of release via bursting pipes and tanks The PASI was closed on August 5 1993 and a removal action was recommended Based on the results of the PASI EPA Acting Regional Administrator Paul Keough signed an Action Memorandum on December 3 1993 authorizing $1998000 to mitigate the threats to public health and the environment posed by the $ite The removal action was initiated on December 7 1993 Due to extreme weather conditions during the winter of 1993-1994 and difficulties

encountered (and eventually resolved) in properly disposing of dioxin-containing wastes the removal action took more than one year to complete Therefore a request for a 1-year exemption was approved by EPA Acting Regional Administrator Patricia Meaney on December 30 1994

HI CHRONOLOGY OF EVENTS

Tuesday 23 November 1993

EPA OSC Lisa Danek Burke EPA Enforcement Coordinator Mary Dever EPA Site Investigator (SI) Mary Ellen Stanton and Roy F Weston Inc TAT member Timothy Jones arrived at the Site and met with Lt Joseph Sarro (Mansfield Fire Department) Dick Lewis (Mansfield Conservation Committee) Scott Leite (Mansfield Health Department) and Andrea Papadopoulos Richard Packard Gregg Hunt Mark Begley and Len Pinaud of the MADEP Southeastern Region

A perimeter site walk and inspection was conducted by all personnel An entry into the buildings was conducted by OSC Danek Burke and TAT member Jones Air monitoring was conducted at that time and an inventory of tanks and drums located throughout the Site was performed

Tuesday 7 December 1993 through Friday 10 December 1993

OSC Danek Burke and TAT member Zoe Cordon arrived at the Mansfield Fire Station to pick up site keys OSC Danek Burke and TAT member Conlon met OHM Remediation Services Inc (OHM) Response Manager (RM) William Tallman and Foreman (FM) Patrick Ball at the Site A site walk and inspection was conducted OSC Danek Burke and RM Tallman decided to set up the command post in the Hatheway and Patterson Company Inc Office Building Plans for arranging electricity and phone service into the Office Building were discussed

The Emergency Response Cleanup Services (ERCS) contractor OHM personnel began cleaning out the office area An OHM decontamination trailer and portable toilets arrived on site Telephone jacks and electric meters were installed at the Site A subcontract was awarded to Burns Security Service to provide site security during all non-working hours

ERCS personnel began construction of the mobile contamination reduction zone (CRZ) trailer This unit would be transported to appropriate areas of the Site as work progressed TAT member Conlon reviewed the site health and safety plan (HASP) with OSC Danek Burke and RM Tallman and received comments to be incorporated into the HASP

Monday 13 December 1993 through Friday 17 December 1993

Construction of the mobile CRZ continued The former president of the Hatheway and Patterson Company Inc William Haynes was contacted with regard to the contents of different colored pipes as well as various tanks located throughout the Site On 13 December 1993 it was discovered that two pipes had cracked in the Cylinder No 03 Building and the contents of the pipes had leaked into a sump inside the building

OSC Danek Burke TAT member Conlon RM Tallman and FM Ball entered the Cylinder No 01 amp 02 Building to ensure that all valves were turned off

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrman developed an air monitoring program for work around the Site

William Haynes arrived on site and conducted a site walk of the facility with OSC Danek Burke RM Tallman TAT member Conlon and HSO Mohrman Mr Haynes provided information about the former wood treatment process as well as the contents of many of the tanks

The west side of the Cylinder No 03 Building was sealed up with plywood to reduce the wind chill factor in the building The building walls had been torn out by others to remove a pressure vessel prior to the removal action MADEP representatives Julie Hutcheson and Len Pinaud arrived on site for a site walk and an update of recent removal activities

Sampling of the bulk Dricon (a fire retardant) in Tank Nos 01 02 and 04 was completed The samples were packaged and shipped via Federal Express to the manufacturer (Hickson Corporation) in Conley Georgia The samples were submitted to evaluate the possible reuse of the Dricon by the Hickson Corporation

Monday 20 December 1993 through Wednesday 22 December 1993

Two Massachusetts wood treaters were contacted regarding the possibility of accepting the dilute CCA contained in Tank Nos 17 19 20 and 21 for use in their wood treatment processes

The ERCS crew cleaned out the Mill Building for future staging of miscellaneous drums and small containers Construction of a berm along the eastern side of the CCA drip pad was completed in an attempt to prevent rain water from entering into an outside sump The OHM sample technician (ST) continued to log in all remaining tanks and determine the volume of material contained in each

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

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labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

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IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

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Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

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Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

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Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 4: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

encountered (and eventually resolved) in properly disposing of dioxin-containing wastes the removal action took more than one year to complete Therefore a request for a 1-year exemption was approved by EPA Acting Regional Administrator Patricia Meaney on December 30 1994

HI CHRONOLOGY OF EVENTS

Tuesday 23 November 1993

EPA OSC Lisa Danek Burke EPA Enforcement Coordinator Mary Dever EPA Site Investigator (SI) Mary Ellen Stanton and Roy F Weston Inc TAT member Timothy Jones arrived at the Site and met with Lt Joseph Sarro (Mansfield Fire Department) Dick Lewis (Mansfield Conservation Committee) Scott Leite (Mansfield Health Department) and Andrea Papadopoulos Richard Packard Gregg Hunt Mark Begley and Len Pinaud of the MADEP Southeastern Region

A perimeter site walk and inspection was conducted by all personnel An entry into the buildings was conducted by OSC Danek Burke and TAT member Jones Air monitoring was conducted at that time and an inventory of tanks and drums located throughout the Site was performed

Tuesday 7 December 1993 through Friday 10 December 1993

OSC Danek Burke and TAT member Zoe Cordon arrived at the Mansfield Fire Station to pick up site keys OSC Danek Burke and TAT member Conlon met OHM Remediation Services Inc (OHM) Response Manager (RM) William Tallman and Foreman (FM) Patrick Ball at the Site A site walk and inspection was conducted OSC Danek Burke and RM Tallman decided to set up the command post in the Hatheway and Patterson Company Inc Office Building Plans for arranging electricity and phone service into the Office Building were discussed

The Emergency Response Cleanup Services (ERCS) contractor OHM personnel began cleaning out the office area An OHM decontamination trailer and portable toilets arrived on site Telephone jacks and electric meters were installed at the Site A subcontract was awarded to Burns Security Service to provide site security during all non-working hours

ERCS personnel began construction of the mobile contamination reduction zone (CRZ) trailer This unit would be transported to appropriate areas of the Site as work progressed TAT member Conlon reviewed the site health and safety plan (HASP) with OSC Danek Burke and RM Tallman and received comments to be incorporated into the HASP

Monday 13 December 1993 through Friday 17 December 1993

Construction of the mobile CRZ continued The former president of the Hatheway and Patterson Company Inc William Haynes was contacted with regard to the contents of different colored pipes as well as various tanks located throughout the Site On 13 December 1993 it was discovered that two pipes had cracked in the Cylinder No 03 Building and the contents of the pipes had leaked into a sump inside the building

OSC Danek Burke TAT member Conlon RM Tallman and FM Ball entered the Cylinder No 01 amp 02 Building to ensure that all valves were turned off

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrman developed an air monitoring program for work around the Site

William Haynes arrived on site and conducted a site walk of the facility with OSC Danek Burke RM Tallman TAT member Conlon and HSO Mohrman Mr Haynes provided information about the former wood treatment process as well as the contents of many of the tanks

The west side of the Cylinder No 03 Building was sealed up with plywood to reduce the wind chill factor in the building The building walls had been torn out by others to remove a pressure vessel prior to the removal action MADEP representatives Julie Hutcheson and Len Pinaud arrived on site for a site walk and an update of recent removal activities

Sampling of the bulk Dricon (a fire retardant) in Tank Nos 01 02 and 04 was completed The samples were packaged and shipped via Federal Express to the manufacturer (Hickson Corporation) in Conley Georgia The samples were submitted to evaluate the possible reuse of the Dricon by the Hickson Corporation

Monday 20 December 1993 through Wednesday 22 December 1993

Two Massachusetts wood treaters were contacted regarding the possibility of accepting the dilute CCA contained in Tank Nos 17 19 20 and 21 for use in their wood treatment processes

The ERCS crew cleaned out the Mill Building for future staging of miscellaneous drums and small containers Construction of a berm along the eastern side of the CCA drip pad was completed in an attempt to prevent rain water from entering into an outside sump The OHM sample technician (ST) continued to log in all remaining tanks and determine the volume of material contained in each

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

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OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 5: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 13 December 1993 through Friday 17 December 1993

Construction of the mobile CRZ continued The former president of the Hatheway and Patterson Company Inc William Haynes was contacted with regard to the contents of different colored pipes as well as various tanks located throughout the Site On 13 December 1993 it was discovered that two pipes had cracked in the Cylinder No 03 Building and the contents of the pipes had leaked into a sump inside the building

OSC Danek Burke TAT member Conlon RM Tallman and FM Ball entered the Cylinder No 01 amp 02 Building to ensure that all valves were turned off

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrman developed an air monitoring program for work around the Site

William Haynes arrived on site and conducted a site walk of the facility with OSC Danek Burke RM Tallman TAT member Conlon and HSO Mohrman Mr Haynes provided information about the former wood treatment process as well as the contents of many of the tanks

The west side of the Cylinder No 03 Building was sealed up with plywood to reduce the wind chill factor in the building The building walls had been torn out by others to remove a pressure vessel prior to the removal action MADEP representatives Julie Hutcheson and Len Pinaud arrived on site for a site walk and an update of recent removal activities

Sampling of the bulk Dricon (a fire retardant) in Tank Nos 01 02 and 04 was completed The samples were packaged and shipped via Federal Express to the manufacturer (Hickson Corporation) in Conley Georgia The samples were submitted to evaluate the possible reuse of the Dricon by the Hickson Corporation

Monday 20 December 1993 through Wednesday 22 December 1993

Two Massachusetts wood treaters were contacted regarding the possibility of accepting the dilute CCA contained in Tank Nos 17 19 20 and 21 for use in their wood treatment processes

The ERCS crew cleaned out the Mill Building for future staging of miscellaneous drums and small containers Construction of a berm along the eastern side of the CCA drip pad was completed in an attempt to prevent rain water from entering into an outside sump The OHM sample technician (ST) continued to log in all remaining tanks and determine the volume of material contained in each

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

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OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

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the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

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Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 6: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 27 December 1993 through Friday 31 December 1993

EMI electricians hooked up electric heaters to the mobile CRZ unit completing its construction Electric heaters were placed in both the Cylinder No 01 amp 02 Building and the Cylinder No 03 Building to prevent the freezing of solution remaining in pipes and tanks

OSC Danek Burke continued to investigate the possibility of sending dilute CCA to a wood treater for re-use Northeast Wood Treaters in Belchertown MA was the most likely candidate Samples would be sent to an outside laboratory to be analyzed for chromium copper and arsenic to determine the ratio of these components in solution and verify whether the solutions could be re-used Upon acceptance Northeast Wood Treaters could initially take 15000 gallons of the CCA solution use that over a period of approximately a week and would then take the remainder of the solution

The ERCS crew continued to wrap the pipes on tanks located outside with heat tape the ST continued to map pipes connecting the various tanks on site The CCA drip pad was reshycovered with polyethylene after winds blew some of it off over the weekend Due to cold temperatures electric heat tape was wrapped around exposed pipes leading from the Dricon tanks in anticipation of Mansfield Electric Company turning on power to that portion of the Site Materials to be lab-packed and all drums from around the Site were staged in the Mill Building

A kerosene salamander heater which was being used to warm the pipes leading from Tank Nos 06 and 07 malfunctioned and the pipe insulation as well as the heater caught fire The fire on the insulation was easily extinguished however the heater continued to burn The fire burning the salamander heater required the use of a fire extinguisher

On 29 December 1993 the site fire alarm sounded at approximately 1115 hours This was a false alarm caused by OHM employee who accidently hit the fire alarm box in the Cylinder No 01 amp 02 Building The fire department responded in less than five minutes By 1130 hours the fire department was off site and work resumed

OSC Danek Burke and FM Ball discovered a broken water pipe in the Cylinder No 03 Building It was thought that the water had been turned off on 14 December 1993 but apparently was not The Mansfield Water Department (MWD) was contacted and they arrived at the Site The MWD crimped the leaking pipe as a temporary solution to the problem until the water main could be located and shut off

Heavy snow which covered the parking lot was plowed using the Bobcat Attempts were made by the MWD to locate the water main but they were unsuccessful RM Tallman and OSC Danek Burke decided to aerate the Dricon solution in Tanks Nos 02 and 04 and the dilute Duratreet (PCP) solution in Tanks Nos 06 and 07 Aeration of the solutions was performed in an attempt to prevent them from freezing

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

10

Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

11

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 7: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

A ST and two Removal Technicians (RTs) worked to prepare a piece of PVC piping to be used for tank aeration Aeration systems were installed in Tank Nos 02 and 04 (containing Dricon) as well as Tank Nos 06 and 07 (containing PCP) Shortly after beginning the aeration Tank Nos 06 and 07 foamed over The aeration was immediately terminated and OSC Danek Burke was notified ERGS personnel then cleaned up the spill All spilled material was confined to the containment area and then transferred to 5 5-gallon drums and staged in the Mill Building to await disposal

Monday 3 January 1994 through Friday 7 January 1994

The search for miscellaneous drums and small containers around the Site was completed Julie Hutcheson of MADEP arrived at the Site to obtain an update of site activities Bid packages for analytical work were distributed to laboratories by OHM via Federal Express

A steam generator was mobilized and set up High pressure hoses were placed into Tank Nos 06 and 07 with warm water flowing through the hoses This method proved effective in preventing the tanks from freezing Snow removal operations continued on site RM Joe Coleman who would temporarily replace RM Tallman the following week arrived on site to familiarize himself with site activities

Monday 10 January 1994 through Friday 14 January 1994

ERCS personnel began tagging pipe lines in the process buildings on site in preparation for line purging Two additional ERCS crew members FM Dave Nock and RT Dennis OKoye arrived on site OSC Danek Burke and TAT member Cordon attended a meeting with the Mansfield Fire and Police Departments OSC Danek Burke explained the layout of the Site and the location of the various tanks and their contents The material safety data sheets (MSDS) for materials present on site were reviewed

Four of the six analytical laboratories (solicited previously) submitted their bids for sample analysis IEA laboratory of Billerica Massachusetts was the lowest qualified bidder

OHM personnel removed the electric heat tape from the pipes in the Dricon area and completed purging the Dricon pipe lines The mobile CRZ was moved adjacent to the Cylinder No 03 Building Line purging began in the Cylinder No 03 Building

Monday 17 January 1994 through Friday 21 January 1994

RM Tallman arrived back on site RM Coleman remained to update RM Tallman on the previous weeks activities OHM personnel completed purging tank lines in the Cylinder No 03 Building Fifty polyethylene and 50 steel drums were delivered

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 8: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Five samples of the CCA solution were collected from Tank Nos 17 through 21 located in the Cylinder No 03 Building for total metals analysis Samples were packaged and sent to IEA Laboratories in Billerica Massachusetts

Monday 24 January 1994 through Friday 28 January 1994

The mobile CRZ was moved adjacent to the Cylinder No 01 amp 02 Building in anticipation of line purging Line purging began in the Cylinder No 01 amp 02 Building and was completed by the end of the week

Monday 31 January 1994 through Friday 4 February 1994

ERCS personnel cleaned out Tank No 25 (See Figure 2 - Site Diagram) located south of the railroad tracks The contents were placed in one 55-gallon drum

OSC Danek Burke and TAT member Conlon visited Northeast Wood Treaters in Belchertown Massachusetts The President of the company David Reed provided a tour of the facility Mr Reed had agreed to take the dilute CCA solution which was located in the Cylinder No 03 Building (-40000 gallons)

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution into the publicly owned treatment facility The WWTP had specific requirements which had to be met before water could be discharged from the Site

OHM personnel completed cleaning out the liquid from Tank No 23 located in the Cylinder No 03 Building The contents were placed into 23 55-gallon drums A manhole was cut to allow access to Tank No 29 in the Cylinder No 01 amp 02 Building Cleaning of Tank Nos 29 12a and 12b continued The data package for the metals analyses of the dilute CCA samples was received by OHM from IEA Laboratories

Monday 7 February 1994 through Friday 11 February 1994

Mike Hoye and Greg Forest from General Chemical arrived on site to labpack small containers Labpacking was completed by 1400 hours and the containers were transported off site to the ENSCO Inc disposal facility located in El Dorado Arkansas

OHM personnel continued to clean out Tank No 29 in the Cylinder No 01 amp 02 Building By the end of the week sludge removal from Tank No 29 was completed One additional ST was mobilized to the Site

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

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Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

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Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

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OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

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Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 9: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Eight samples were collected for wastewater analysis from Tank Nos 01 02 04 09 10 11 22 and 26 respectively The samples were delivered to IEA Laboratories in Billerica MA The analysis was required to determine if the Mansfield WWTP could accept any or all the wastewater presently on site

OHM personnel began preparing to cut Tank No 13 On 11 February 1995 all nonshyessential personnel demobilized from the Site early due to a heavy snow storm which began at approximately 0930 hours

Monday 14 February 1994 through Friday 18 February 1994

Liquid samples were collected from Tank Nos 05 06 and 07 (composite) 08 15 23 30a 30b 31 and 32 These samples were labelled packaged and submitted to IEA laboratories for disposal analyses Sludge removal began in Tank No 13 after the liquid contents were pumped out of the tank and into 55-gallon drums

OSC Danek Burke determined that all dioxin analyses (including the above-mentioned samples) would be conducted through the Contract Laboratory Program (CLP) and that the data validation would be performed at EPAs New England Regional Laboratory (NERL)

OSC Danek Burke attended a meeting at the Mansfield Town Hall Attendees included five members of the Mansfield Health Department and five members of MADEP OSC Danek Burke gave an overview of the removal progress and answered questions regarding EPAs future plans for the Site Other topics included the location of monitoring wells MADEPs assessment plans and possible future use of the property

David Simmons and Ken Hackett from the Mansfield WWTP arrived on site and conducted a site walk The OHM crew completed cleaning out Tank No 13 A total of 22 drums were generated (two liquid drums and 20 drums containing solids)

Tuesday 22 February 1994 through Friday 25 February 1994

The OHM crew completed cleaning out Tank Nos 27 and 28 generating two and four 55shygallon drums respectively Tank Nos 14 and 16 were opened and found to contain less than 2 inches of material The waste from both tanks was placed inside one 55-gallon drum

Julie Hutcheson of the MADEP arrived on site OSC Danek Burke and TAT member Conlon toured the Site with her and gave an update regarding site activities

Monday 28 February 1994 through Friday 4 March 1994

RM Coleman was on site to temporarily replace RM Tallman while he was at the Pownal Tannery Site in Pownal VT with OSC Danek Burke and other members of the ERCS crew Eight sludge and three liquid samples were collected for disposal analysis The samples were

8

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

10

Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

11

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 10: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

labelled packaged and shipped to IEA laboratories located in Billerica MA The data package for samples previously submitted (Sample Nos 13 through 20) was received from IEA laboratories

Monday 7 March 1994 through Friday 11 March 1994

Removal of material from Tank No 15 began and was completed One drum of solid waste and thirteen drums of liquid waste were generated Eight liquid and eight sludge samples were collected and submitted to a CLP laboratory for dioxin analysis Phil Aquan from the Environmental Services Assistance Team (ESAT) arrived on site to package the dioxin samples and ship them to the laboratory

A water line in the Cylinder No 01 amp 02 Building thawed and began to leak FM Ball crimped the line and contacted Ben Couture from the MWD The MWD arrived on site to delineate the location of water lines leading to the Site Excavation and the subsequent securing of the water lines was postponed until DigSafe arrived The sumps in the Cylinder No 01 amp 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed One drum containing liquids and two drums containing solids were generated

Monday 14 March 1994 through Friday 18 March 1994

The MWD arrived and proceeded to excavate a portion of County Street to turn off water service to the Cylinder No 01 amp 02 Building Due to the close proximity of the MWD crew to the Site TAT member Cordon and HSO Mohrman performed air monitoring adjacent to the excavation No results above background were detected One of the two water mains was located and shut off

Margery Adams from EPAs Office of Regional Council (ORC) informed OSC Danek Burke that the Bank of Boston did not claim ownership of any chemicals on site In addition there were no legal problems with shipping the CCA to Northeast Wood Treaters for use in their wood treating process The compliance history of Northeast Treaters was checked by the EPA RCRA program and MADEP

OHM personnel set up a high-visibility fence around the area of contaminated soil west of the CCA drip pad to restrict access to this area Soil results from the PASI revealed high levels of arsenic (gt 1000 parts per million (ppm)) The sump located in the Cylinder No 03 Building was pressure washed The liquid waste that was generated was placed into two 55shygallon drums Two bag filters were constructed in the Cylinder No 03 Building to be used to filter the dilute CCA solution prior to transporting the material to Northeast Wood Treaters Filtration of this solution is consistent with normal wood treatment operations at Hatheway amp Patterson

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

10

Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

11

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

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the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

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Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

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VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 11: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 21 March 1994 through Friday 25 March 1994

OSC Danek Burke sent (via facsimile) the Certification of Proper Use Treatment Storage or Disposal of the CCA solution to Margery Adams of EPAs ORC for review The form was correct and was sent to David Reed of Northeast Wood Treaters who agreed to sign the certification

Julie Hutcheson of the MADEP arrived on site to observe the CCA pumping operations The first shipment (4800 gallons) of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5000-gallon tanker truck OSC Danek Burke and RM Tallman escorted the first load of CCA to the facility to ensure that no problems occurred during the unloading operation

FES arrived to pick up a second load of CCA RM Tallman checked inside of the tanker and found an oily layer inside the tanker from a different FES shipment The tanker was cleaned out by OHM personnel and the contents placed into three 55-gallon polyethylene drums to be transported off site by FES FES was charged for this cleaning The second shipment (4900 gallons) of CCA was shipped to Northeast Wood Treaters

Sludge was removed from Tank No 22 and drummed Draft dioxin analytical results were received by OSC Danek Burke for review

Monday 28 March 1994 through Friday 1 April 1994

Six additional shipments of CCA solution were sent to Northeast Wood Treaters (bringing the total number of trucks to eight) The CCA solution was pumped from Tank Nos 17 19 20 and 21 into FESs 5000-gallon tanker truck(s)

The ERCS crew cleaned out the Stacker Building and drummed the debris Breathing air equipment was decontaminated

Monday 4 April 1994 through Friday 8 April 1994

No site activities were performed during the week due to operations conducted at the Pownal Tannery Site in Pownal Vermont

Monday 11 April 1994 through Friday 15 April 1994

The residual CCA liquid and sludge remaining in Tank Nos 20 and 21 was pumped into 55shygallon drums An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site

10

Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

11

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 12: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 18 April 1994 through Friday 22 April 1994

Sludge removal and drumming activities were completed from Tank Nos 17 19 20 and 21

Monday 25 April 1994 through Friday 29 April 1994

Disposal options for waste located on site (in bulk as well as drums) were discussed by EPA and OHM personnel Test bulking continued by ERGSs Chemist Tobin The ERGS crew utilized an air-powered chipping hammer to remove dried PGP-resin off of the PGP drip pad (located behind the Cylinder No 01 amp 02 Building) A different decontamination trailer arrived on site to replace the current decontamination trailer at no cost to EPA An inventory was taken of contents in the replacement trailer

Monday 2 May 1994 through Friday 6 May 1994

The removal of dried PGP-resin from the drip pad was completed and the material was placed into 55-gallon drums In addition the PCP-sump in the Cylinder No 03 Building was scraped-out and the contents placed into drums The PGP-contaminated pallets in the Cylinder No 01 amp 02 Building were cut up and drummed Decontamination of equipment began in anticipation of site demobilization

Monday 9 Mav 1994 through Friday 13 May 1994

John Gilbert and Alan Humphrey of EPAs Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994) ERTs Gilbert and Humphrey tasked the Response Engineering and Analytical Contract (REAC) team to develop a soil sampling plan for the Site On-site screening of samples was planned to better define the surficial concentrations of contaminants around the Site Moreover an assessment was planned to determine potential threats posed to individuals and the environment by exposure to the contaminated surface soil

Bulking of PGP-contaminated waste and drum logs for all drums were completed OHM personnel began to prepare for temporary demobilization

Monday 16 Mav 1994 through Friday 18 Mav 1994

OHM personnel collected additional samples from drums and tanks to be sent to Laboratory Resources for disposal analyses as requested by OHM Disposal Coordinator (DC) Tobin Temporary demobilization from the Site occurred Twenty-four hour site security was initiated

11

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 13: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Thursday 1 September 1994 through Friday 2 September 1994

EPA OSC Danek Burke RM Tallman and FM Thomas McLaughlin remobilized to the Site OSC Danek Burke reviewed the drum logs with RM Tallman and discussed upcoming disposal options A complete site walk was conducted by OSC Danek Burke and RM Tallman to assess site conditions and to identify any potential hazards that may have arisen RM Tallman began securing personnel and equipment for the remainder of the removal action FM McLaughlin proceeded to gather necessary supplies and expendables in anticipation of upcoming removal activities

Tuesday 6 September 1994 through Friday 9 September 1994

TAT member Daniel Keefe arrived on site RM Tallman continued to make arrangements to secure personnel and equipment The Region II ERGS Disposal Coordinator (DC) Michael Schubert arrived on site (during the temporary demobilization the ERCS Region I DC Tobin resigned) The replacement DC for Region I (Barry Taggart) also on arrived on site for training OSC Danek Burke TAT member Keefe and both Disposal Coordinators conducted a site walk while discussing the various waste streams present in drums and remaining in tanks on site

Based on analytical results from tanks containing wastewater OSC Danek Burke determined that shipping the wastewater off-site for treatment and disposal would be less expensive than treating it onsite and discharging it to the municipal sewer system

OHM personnel restocked the mobile CRZ (constructed previously and left on site) A decontamination trailer arrived on site the contents were inventoried by TAT member Keefe and FM McLaughlin Also arriving on site was a CAT IT-28 front-end loader OHM HSO Mike Zustra arrived to read and review the original HASP Five amendments were incorporated into the HASP as recommended The new amendments were discussed with all personnel on site

Monday 12 September 1994 through Friday 16 September 1994

ERCS personnel continued to prepare for upcoming removal operations The mobile CRZ was moved in front of the Cylinder No 03 Building adjacent to the electrical panel

EPA Managers Steve Novick Donald Berger and Nancy Barmakian arrived on site to conduct a site walk with OSC Danek Burke In addition MADEP representative Susan Benoit arrived on site to walk through the Site with OSC Danek Burke

TAT member Keefe and FM McLoughlin collected three samples from Tanks Nos 06 amp 07 (composite) Tank No 05 and Drum No 183 (which contained liquid from Tank No 15) for PCP analysis to be performed at EPAs New England Regional Laboratory (NERL) The analysis was requested due to some discrepancies between results determined previously by

12

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

13

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

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OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

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the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

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Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

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VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

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Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

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TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

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- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

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MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 14: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

IEA Laboratories and information regarding the contents of the above-mentioned tanks obtained from William Haynes TAT member Keefe delivered the three samples to NERL EPA Health and Safety Officer John Desmond reviewed and signed the original copies of the HASP amendments

ERCS personnel used a drum vacuum to remove additional small pieces of dried PCP from the PCP-drip pad The pad had been previously cleaned with a air hammer which had left small pieces in cracks and around the railroad ties present on the drip pad

DC Mike Schubert presented a Request For Quotation (RFQ) package to OSC Danek Burke Eighteen companies including landfills incinerators treatment facilities and waste brokers were requested to bid on all or part of the sixteen sections of the RFQ The RFQ was designed to obtain the best possible pricing as well as maintain a smooth transition between disposal of the bulk waste and the drummed waste The bids were sent via Federal Express on 15 September 1994 vendors were requested to respond by 23 September 1994

TAT member Keefe and FM McLoughlin affixed confined space warning signs on all tankscylinders previously emptied OHM personnel began to stage wooddebris from around the Site inside the Stacker Building

Monday 19 September 1994 through Friday 23 September 1994

OHM personnel gathered treated lumber from around the Site The staging of miscellaneous lumber was conducted to minimize tripping hazards and facilitate the upcoming soil sampling event The OHM crew removed the tarp from the CCA drip pad and placed all extraneous material into drums as CCA drip pad waste RM Tallman was demobilized from the Site and replaced by RM Michael Blodgett Bids for waste disposal were received by DC Schubert

Monday 26 September 1994 through Friday 30 September 1994

Alan Humphrey of EPAs ERT and members of Roy F Weston Inc REAC arrived on site OSC Danek Burke EPAERT representative Alan Humphrey and REAC task leader Jacqueline Marrone conducted a site walk to determine from which areas of the Site to collect random surface soil samples After mapping and gridding the five major portions of the Site REAC personnel began to collect and analyze surface soil samples Samples were screened on site for PCP and polynuclear aromatic hydrocarbons (PAHs) by immunoassay test kits Arsenic copper chromium and lead concentrations were determined on site using a Spectrace 9000 X-Ray Fluorescence (XRF) analyzer In addition in situ analysis was also performed with the Spectrace

RM Michael Blodgett arrived on site A site walk was conducted with OSC Danek Burke TAT member Keefe and RM Blodgett

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Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

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Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

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Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

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OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

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Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

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Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

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the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

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Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

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The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

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Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 15: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Members of ERT and REAC completed all sampling and on-site field screening and departed the Site The sample locations and arsenic screening results are given in Figures Ashy5 A-6 A-7 and A-8 The final REAC report entitled Soil Sampling and Field Screening December 1994 can be referenced for additional information regarding sampling results for arsenic copper chromium lead PCP and PAHs

Tuesday 4 October 1994 through Friday 7 October 1994

OHM personnel were temporarily demobilized Disposal bids were reviewed by OSC Danek Burke TAT member Keefe and Disposal Coordinators Schubert and Taggart The remobilization of the ERCS crew back to the Site was contingent upon treatment and disposal facility acceptance of each waste stream in the bid package

Monday 10 October 1994 through Thursday 13 October 1994

No site activities occurred EPA TAT and the ERCS crew waited for the completion of waste disposal arrangements prior to remobilizing back to the Site Disposal Coordinators Schubert and Taggart worked with facilities as well as with the ERCS purchasing department to obtain purchase orders for waste disposal

Analytical results were obtained from NERL confirming the following Tank No 05 contained percent levels of PCP (20-30) Tank Nos 06 and 07 contained levels of PCP less than 1 percent and Tank No 15 contained levels of PCP around 1 percent

Monday 17 October 1994 through Friday 21 October 1994

The new Region I ERCS DC (Barry Taggart) assumed disposal responsibilities from DC Schubert Of the eighteen potential vendors participating in the bid process seven companies were collectively awarded the disposal subcontract

TAT member Keefe completed a inventory of the archived samples previously collected on site Samples were present for the majority of the tanks as well as from each drum The samples were archived to send to facilities for waste profiling

Friday 28 October 1994

TAT member Keefe and RM Blodgett collected two additional samples for disposal analysis A composite sample of contaminated sawdust was collected as well as a sample from the CCA recovery sump located outside and adjacent to the Cylinder No 03 Building

14

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 16: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Wednesday 2 November 1994 through Friday 4 November 1994

OSC Danek Burke TAT member Keefe and DC Taggart arrive on site A discussion was held regarding the disposal bid package Each subsection of the package was reviewed as well as the number of samples needed for waste-profiling by each respective facility TAT member Keefe and RT Vieras composited archived drum and tank samples for shipment to disposal facilities for testing prior to accepting the waste TAT member Keefe DC Taggart and RT Vieras prepared samples for shipment via Federal Express to disposal facilities

Monday 7 November 1994 through Friday 11 November 1994

No site activities occurred EPA TAT and the ERCS crew waited for facility acceptance of each waste stream for disposal DC Taggart worked with facilities in an attempt to expedite the disposal process However due to the presence of varying levels of dioxin contained in some of the bulk liquid waste many treatment and disposal facilities were now stating they would be unable to accept this material and withdrew their bids

Tuesday 15 November 1994

TAT member Keefe and RM Blodgett arrived on site to meet with FM Ball FM Ball updated RM Blodgett and TAT member Keefe with regards to the previous tank cleaning operation the locations of valves problems encountered and problems to possibly expect with the remaining 15 full tanks located on site

Monday 28 November 1994 through Friday 2 December 1994

OHM personnel mobilized to the Site in anticipation of waste disposal RM Blodgett conducted a site walk with new members of the OHM crew OHM personnel attached a pipe fitting to a common Dricon pipe leading from both Tank Nos 02 and 04 A Bobcat and a water compressor were delivered to the Site OHM personnel continued to mount fittings on pipes including the pipe leading from Tank Nos 06 and 07 (dilute PCP-waste) ERCS crew began segregation of approximately 300 drums located inside the Mill Building and the Kiln Building

Capitol Environmental was awarded disposal of the bulk Dricon liquid Seven 5000-gallon tanker trucks from Freehold Cartage Inc (FCI) Capitols waste hauler arrived on site While filling the first tanker it became apparent that one end of the common Dricon pipe was not blocked-off A small amount of Dricon (5 gallons) spilled into the containment area A plug was obtained and pumping operations continued from Tank No 04 followed by Tank No 02 All tankers were loaded and departed the Site for EI DuPont Deepwater NJ for waste water treatment

OHM personnel set up a tank mixer in Tank No 01 The mixer successfully stirred the tank bottoms into solution Segregation of drums continued

15

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 17: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 5 December 1994 through Friday 9 December 1994

Two 5000-gallon tanker trucks (from FCI) arrived on site to complete the removal of the bulk Dricon liquid The trucks removed all the remaining Dricon liquid from Tank Nos 02 and 01 as well as liquid from the Dricon recovery sump

ERCS personnel continued to segregate drums according to DC Taggarts drum map OSC Danek Burke RM Blodgett and TAT member Keefe discussed the most appropriate waste stream for a few miscellaneous drums TAT member Keefe assisted by the OHM crew emptied unused drum samples into their original drums

DC Taggart again expressed difficulty with regards to disposal of some sections of the bid package due to the presence of low levels of dioxin He stated that it might be necessary to send the dioxin-contaminated waste to specialized dioxin-approved incinerators DC Taggart informed OSC Danek Burke that five sections of the RFQ would have to be re-bid due to the withdrawal of bids for the disposal of dioxin-contaminated waste

RM Blodgett wrapped exposed pipes leading from Tank Nos 06 and 07 with electric heat tape and pipe insulation to prevent the dilute PCP solution from freezing OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor

Monday 12 December 1994 through Friday 16 December 1994

RM Blodgett placed electric space heaters adjacent to Tank No 11 in the Cylinder No 01 amp 02 Building to prevent the wastewater from freezing RT Williams mobilized to the Site to assist RM Blodgett in emptying wooden bins and drums full of sawdust into twelve 1-cubicshyyard boxes

Franks Vacuum Truck Service arrived on site (Environmental Waste Technologies waste transporter) RM Blodgett loaded 60 drums containing liquid CCA onto the trailer truck for transport to Envotech Management Services located in Belleville Michigan

Dart Trucking Inc (Capitol Environmentals waste transporter) arrived on site to pick up a variety of hazardous waste drums The waste included miscellaneous chemicals left by the former facility (ie sulfamic acid hydrogen peroxide and triethanolamine) and nine drums of assorted flammable liquids and solids The waste was transported off site for treatment and disposal at the Chem-Met disposal facility located in Wyandotte Michigan In addition 60 RCRA empty drums and 12 cubic-yard boxes of contaminated sawdust and debris were shipped to the LWD Inc disposal facility located in Calvert City Kentucky

Temporary demobilization occurred in anticipation of the long holiday weekend The remobilization of OHM personnel was expected to occur only after additional disposal contracts were awarded and the disposal scheduled

16

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 18: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Wednesday 21 December 1994

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly

Tuesday 27 December 1994 through Thursday 29 December 1994

TAT member Keefe arrived on site A severe weather storm occurred over the previous weekend and blew the mobile CRZ across the Site no damage had occurred The storm blew a few clean empty plastic drums around the Site No problems were evident with regards to the tanks and drums on site as a result of the storm

MADEP representative Julie Hutcheson contacted OSC Danek Burke and TAT member Keefe regarding the removal of the fuel oil remaining in Tank No 08 The State reaffirmed its commitment to remove this material Analytical results and volume calculations for this material were sent to her via facsimile

DC Taggart contacted OSC Danek Burke regarding the disposal of bulk waste remaining in tanks Because sections of the disposal RFQ were re-bid it was necessary to collect additional samples to send to disposal vendors to gain facility acceptance

TAT members Keefe and David Strzempko arrived on site to collect three additional composite samples for disposal analysis DC Taggart picked up the samples and shipped them to the respective disposal facility

Tuesday 3 January 1995

TAT member Keefe performed a site walk and conducted a visual inspection of tanks and drums remaining on site TAT member Keefe verified that the electrical heat tape on Tank Nos 06 and 07 and the space heaters adjacent to Tank No 11 were operating properly EPA TAT and ERCS personnel waited for waste disposal confirmation prior to remobilizing to the Site

Tuesday 10 January 1995 through Friday 13 January 1995

MADEP representatives Hutcheson and Michael Moran arrived on site and conducted a bid walk with disposal companies for the removal of the fuel oil contained in Tank No 08

ERCS personnel mobilized to the Site including four RTs and one Team Leader (TL) A tanker truck from FCI arrived on site as the transporter for EnTech Inc FCIs 5000-gallon tanker truck proceeded to vacuum out the wastewater contained in Tank No 11 as well as the contaminated liquids and sludges in Tank Nos 09 and 10 for transport to the LWD Inc disposal facility located in Calvert City Kentucky

17

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 19: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

OSC Danek Burke spoke with Region IV EPA representative Larry Lambert and confirmed that the LWD Inc disposal facility was still a CERCLA-approved facility Two additional FCI 5000-gallon tanker trucks arrived on site The liquid contents of Tank Nos 30a and 30b were pumped into the first truck while two RTs were preparing for a confined space entry into Tank No 09

TAT member Keefe performed air monitoring in Tank No 09 prior to ERCS personnel entering the confinedspace The second tanker was used to pump out the remaining sludge in Tank No 09 Upon completion the remainder of the truck was filled with liquid waste from Tank No 32 Both trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Tuesday 17 January 1995 through Friday 20 January 1995

One FCI 5000-gallon tanker truck (for Entech Inc) and one 5000-gallon tanker truck from FES arrived on site OHM personnel completed filling FCIs tanker with liquid waste from Tank Nos 30b and 30c FCIs tanker truck departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

The first FES tanker received pumpable sludge from Tank No 30a while OHM personnel prepared to enter Tank No 10 TAT member Keefe performed air monitoring prior to the entry of ERCS personnel into Tank No 10 The sludge that remained in Tank No 10 was pumped out into the FES tanker truck The remaining space in the tanker was filled with liquid and sludge from Tank Nos 31 and 32

A second FES 5000-gallon tanker truck arrived on site TAT Keefe performed air monitoring above Tanks Nos 30a 30b and 30c in anticipation of ERCS performing confined space entries OHM personnel entered Tank No 30c to pump out the sludge remaining on the bottom of the tank Tank Nos 30a and 30b were also entered and pumped out into a FES tanker truck Upon completion of Tank Nos 30a 30b and 30c the ERCS crew filled FESs tanker truck with liquid from Tank No 26 followed by sludge from Tank No 31 The sludge from Tank No 31 was extremely thick and only a limited quantity was pumped out before the vacuum hose clogged The remaining sludge (approximately 2-feet deep) was cleaned out manually Both of FESs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

ERCS personnel prepared the area surrounding Tank No 31 which included laying down plastic and moving the confined space entry equipment adjacent to the manway to Tank No 31 TAT member Keefe performed air monitoring in and above Tank No 31 OHM personnel entered Tank No 31 to begin manually removing the remaining sludge using 5shygallon pails The material was placed into 55-gallon steel drums Several entries were made in order to complete the cleaning of Tank No 31 and a total of eighteen 55-gallon drums were generated

18

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

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~A H0 C3

1

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o 8i eoi

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S c laquo

i IJ- O plusmn o

s tb

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8 Q o 0 if

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8

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Z Q LUffi^d

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iiU 0

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15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 20: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Jim Dilorenzo from EPAs Remedial program arrived on site to obtain an update of site activities A site walk was conducted by OSC Danek Burke TAT member Keefe and EPA Remedial representative Dilorenzo

Monday 23 January 1995 through Friday 27 January 1995

Two FES tanker trucks returned to site after delivering waste to the LWD Inc disposal facility located in Calvert City Kentucky The trucks contained a residual oily layer lining the inside of both tankers OHM crew prepared to enter the tankers while TAT member Keefe conducted air monitoring Both tanker trucks were cleaned by the OHM crew prior to departing the Site

MADEP representative Hutcheson and MADEPs contractor Zecco arrived on site and pumped out fuel oil from Tank No 08 into a 3000-gallon vacuum truck In addition the waste oil contained in two 55-gallon drums was also sent off site with the fuel oil

ERGS personnel decontaminated their equipment the sides of the recently generated drums and the area surrounding Tank No 31 The crew proceeded to organize the drums in the Mill Building in anticipation of future transportation and disposal

FES arrived on site to pick up drummed waste (liquids and sludges) The first FES truck received 65 drums of liquid waste generated from the cleaning of Tank Nos 13 14 15 23 29 and decontamination rinse water The second FES truck was loaded with drums containing sludges from Tank Nos 12 13 14 16 27 and 29 Both trucks (loaded with drums) departed the Site for LWD Inc disposal facility to deliver the drums for treatment andor disposal

Monday 30 January 1995 through Friday 3 February 1995

The subcontract for the removal of bulk PCP-waste contained in Tank Nos 05 06 and 07 was awarded to EnTech Inc An FCI tanker truck (EnTechs transporter) arrived on site FCI started to pump out Tank Nos 06 and 07 when it was realized that the common pipe leading from both tanks was frozen Electric space heaters were placed adjacent to the pipe to thaw the frozen waste

The tanker proceeded to vacuum off the liquid from Tank No 05 However due to a large amount of sludge contained in Tank No 05 only a small amount (lt 1000 gallons) of waste was pumpable The remaining space in the first tanker was filled with the liquid PCP-waste from Tank No 06 after the pipeline thawed A second FCI tanker was filled with the liquid PCP-waste from Tank No 07 Both FCIs tanker trucks departed the Site with waste to the LWD Inc disposal facility located in Calvert City Kentucky

Freebird Construction arrived on site unannounced and without a valid Access Agreement Freebird Construction was contracted by John Aiello (of Richmond Sand and Gravel

19

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 21: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Wyoming Rhode Island) to take down two large storage sheds on Hatheway amp Patterson Company property It would appear that the former president of Hatheway amp Patterson Company (William Haynes) sold the buildings to Mr Aiello The removal of the buildings was temporarily halted by EPA OSC Lisa Danek Burke pending further clarification of the transaction

Due to the extremely viscous nature of the sludge remaining in Tank No 05 it was necessary for the ERCS crew to enter the tank through two manways cut into the sides of the tank and manually shovel the waste into drums A total of 35 drums of PCP-contaminated sludge were generated and stored in the Mill Building EPA TAT and ERCS temporarily demobilized from the Site pending the award of the subcontract for the removal of the remaining 88 drums

Monday 13 February 1995 through Tuesday 15 February 1995

OSC Danek Burke TAT member Keefe and the ERCS crew returned to the Site in anticipation of loading out drums RM Blodgett DC Taggart and TAT member Keefe affixed the necessary labels to the remaining drums to be shipped off site

A tractor trailer (from Capitol Environmental) arrived on site to pick up the remaining 88 55-gallon drums containing PCP-contaminated solids and sludges The waste was transported by BeChem Trucking to the LWD Inc disposal facility for treatment andor disposal The only waste remaining on site consisted of used disposable Personal Protective Equipment (PPE) Furthermore the PPE was segregated into two waste streams non-hazardous and hazardous (PCP-contaminated) PPE

Prior to demobilization OHM personnel secured the Site including the addition of new locks to entrances to the buildings on site and posting warning signs on fences around the Site

An EMI electrician arrived on site to disconnect two power boards installed at various locations around the facility The electrical service for the Office Building as well as the fire alarm system remained intact Demobilization of ERCS equipment and personnel from the Site occurred Site security was discontinued

Tuesday 21 February 1995 through Friday 24 February 1995

John Aiello owner of Richmond Sand and Gravel was granted restricted access to the Site (by EPA) to remove the two storage sheds Aiellos contractor Freebird Construction disassembled both sheds and transported them off site

Thursday 2 March 1995

ENSCO Inc was awarded the disposal of 20 cubic yards of non-hazardous PPE A Dart Trucking Inc tractor trailer arrived on site (ENSCOs transporter) and was used to transport

20

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

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G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

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r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 22: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

the non-hazardous PPE to Atlantic Waste Disposal located in Waverly Virginia The remaining hazardous PPE (PCP-contaminated) would remain until all site activities were completed Temporary demobilization of all site personnel occurred

Thursday 27 April 1995

OSC Gardner assumed site responsibilities from OSC Danek Burke TAT members Keefe and Pamela Cruickshank mobilized to the Site Thirty-six additional surface soil samples were collected and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 9 May 1995

TAT members Keefe and Joseph Francis mobilized to the Site Nineteen additional surface soil samples were collected from the perimeter of the Site and analyzed on site for arsenic utilizing a Spectrace 9000 XRF analyzer The arsenic results were used to better define contaminated surfaces and to determine which areas would receive temporary gravelasphalt cover

Tuesday 13 June 1995 through Friday 16 June 1995

ERCS personnel mobilized to the Site including RM Blodgetts replacement Stan Rhoad The ERCS crew began clearing contaminated areas of the Site of brush saplings and debris OSC Gardner along with MADEP representative Hutcheson agreed on portions of the Site to be paved based on previous analytical results

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site OSC Gardner also walked the Site with MADEP representative Hutcheson and Mansfield Heath Department representative Scott Incite to discuss site plans and progress

OSC Gardner and TAT member Keefe constructed a sampling grid along the southern portion of the property Forty-seven samples were collected from this grid and 35 samples were collected from sample stations around the perimeter of the Site All 82 samples were screened for arsenic at EPAs New England Regional Laboratory using a Kevex 7000 XRF analyzer

OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence

21

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

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tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

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(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

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CO CO

CD 9 E

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Z Q LUffi^d

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iiU 0

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15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 23: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Monday 19 June 1995 through Friday 23 June 1995

RM Rhoad and TAT member Keefe continued the perimeter walk of the fence identifying areas of the fence to be repaired as well as areas where a fence needed to be installed The ERCS crew continued clearing and grubbing portions of the Site to receive temporary gravelasphalt cover

Lt Joseph Sarro from the Mansfield Fire Department arrived on site to get an update on work progress from OSC Gardner In addition the crew began making repairs to some sections of the fence in the southern portion of the property EPAEPRB section chief Novick arrived on site to review site progress

Six loads of gravel (approximately 36 tonsload) arrived on site TAT member Keefe photodocumented the areas prepared for paving Dust control equipment arrived on site which included two lawn sprinklers and a gas powered water pump

Monday 26 June 1995 through Friday 30 June 1995

Forty rolls of geotextile fabric (150000 sq ft total) arrived on site The ERCS crew continued clearing and grubbing areas of the Site for placement of geotextile fabric and gravel A york-rake attachment for the Bobcat was used to assist clearing area of debris and vegetation

The ERCS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No 03 Building The crew prepared the smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for geotextile fabric and gravel This process requires extensive hand-shoveling to adjust grades in the narrow areas between and around the buildings The ERCS crew secured the Site for the long holiday weekend

Wednesday 5 July 1995 through Friday 7 July 1995

Two surveyors arrive on site from Atlantic Design Engineering (ADE) The surveyors proceeded to survey existing grades of the large area in the northwestern portion of the Site The survey was conducted to insure that water run-off from this area (after paving) would flow toward the river and not the street

The ERCS crew continued preparing smaller areas around the Mill Building Kiln Building and the Cylinder No 01 amp 02 Building for gravel cover ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel The ERCS crew began and completed the gravel cover in the seep area Clearing and grubbing was completed in all portions of the Site south of the railroad tracks Two samples from a pile of gravel located in the southwestern portion were collected The samples were analyzed for extractable baseneutrals and acids (BNAs) and screened for metals at NERL

22

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

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~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

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s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

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9 B

gt raquo bull g pound

iiU 0

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sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 24: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Metals results from the soil samples collected on 6 July 1995 were below action levels therefore that area did not receive gravel cover The ERCS crew completed placing fabric and gravel cover at the following locations the rectangular area next to the large bedrock outcrop areas adjacent to the roadway and near the former storage shed in the southern portions of the Site START member Keefe transferred existing grades onto a site map to help in designing grade alteration plans

Monday 10 July 1995 through Friday 14 July 1995

An additional 50 loads of gravel arrived on site The ERCS crew continued installing geotextile and gravel cover The following areas were so covered adjacent to the CCA drip pad the triangular area adjacent to County Street and the Rumford River near the Office Building and the northwestern part of the Site

ERCS crew used the front-end loader to adjust the existing gradeslope in the northwestern portions of the Site (according to the stakes left by the surveyors) Grade lines between stakes were established by OSC Gardner and START member Strzempko in the northwestern portion of the Site to aid in grading with the front-end loader OSC Gardner and RM Rhoad had the EO create a swale leading to the Rumford River to help drain the water runoff from areas to be paved

OSC Gardner updated abutting resident James Sera of site progress

The EO informed RM Rhoad that the front-end loader was continuously overheating RM Rhoad began procuring a replacement loader for the one that overheated and a second larger front-end loader to assist with spreading gravel A second larger loader (CAT F950) arrived on site

Monday 17 July 1995 through Friday 21 July 1995

The replacement front-end loader (Dresser 520C) arrived on site 11 additional loads of gravel were delivered to the Site Installation of geotextilegravel continued and was completed in all areas by the end of the week

Abutter J Dwinell and MADEP Representatives Hutcheson and Richard Packard arrived on site to receive an update regarding site progress

The disposal of contaminated PPE was awarded to Capitol Environmental A bid walk was conducted to solicit bids for the upcoming paving work four paving companies participated The paving contractors informed OSC Gardner and RM Rhoad that the individual filling of pot-holes would cost more than repaving the entire deteriorated area (due to the large number of pot holes) Moreover the patches would not last very long All paving contractors recommended that a single 3-inch layer of asphalt on top of a Petromat layer would be cost effective and long lasting

23

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 25: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

The tax map and property deed were obtained to better define the boundary between the Site and abutter James Sera for the installation of a chain-link fence along the property line

A pipe leading into the Cylinder No 01 amp 02 Building was removed and placed inside the PCP containment RM Rhoad attached chains and locks to the manways to Tank Nos 30a 30b and 30c An ERGS welder Daniel Corvello arrived on site to weld hasps onto both manways to Tank No 1 Subsequently RM Rhoad applied locks to these manways Both front-end loaders were demobilized The ERCS crew secured the dricon sump with the addition of high-visibility fence RM Rhoad using the Bobcat straightened-out bent fence posts around the Site Both EOs and two RTs were demobilized from the Site

Monday 24 July 1995 through Thursday 27 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams RM Rhoad obtained two rolls of barbed wire (approximately 1000 ftroll) The ERCS crew installed a single strand of barbed wire to the tops of the wooden fence posts in the southern portions of the Site In addition repairs were made (with barb wire) to holes cut in the fence

OSC Gardner RM Rhoad and Project Accountant Phil Joseph prepared specifications for the major fence work

Dart Trucking Inc (Capital Environmental Services transporter) arrived on site to pick up the PCP-contaminated PPE Also arriving on site was ERCS DC Barry Taggert RM Rhoad and RT Williams loaded the tractor trailer with bags of PPE The PPE was shipped to LWD Inc located in Calvert City Kentucky

The ERCS crew swept away sand and gravel from around the potholes to prepare these areas for an additional layer of asphalt A bush-hog industrial mower was mobilized to the Site and a 4-foot wide strip was cleared for the installation of new fence in the southwestern portion of the Site A site walk was conducted by OSC Gardner and START member Keefe which included a check on existing fences gates buildings and tanks to ensure site security

Monday 7 August 1995

OSC Gardner RM Rhoad and START member Keefe conducted a bid walk with representative of Custom Fence (potential fencing subcontractor) Fence contractors were required to submit their quotation by the end of the following week A meeting was held at the Site to discuss work progress and future plans for the Site Representatives from the MADEP the Town of Mansfield and EPA were present

24

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 26: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Thursday 10 August 1995 through Friday 11 August 1995

Tilcon Inc (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt The process buildings on site were secured with additional locks and warning signs were posted on building entrances

Monday 14 August 1995 through Tuesday 15 August 1995

Surveyors from ADE arrived on site to survey the areas covered with gravel (prior to paving) The survey confirmed that overland water flow would be directed toward the Rumford River in the northwestern portion of the Site

Members of the Tilcon crew as well as members of New England Sealcoat Company (NESCo) crew arrived on site The NESCo crew applied the Petromat (a combined layer of tar and fabric) onto the badly deteriorated paved areas and potholes on site The Tilcon crew proceed to pave areas in the northwestern portion of the Site Other areas paved were adjacent to the CCA drip pad and the areas prepped with the Petromat

Custom Fence was awarded the subcontract to install new sections of fence and make repairs to the existing fence

Wednesday 23 August 1995 through Friday 25 August 1995

Members of the Custom Fence crew arrived on site and began making repairs to the existing fence and installing new sections of fence in the southwestern portion of the Site

One load of Number 4 Stone (Railroad Ballast) arrived on site The stone was placed in the swale to prevent the smaller gravel from sliding down the geotextile fabric The Custom Fence crew continued with the installation of new fence in the southwestern portion of the Site and made repairs to old sections of the fence

OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week

Monday 28 August 1995 through Friday 1 September 1995

Members of the Custom Fence crew arrived on site and completed the installation of new sections of fence and repairs to the existing fence

Lt Sarro from the Mansfield Fire Dept arrived on site to check the fire alarm system He verified that the system was activated and operational

25

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 27: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

In anticipation of complete demobilization the electrical and water utility services were disconnected from the Office Building (command post) START member Keefe and RM Rhoad placed warning signs on the site perimeter fence All gates and buildings were locked and secured All remaining equipment and supplies were demobilized from the Site on September 1 1995

IV ORGANIZATION OF THE RESPONSE

This removal was a fund-lead action conducted by the ERGS contractor The Site is owned by Hatheway amp Patterson Company Inc and HPC Realty Trust The primary contact is William Haynes the companys president Hatheway amp Patterson Company Inc and Mr Haynes were both invited to perform the removal action but both declined Mr Haynes assisted in identification of the contents of various pipes tanks and vessels

During the removal action MADEP arranged for the removal of waste fuel oil contained in one above-ground tank and two 55-gallon drums In addition representatives from MADEP were kept informed of site decisions and provided technical assistance to the EPA The long-term monitoring and care of the Site will be carried out by the MADEP The Mansfield Fire Department Health Department and Conservation Commission also provided technical input and support throughout the removal action

V SUMMARY OF WASTE DISPOSAL

Approximately 40000 gallons of dilute CCA which was left in tanks on site were transported to Northeast Wood Treaters a wood treatment facility in Belchertown Massachusetts Northeast Wood Treaters used the CCA solution in their wood treatment process Sending this material for re-use saved the government approximately $350000 in disposal costs See the attached Table 1 Off-Site Disposal Summary for a complete summary of all waste streams

26

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 28: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

VI RESOURCES COMMITTED

Extramural Costs CEILING SPENT REMAINDER

ERCS Contractor1 1300000 1161877 138123 106

ERTREAC 70000 48000 22000 314

Technical Assistance Team and Superfund Technical Assessment and Response Team

Extramural Total

Intramural Costs

EPA Regional Personnel

Contingencies

TOTAL PROJECT CEILING

+95000 107100 (12100) (127)

1465000 1316977 148023 101

120000 109350 10650 89

+ 313000 - 0 - 313000 100

$1898000 $1426327 $471673 249

Current ceiling in ERCS Delivery Order ERCS ceiling in Action Memo is $1400000

The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery

The EPA costs were based on a $30hour estimate for direct labor costs plus $60hour for indirect labor costs Other indirect costs include per diem hotel charges and miscellaneous expenses In accordance with EPA guidance the STARTTAT costs include per diem hotel charges and miscellaneous expenses

VII PROJECT SUPPORT FILE

Action Memorandum (209) Air Monitoring (203) ARAR(211) Bid Document (215) Business CardsTelephone Numbers (1707) Chain of Custody Record (203) Community Relations (1301)

27

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

a LU u CD LU x tn

8

^

1 LJJ

tplusmn]

sd

C) o

0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

O

H

(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 29: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

Community Relations - Plan (1302) Contractor Report (206) Correspondence - Congressional (1401) Correspondence - EPA (201) Correspondence - Local (201) Correspondence - Misc Parties (201) Correspondence - OHM (201) Correspondence - PRP (1109) Correspondence - State (201) Correspondence - TAT (201) Daily Work Order (213) Daily Work Report (213) Daily Work Sheet1900-55 (214) Delivery OrderModification (216) Disposal Information (202) Drum Log (203) EntryExit Log - EquipmentExpendables (212) EntryExit Log - Hot Zone (212) EntryExit Log - Personnel (212) Field Log (212) Health Assessment (202) Incident Obligation Log (214) Invoice (207) Litigation Report (1002) Manifest (212) Map (1704) Material Safety Data Sheet (1707) News ArticlePress Release (1303) Off-site Disposal Report (217) OSC Notes (212) OSC Report (205) Photograph (1704) Polrep (204) Preliminary Assessment - Pre-Removal (102) Property OwnersAbutters (1702) PRP Related Documents (1109) PRP Specific Correspondence (1109) Safety Plan (202) Sampling and Analysis Data (203) Sampling Plan (203) Site Investigation (202) StateLocal Technical Record (1708) Subcontractor Document (215) TAT Report (206)

28

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

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0shy I Q 5 M

I

8

s I ipound

bull IA

yen

9 o V U

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(0

n

raquor)V^__X

~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

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CD 9 E

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Z Q LUffi^d

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CO

a

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9 B

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iiU 0

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ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 30: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

TDD (215) Telephone Notes (201) Waste Profile (212) Work Plan (206)

29

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

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8

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0shy I Q 5 M

I

8

s I ipound

bull IA

yen

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sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 31: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

- mdash N

G r e a t W o o d s MAIraquoSF(tLD X

V

SCALE 1 25000 FIGURE 1 SITE LOCATION MAP

MANAGERS ^^0 ESI ONE ( CONSULTANTS HATHEWAY AND PATTERSON SITE RE a ON I SUPERRJND TECHNICAL AND ASSESSMENT RESPONSE TEAM

MANSFIELD MASSACHUSETTS DRAWN BY PCS D KEEFE 1020SLMDRW

SOURCE US QEOLOOJCAL SURVEY 1969 TOPOGRAPHIC MAP MANSFIELD MASSSACHUSETTS QUANDRANQLE 7 S MINUTE SERIES PHOTOREVISED 1973

QC m ca alaquolt gt_ i mdashymdash ^ ^ ^^ LT 1-1 lt LU

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0shy I Q 5 M

I

8

s I ipound

bull IA

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9 o V U

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(0

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~A H0 C3

1

3 2

LU m H 2 co co

9|E5 w co CO S 8 pound g oes J Lo

o 8i eoi

o Q J d 5

oo ltZ gt Q LJJ OC lt rJ ii LJJ gt CD pound Q m LL

S c laquo

i IJ- O plusmn o

s tb

ZQcrd LLJ D Q CO Z

8 Q o 0 if

ymdash

5 Q

8

LLJ

CO CO

CD 9 E

111siltlt lt ij Q

Z Q LUffi^d

Sic CO sgill i

CO

a

ll

9 B

gt raquo bull g pound

iiU 0

D D

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ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 32: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

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o 8i eoi

o Q J d 5

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S c laquo

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ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 33: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

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i f f D D M

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Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 34: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

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Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 35: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

CO

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i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 36: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

bullis

ltJ sCJ

sect E09 Z

i i u z

15 9

i f f D D M

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 37: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

r rticicat ing Agencies and Personnel

bullpound EMVIRCMMEXTAl PROTECTION AGENCY

Emergency Planning and Response Branch

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service ERCSSuperfund Technical Assessment and Response Team 3TART) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

RCY F KESTCX Inc

Donald Berger

Steve Ncvick

Frank Gardner Asa Danek Burke

Mary Dever

John Carlson

John DeVil_ar

Andrew Raubvcgei Kathleen Woodward

Superfund Technical Assessment and Response TeamTechnical Assistance Team

STATE CF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFISLD MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conion

David StrzenpKC Pamela Cruiccsha

Josepr Francis

Fulie JHutcheson

Lt Joseph Sarrc

Dick Lewis

Scott Leite

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 38: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

YS IA poundCS PRIM7 CONTRACTOR

OHM Remediation Services Inc

Response Managers

Disposal Coordinators

Stan Rhoad Micnael Biodgett William Tall-nan

Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor

Airborne ExpressATampTAtlantic Design Engineering3est Equipment3arns SecurityCape Cod SandcastlesCapitol Er--i-on-entalCassidy EquipmentCustotrade FenceCart Ti_gtcltirgDenis EngineeringEXIEXSCC IncEnTecn ~cEnvironmental Waste TechnologiesFederal ExpressFranltlin Environmental ServicesFranks Yac^r Truck ServiceFreehold Cartage IncGeneral CrerricalGeotextile ServicesGuard Force ManagementIEA Laboratories IncKoral RentalLaDoratory ResourcesLaidlaw EnvironmentalMansfield Electric CompanyMSANew England Sealcoat Companyew England AirgasNew England TelephonePoland SpringsRusso IncSimpson SpringsTage MotelTaylor RentalTilcon United Oil and HeatZee Medical

Sample Shipment Long Distance Phone Service

Surveyors Office Equipment Site Security

Port-A-John Rental Waste Disposal

Front-end Loader Fence Subcontractor Waste Transporter

Front-end Loader Electricians

Waste Disposal Waste Disposal

Waste Disposal Shipping

WasteDisposal Waste Disposal

Waste Transporter Labpacking

Geotextile Fabric Site Security

Disposal Analysis Bobcat

Disposal Analysis Dumpster RentalNew Drums

Electricity Respiratory Equipment

Petromat Breathing Air Cylinders

Local Phone Service Site Fluids

Crushed Gravel Site Fluids

Lodging Plate Compactor Asphalt Subcontractor

Diesel Fuel First Aid

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence

Page 39: FEDERAL ON-SCEN COORDINATOR'E REPORS T · at the Sit ane d futur planse I. n response , several articles i appearen area newspaperd s documenting EPA' accomplishments ins cleaning

LIST OF ACRONYMS

Design Engineering surveyors Extractabie BaseNeutrals and Acids Chrorated Copper-Arsenate -de f Federal Regulations

CLP ntjact laboratory Program CRZ Ocrra-ination Reduction Zone DC Disposal Coordinator

SPA Enviicnmental Protection Agency Emergency Planning and F^sponse Branch

EO Equipment Operator ERC3 Emergency Response Cleanup Service ERT Environmental Response Team

ESAT Environmental Services Assistance Team Fl^crc shy Chrome Arsenate Phenol Freehold Cartage Inc (transporter) Franklin Environmental Services

FM HAS Health a nd Safety Plan HSC Hea It and Safety Officer

MAD E Massachusetts Department of Environmental Protection M3DS MVvD

Material Safety Data Sheets Marsfie-c ater Department

XERL Xew England Region laboratory Jew England Sealcoat Company

NCR Responsibility xcx HM

Xoncompliance OHM Remediation Services Inc

3RC Office of Regional Counsel CSC On-Scene Coordinator CSKA Occupational Safety and Health Administration PASI Preliminary AssessmentSite Investigation

PAH Polynuclear Aromatic Hydrocarbons CP Fentachlorophenol

PCLREP Pollution Report PPE Personal Protective Equipment pprn carts per million

RCRA Resource Conservation and Recovery Act REAC Response Engineering and Analytical Contract RFC Request For Quotation RM Response Manager RT Removal Technician 31 Site Investigator ST Sample Technician

START Superfund Technical Assessment and Response Team 5mM Short Term Measures TAT Tecnnical Assistance Team TDD Technical Direction Document

Team leader Wastewater Treatment Plant X-ay Fluorescence


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