V i

AFTER ACTION REPORT FOR THE

HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

December 1993 Through September 1995

SDMS DocID 000225305

Prepared For:

U.S. Environmental Protection Agency Region I

60 Westview Street Lexington, Massachusetts

CONTRACT NO. 68-W5-0009

TDD NO. 95-0610-15C

PCS NO. 1246 f

DC NO. R-177

Prepared By:

Roy P. Weston, Inc. Superfund Technical Assessment Response Team

Region I

October 1995

TABLE OF CONTENTS PAGE

LIST OF FIGURES iii

LIST OF ACRONYMS iv

LIST OF APPENDICES v

LIST OF FIGURES IN APPENDIX A vi

LIST OF TABLES IN APPENDIX B vii

1.0 EXECUTIVE SUMMARY 1

2 . 0 SUMMARY OF EVENTS 3 2.1 Participating Agencies and Personnel 3 2.2 Site Location and Description 5 2.3 Cause of Release/Potential Release 8 2.4 Efforts to Obtain Response by Responsible Parties . 9 2.5 Response Organization 10 2.6 Resources Committed 11 2.7 Notification of Natural Resource Trustees 11 2.8 Natural Resource Trustee Assessment and Restoration

Activities 12 2.9 Chronological Summary of Activities 12 2.10 Treatment/Disposal/Alternative Technology 40 2.11 Community Relations 40 2.12 Health and Safety 41

3.0 EFFECTIVENESS OF THE REMOVAL 41 3.1 The Responsible Parties 41 3.2 State and Local Agencies 42 3.3 Federal Agencies 42 3.4 Contractors and Private Groups 42

'• -* i4^Q: DIFFICULTIES ENCOUNTERED 42 ^ " \ * f , l "*• .

* * *

5.0 RECOMMENDATIONS ' ' . . . * . . . 43 5.1 Prevention of Similar Release 43 5.2 Improvement of Response Actions 43

11

LIST OF FIGURES

PAGE

FIGURE 1 ­ Site Location Map 6

FIGURE 2 ­ Site Diagram 7

111

LIST OF ACRONYMS

ADE - Atlantic Design Engineering (surveyors) BNA - Extractable Base/Neutrals and Acids CCA - Chromated Copper-Arsenate CFR - Code of Federal Regulations CLP - Contract Laboratory Program CRZ - Contamination Reduction Zone DC - Disposal Coordinator EPA - Environmental Protection Agency EPRB - Emergency Planning and Response Branch

EO - Equipment Operator ERCS - Emergency Response Cleanup Service ERT - Environmental Response Team ESAT - Environmental Services Assistance Team FCAP - Fluoro-Chrome Arsenate Phenol FCI - Freehold Cartage, Inc. (transporter) FES - Franklin Environmental Services FM - Foreman

HASP - Health and Safety Plan HSO - Health and Safety Officer

MADEP - Massachusetts Department of Environmental Protection MSDS - Material Safety Data Sheets MWD - Mansfield Water Department NERL - New England Region Laboratory NESCo - New England Sealcoat Company NOR - Notice of Responsibility NON - Notice of Noncompliance OHM - OHM Remediation Services, Inc. ORC - Office of Regional Counsel OSC - On-Scene Coordinator OSHA - Occupational Safety and Health Administration PA/SI - Preliminary Assessment/Site Investigation

PAH - Polynuclear Aromatic Hydrocarbons PCP - Pentachlorophenol

POLREP - Pollution Re'port ,PPE - Personal Protective Equipment

*" ppm - parts per million5 - ' "X-jf— f""" ' * ' RCRA - Resource Conservation and Recovery Act .* REAC - Response Engineering and Analytical Contract RFQ - Request For Quotation RM - Response Manager RT - Removal Technician SI - Site Investigator ST - Sample Technician

START - Superfund Technical Assessment and Response Team STM - Short Term Measures TAT - Technical Assistance Team TDD - Technical Direction Document TL - Team Leader

WWTP - Wastewater Treatment Plant XRF - X-Ray Fluorescence

IV

LIST OF APPENDICES

APPENDIX A Additional Site Maps

APPENDIX B Analytical Results Tables

APPENDIX C Off-Site Disposal Summary

FIGURE A-l

FIGURE A-2

FIGURE A-3

FIGURE A-4

FIGURE A-5

FIGURE A-6

FIGURE A-7

FIGURE A-8

LIST OF FIGURES IN APPENDIX A

Cylinder No. 01 & 02 Building

Cylinder No. 03 Building

Dricon Process Building

Base Map & Location of Temporary Cover Map

Sample Location Map - Northeast Quadrant

Sample Location Map - Northwest Quadrant

Sample Location Map - Southwest Quadrant

Sample Location Map - Southeast Quadrant

VI

LIST OF TABLES IN APPENDIX B

TABLE B-l ­ Disposal Sample Results Summary

TABLE B-2 ­ Arsenic Screening Results Summary

TABLE B-3 ­ Arsenic Results Comparison

Vll

1.0 EXECUTIVE SUMMARY

The following After Action Report for the Hatheway and Patterson Company, Inc. Site (the "Site"), in Mansfield, Massachusetts, is a chronological summary of the United States Environmental Protection Agency (EPA), Region I, Emergency Planning and Response Branch's (EPRB) response operations. The report details the situation as it developed, the actions taken, the resources committed, the effectiveness of the removal action, the problems encountered and the On-Scene Coordinator's (OSC) recommendations.

On 22 June 1993, the EPA EPRB conducted a Preliminary Assessment/Site Investigation (PA/SI) at the Site. The site investigation was conducted at the request of EPA personnel from the Resource Conservation and Recovery Act (RCRA) Section, subsequent to the company's declaration of bankruptcy and closure in April 1993. In addition, the Massachusetts Department of Environmental Protection (MADEP) expressed concerns about the Site due to soil and groundwater contamination and the potential release of wood treatment chemicals.

The results of the PA/SI warranted action by the EPA EPRB due to presence of tanks containing hazardous waste which were located outside and inside buildings around the facility, and the possibility of release which existed if the tanks and pipelines froze and ruptured during cold weather. As a result, on 7 December 1993, EPA EPRB initiated an emergency Removal Action pursuant to 40 CFR 300.415 to stabilize site conditions.

On 3 December 1993, EPA Acting Regional Administrator Paul Keough signed an Action Memorandum authorizing $1,998,000 to mitigate the threat to public health and to the environme resulting from actual or potential exposure of nearby populations, animals, or the food chain to hazardous-substances contained in the .tanks at the facility. On 30 December 1994, a 1-year exemption letter was signed by EPA Acting Regional Administrator Patricia Meaney.

Activities conducted during the removal action consisted of the removal of bulk chemicals in tanks, vessels and drums, as well as addressing soil contamination from past wood treatment operations and waste disposal at the Site. Contact threats associated with contaminated surface soils were mitigated by the installation of a temporary gravel/asphalt cover. A site health and safety plan was developed and maintained during site activities. All activities were conducted in accordance with the protocols set forth in the health and safety plan and were in compliance with Occupational Safety and Health Administration (OSHA) regulations.

Primary sources of information pertaining to the Site were assembled by the OSC and the Roy F. Weston, Inc., Technical Assistance Team (TAT) during the removal action. The site file is located at EPA's Emergency Planning and Response Branch, located at 60 Westview Street, Lexington, Massachusetts, 02173. This After Action Report was prepared according to the Code of Federal Regulations (CFR), Title 40, Protection of Environment, Part 300, Subpart B ­Responsibility and Organization for Response, Section 300.165, OSC Reports (revised as of July 1, 1991). The EPA identification number assigned to the Site is X3.

2.0 SUMMARY OF EVENTS

2.1 Participating Agencies and Personnel

U.S. ENVIRONMENTAL PROTECTION AGENCY

Emergency Planning and Response Branch

Branch Chief

Section Chief

On-Scene Coordinators

Enforcement Coordinator

Emergency Response Cleanup Service (ERCS)/Superfund Technical Assessment and Response Team (START) Deputy Project Officer

Region I Office of Regional Administrator

Regional Administrator

Office of Regional Counsel

ROY F. WESTON. Inc.

Donald Berger

Steve Novick

Frank Gardner Lisa Danek Burke

Mary Dever

John Carlson

John DeVillars

Andrew Raubvogel Kathleen Woodward

Superfund Technical Assessment and Response Team/Technical Assistance Team

STATE OF MASSACHUSETTS

Department of Environmental Protection

TOWN OF MANSFIELD. MASSACHUSETTS

Fire Department

Mansfield Conservation Committee

Mansfield Health Department

Daniel Keefe Zoe Conlon

David Strzempko Pamela Cruickshank

Joseph FranBis'

Julie J.Hutcheson

Lt. Joseph Sarro

Dick Lewis

Scott Leite

U.S. EPA ERCS PRIME CONTRACTOR

OHM Remediation Services, Inc.

Response Managers Stan Rhoad Michael Blodgett William Tallman

Disposal Coordinators Barry Taggart Michael Schubert

John Tobin

Subcontractors to the ERCS prime contractor:

Airborne Express Sample Shipment AT&T Long Distance Phone Service Atlantic Design Engineering Surveyors Best Equipment Office Equipment Burns Security Site Security Cape Cod Sandcastles Port-A-John Rental Capitol Environmental Waste Disposal Cassidy Equipment Front-end Loader Custom Fence Fence Subcontractor Dart Trucking Waste Transporter Denis Engineering Front-end Loader EMI Electricians ENSCO, Inc. Waste Disposal EnTech, Inc. . Waste Disposal Environmental Waste Technologies Waste Disposal Federal Express __ Shipping Franklin Environmental Services Waste Disposal Frank's Vacuum Truck Service Waste Disposal Freehold Cartage, Inc. Waste Transporter General Chemical Labpacking GeoteXtile Services i ^ -<• * * , Geotextile Fabric

». _ „ Site Security •>.* ****<•* Disposal Analysis

Koral Rental Bobcat Laboratory Resources Disposal Analysis Laidlaw Environmental Dumpster Rental/New Drums Mansfield Electric Company Electricity MSA Respiratory Equipment New England Sealcoat Company Petromat New England Airgas Breathing Air Cylinders New England Telephone Local Phone Service Poland Springs Site Fluids Russo, Inc. Crushed Gravel Simpson Springs Site Fluids Tage Motel Lodging Taylor Rental Plate Compactor Tilcon Asphalt Subcontractor United Oil and Heat Diesel Fuel Zee Medical First Aid

2.2 Site Location and Description

The information in the Site Description is excerpted from the EPA Action Memorandum, entitled "Request for Removal Action at the Hatheway and Patterson Company, Inc. Site". U.S. EPA Region I, Boston, Massachusetts, 1993.

The Site is located at 15 County Street in Mansfield, Massachusetts in a mixed residential/industrial area (Figure 1). Hatheway and Patterson Company, Inc. operated a wood treatment facility at the Site beginning in 1953 . Hatheway and Patterson Company, Inc. 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 (see Figure 2). Figure 2 has been further expanded into Figures A-l, A-2 and A-3 (located in Appendix A) which detail the predominant process areas where much of the removal action took place. These process buildings contained large tanks, process vessels, drums, and various small containers. Most of the indoor sumps and pits contained water and sludge from the former wood treatment processes. Located around the Site are process recovery pits (drip pads), as well as several locations used for storage of treated lumber. In addition, located outdoors were three above-ground tanks containing pentachlorophenol (PCP), one tank containing approximately 500 gallons of fuel oil, three tanks containing a fire retardant in water, and six underground tanks containing various process waste.

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 solution of PCP in fuel 5>il, as3well as creosote/ to treat . lumber. However, information gathered while on site ,>*>:,„\ suggests that the business has been in operation since 19 27. From 1958 to 1974, solutions of PCP in fuel oil, and fluoro­chrome-arsenate-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.

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FIGURE 1 SITE LOCATION MAP HATHEWAY AND PATTERSON SITE

MANSFIELD, MASSACHUSETTS

:: U.S. QEOLOaCW. SURVEY. 1S«9, TOPOQfWHC MAP, MANSF1EU9 SOURCE: MASSSACHKETTSQUANDRANQLE.7.S MINUTE SERES, PHOTOREVISEO197S

i

Tank No. 25

i ininn

ooq aMILL CYLINDER

BUILDING No. 01 S 02 BUILDING

KJLN BLOG.

(COMMAND POST)

CYLINDER CCA DRIP PAD See FIGURE No. 03 BUILDING

r t».r- T- » t».«> »>.*«

COUNTY STREET

LEGEND BBUWAHX

CZZJ- DRIP PAD/TANK CtNTAINMEm

CZSZ3- NOOOEN BRX06E

FIGURE 2 SITE DIAGRAM HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

TO STORAGE SHEDS

11 imTi'i 11 ii1 1

STACKER BUILDING

See FIGURE A-3

See FIGURE A-l

ooo DRICQN TANKS

A-2

HUMFORD RIVER

v

NOT TO SCALE CMlULIMrU

ICMON 1 ASfounen «n m

HUNNBY D. KEEFE

DATE 09/95 PCS •

APPROVED BY IATE TOO •

GC, 95-0610-15A

In 1972, a tar mat release (62 feet long and 6 inches thick) was discovered on the banks of the Rumford River by representatives of the town and the MADEP. Additionally, "oily water" and dead fowl were frequently reported in Fulton's Pond (downstream of the Rumford River). The MADEP and the town subsequently requested Hatheway and Patterson Company, Inc. to contain the seepage which appeared to originate from the facility. Continuous groundwater pumping operations were conducted by Hatheway and Patterson Company, Inc. from approximately 1973 through 1976.

In 1981, an "oily seepage" was again detected. A prospective buyer of the Site arranged for soil samples to be collected and analyzed. The results revealed the presence of "oily soils and/or oily groundwater". In 1988, the MADEP issued a Notice of Responsibility (NOR) to Hatheway and Patterson Company, Inc. In 1990, the MADEP issued a Request for Short-Term Measure (STM) to address the imminent contamination of the Rumford River from the Site. Hatheway and Patterson Company,.Inc. started product recovery operations in 1991. In 1992, a Phase II Scope of Work was approved by the MADEP for further assessment activities.

In 1992, EPA's RCRA Program-personnel conducted inspections at Hatheway and Patterson Company, Inc.'s 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.

In January 1993, the MADEP requested that a second STM be performed at the Site which called for an additional site assessment followed by the implementation of environmental controls designed" to contain the release of contaminants to r the environment. In April 1993, manufacturing operations ceased, and the Site closed on 21 May 1993.

2.3 Cause of Release/Potential Release

In April 1993, Hatheway and Patterson Company, Inc. ceased operations, leaving wood treatment solvents and sludges in tanks, sumps, and drums at the Site. The Site was without heat or electricity, and freezing weather conditions posed the threat of release of these chemicals.

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, and PCP in various areas of the Site.

2.4 Efforts to Obtain Response by Responsible Parties

On 16 March 1993, EPA received a letter from counsel representing Hatheway and Patterson Company, Inc. stating that the company had voluntarily declared Chapter 11 bankruptcy and was without sufficient resources to respond to the EPA RCRA issued Information Request. Due to the declared bankruptcy and subsequent facility closure, the MADEP expressed concern regarding the conditions at the Site.

William Haynes, President of Hatheway and Patterson Company, Inc., was sent two Notice of Responsibility letters on 1 December 1993. One letter was addressed to Mr. Haynes personally, and the other was addressed to him as President of Hatheway and Patterson Company, Inc. and as Trustee of HPC Realty Trust. These letters notified Mr. Haynes of his potential liability regarding the Site, and of the upcoming removal activities which would occur at the Site. The letter invited Mr. Haynes to perform or finance the removal activities which were necessary at the Site. Mr. Haynes responded to both letters on 3 December 1994 . He indicated that he never in a personnel capacity operated any site in Mansfield, Massachusetts, and had no capacity or interest to act in any way on behalf of Hatheway and Patterson Company, Inc.

2.5 Response Organization

United States Environmental Protection Agency Emergency Services Division

Emergency Planning and Response Branch

On-Scene Coordinator —|

_L

STATE OF TOWN OF MANSFIELD MASSACHUSETTS Department of Environmental Protection

Department of Public Works, Fire Department, Health Department, Conservation Comm.

EPA RESOURCES: Regional Counsel, Environmental

Response Team (ERT)

Roy F. Western, Inc. .. William Haynejs Technical Assistance

Team/Superfund Technical Assessment and Response Team

OHM Response Manager

OHM Personnel Subcontractors

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2.6 Resources Committed

EPA.resources committed under this removal action began accruing on 7 December 1993 and are estimated as of 08 September 1995.

ERCS: $ 1,160,000 ERT/REAC: $ 48,000 TAT1: $ 83,600 START2: $ 23,500 EPA3: $ 109,700

Total Obligation as of 13 October 1995 $ 1,424,800

Accounting Information

Site ID #: X3 CERCLIS ID #: MAD001060805 ERCS Delivery Order #: 0012-01-018

aFinal estimated TAT costs are summarized by the following Technical Direction Documents (TDD):

TDD #01-9312-03 (A,A) $ 46,000 TDD #01-9312-04 (A,B) $ 1,800 TDD #01-9409-02 $ 5,600 TDD #01-9410-40 (A,B,C) ­ $ 30,200

Total: ' ~ $ 83,600

2Final estimated START costs are summarized by the following TDDs: -'- "

TDD #95-0610-15 (A,B,C) $ 23,500

3The EPA costs. ere .based on a $30/hour estimate for direct labor costs piust$60/hdur for indirect labor costs. Other indirect costs include .per diem, hotel charges and miscellaneous expenses.

In accordance with EPA guidance, the START/TAT costs include per diem, hotel charges and miscellaneous expenses.

2.7 Notification of Natural Resource Trustees

William Patterson of the Department of the Interior is designated as the Regional Environmental Officer, and is the liaison to the Natural Resource Trust. Mr. Patterson was informed of the removal action by receiving a copy of both Notice Letters sent to Mr. William Haynes dated 1 December 1993. He was kept informed of ongoing removal activities by receiving a copy of each Pollution Report (POLREP) issued by the OSC.

11

2.8 Natural Resource Trustee Assessment and Restoration Activities

The OSC is not aware of any Federal or state trustee damage assessment or restoration activities, being performed.

2.9 Chronological Summary of Activities

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 Conlon 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. , _ < . * - ­

ERGS personnel began cleaning out the office area. An OHM decontamination trailer and portable toilets arrived on site.

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.

Telephone jacks and electric meters were installed at the Site. Burns Security Service was initiated on site, with site security to be maintained during all non-working hours.

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.

12

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, two pipes cracked in the Cylinder No. 03 Building and the contents of the pipes had leaked into a sump also located inside the building.

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

TAT member Conlon and OHM Health and Safety Officer (HSO) Kym Mohrtnan 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 "open" western side of the Cylinder No. 03 Building was sealed up with plywood to reduce the wind chill factor in the building. 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 J:ire retardant) in Tank Nos. 01, 02 and 04 was completed (See Figures A-l, A-2, and A-3 in Appendix A for the tank locations). The samples were packaged and shipped via Federal Express to the manufacturer (Hicksoh Corporation) in Conley, Georgia. The samples were submitted jsjtp ,eyaluate 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. One of these, National Forest Products, was not interested in the CCA. However, Northeast Wood Treaters was interested in the dilute CCA, but was concerned about the sediment which may have accumulated in the tanks. They requested that the solution be filtered using a 25-micron filter prior to transporting the dilute CCA to their facility.

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 further flow

13

of rain water into the outside sump.

OHM personnel pumped liquid from the inside sump located in the Cylinder No. 03 Building into Tank Nos. 17 and 18. 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 & 02 Building and the Cylinder No. 03 Building to prevent the freezing of solution remaining in pipes and tanks.

Prior to accepting the dilute CCA solution, Northeast Wood Treaters required samples to be analyzed for chromium, copper, and arsenic to determine the ratio of these components in solution. Upon acceptance, Northeast Wood Treaters could initially take 15,000 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; ST Scenck continued to map the pipes connecting the various tanks on site. The CCA drip pad was re-covered 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 seized drums from around the Site were staged in the Mill Building. ' *• v «;'*.*•,; •.*,•

, - - » f it" -•' "•„• * '* A kerosene salamander heater, which was being used £o atori(**-. 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 & 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)

14

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 (without the use of a tracer). 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.

An ST and two Removal Technicians (RT) 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). During the night shift, Tank Nos. 06 and 07 foamed over while being aerated. The aeration was terminated and ERGS personnel began to clean up the PCP spill (in the containment area) using an absorbent material. The contaminated material was placed into a 500-gallon plastic carboy. Excess liquid in the containment area was pumped back into the tanks. Contaminated snow was placed into 55­gallon drums and staged in the Mill Building.

Monday. 3 January 1994 through Friday^ 7 January 1994

The remainder of the PCP spill was cleaned up and put in 55­gallon drums. 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' arrived on site and was set up. High pressure /Closes were placed into Tank Nos. 06 and 07 with warm water flowing through the hoses. This was 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 O'Koye, arrived on site. OSC Danek Burke and TAT member Conlon 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.

15

The temperature on the steam generator was turned down after the thermometer in one of the PCP tanks broke (Tank No. 06) . 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 on site. RM Coleman remained on site 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 to site.

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 & 02 Building in anticipation of line purging. Line purging began in the Cylinder No. 01 & 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 traces.f The contents were placed in one 55-gallon drum.* V'" . '*' ' ';'..' '

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 (~40,000 gallons). The facility appeared to be very well maintained.

OSC Danek Burke met with personnel from the Mansfield Wastewater Treatment Plant (WWTP) to discuss the possibility of discharging the Dricon solution (non-regulated) 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

16

contents were placed into 23 55-gallon drums. A manhole was cut to allow access to Tank No. 29 in the Cylinder No. 01 & 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, on time.

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 & 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.

The skid mount vacuum .truck was rinsed out with hot water and the residue blown out into a drum. OHM personnel began preparing to cut Tank No. 13. On 11 February 1995,. all_non­essential 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 * " •," J> ,1»WV * - t •

4l4.<2ui£Camples 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 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 EPA's future plans for the Site. Other

17

topics included: the location of monitoring wells, MADEP's 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 55 -gallon 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 KM Tallman while he was at the Pownal Tannery Site in Pownal, VT with OSC Danek Burke and other members of the ERGS crew.

Eight sludge and three liquid samples were collected for disposal analysis. The samples were 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.

Monda. 7 March 1994 through Friday. 11 March 1994

Removal of material from Tank No. 15 began and completed. One drum of vSbljLd waste and thirteen drums of liquid waste were generated. j -*'** *" ' f •• < '*

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 & 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 & 02 Building (which appeared to contain PCP liquid and sludge) were cleaned out and the contents drummed. One drum containing liquids and

18

two drums containing solids were generated.

Monday, 14 March 1994 through Friday. '18 March 1994

The MWD arrived on site and proceeded to excavate a portion of County Road to turn off water service to the Cylinder No. 01 & 02 Building. Due to the close proximity of the MWD crew to the Site, TAT member Conlon 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 EPA's 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. Tanker trucks (containing the dilute CCA solutions) were scheduled for shipping the next week.

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 PA/SI revealed high levels of arsenic (>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 55-gallon 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.

Monday. 21 March 1994 through Friday. 25 March 1994

Prior to shipment' of the dilute CCA solution to Northeast Wood Treaters, the manufacturer {Hickson Corporation), again raised concerns about the quality of the CCA. Hickson Corporation was worried that the constituents that make up CCA (copper, chromium and arsenic) could be out of balance. If so, Hickson Corporation felt it could potentially cause problems with the wood treatment process at the Northeast Wood Treaters facility. Three samples were collected from the most concentrated CCA tanks (Tank Nos. 17, 19 and 20), and were sent overnight to Hickson Corporation for immediate analysis.

OSC Danek Burke sent (via facsimile) the Certification of Proper Use, Treatment, Storage or Disposal of the CCA solution to Margery Adams of EPA's 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 (4,800 gallons)

19

of CCA was sent to Northeast Wood Treaters via Franklin Environmental Services (FES) 5,000-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 on site 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. The second shipment (4,900 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 FES's 5,000-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 55-gallon drums. An ERCS Chemist arrived on site to performed hazard categorization on various drums remaining on site.

Monday. IB 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 ERCS's Chemist Tobin.

The ERCS crew utilized an air-powered chipping hammer to remove dried PCP-resin off of the PCP drip pad (located behind the Cylinder No. 01 & 02 Building).

20

A different decontamination trailer arrived on site to replace the current decontamination trailer. An inventory was taken of contents in the replacement trailer.

Monday, 2 May 1994 through Friday, 6 May 1994

The removal of dried PCP-resin from the drip pad was completed, and the material was place 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 PCP-contaminated pallets in the Cylinder No. 01 & 02 Building were cut up and drummed. Decontamination of equipment began in anticipation of site demobilization.

Monday, 9 May 1994 through Friday, 13 May 1994

John Gilbert and Alan Humphrey of EPA's Emergency Response Team (ERT) arrived on site to assess the Site for the future surface sampling event (tentatively scheduled for July 1994). ERT's 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 PCP-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.

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 arose during the previous three months.

RM Tallman began securing personnel and equipment for the remainder of the removal action. FM McLaughlin proceeded to

21

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 DC Michael Schubert arrived on site (during the temporary demobilization, the ERGS 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 wastestreams present in drums and remaining in tanks on site.

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 on site 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

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

EPA Managers Steve Novick, Donald Bergerfand 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 & 07 (composite), Tank No. 05, and Drum No. 183 (which contained liquid from Tank No. 15) for PCP analysis to be performed at EPA's New England Regional Laboratory (NERL). The analysis was requested due to some discrepancies between results determined previously by 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

22

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 tanks/cylinders previously emptied. OHM personnel began to stage wood/debris from around the Site inside the Stacker Building.

Monday. 19 September 1994 through Friday, 23 September 1994

OHM personnel continued to gather "spent" lumber from the woods bordering the Rumford River. 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 Humphries of EPA's ERT and members of Roy F. Weston, Inc. REAC arrived on site. OSC Danek Burke, EPA/ERT 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), such as cresol, by immunoassay test kits. Arsenic, copper, chromium, and lead 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

23

conducted with OSC Danek Burke, TAT member Keefe and RM Blodgett.

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 A-5, A-6, A-7 and A-8 located in Appendix A. In addition, the field screening arsenic results are summarized in Table B-2, Arsenic Screening Results Summary, located in Appendix B. The final REAC report, entitled Soil Sampling and Field Screening, December 1994, can be referenced for additional information regarding the following screening results: copper, chromium, lead, PCP, and PAHs.

Tuesday, 4 October 1994 through Friday, 7 October 1994

OHM personnel temporarily mobilized off site. Disposal bids were reviewed by OSC Danek Burke, TAT member Keefe, and Disposal Coordinators Schubert and Taggart. The remobilization of the ERGS crew back to the Site was contingent upon treatment and disposal facility acceptance of each wastestream 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 (20­30%), 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.

24

Friday, 28 October 1994

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

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 Taggert, 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 wastestream 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 unable to accept this material and withdrew their bids.

Tuesday. 15 November 1994 f

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

25

300 drums located inside the Mill Building and the Kiln Building.

Capitol Environmental was awarded disposal of the bulk Dricon liquid. Seven 5,000-gallon tanker trucks from Freehold Cartage Inc. (FCI), Capitol's 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 E.I. DuPont, Deepwater, NJ for wastewater 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.

Monday, 5 December 1994 through Friday, 9 December 1994

Two 5,000-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 Taggart's drum map. OSC Danek Burke, RM Blodgett and TAT member Keefe discussed the most appropriate wastestream for a few miscellaneous drums. TAT member Keefe, assisted by the OHM crew, emptied unused drum samples into their original drum.

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.

OHM crew temporarily demobilized due to delays encountered in scheduling the next disposal vendor.

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.

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 & 02 Building to prevent the wastewater from freezing.

26

RT Williams mobilized to the Site to assist RM Blogett in emptying wooden bins and drums full of sawdust into twelve 1-cubic-yard boxes.

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

Dart Trucking, Inc. (Capitol Environmental's waste transporter) arrived on site to pick up a variety of hazardous waste drums. The waste included miscellaneous chemicals left by the former facility (i.e. 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.

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~stbrm 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. Security personnel returned the drums over the weekend to their original location. 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

27

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. FCI's 5,000-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.

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 5,000-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 confined space. 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 5,000-gallon tanker truck (for Entech, Inc.) and one 5,000-gallon tanker truck from FES arrived on site. OHM

28

personnel completed filling FCI's tanker with liquid waste from Tank Nos. 3Ob and 30c. FCI's 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 ERGS 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 5,000-gallon tanker truck arrived on site. TAT Keefe performed air monitoring above Tanks Nos. 30a, 3Ob, 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 3 Ob were also entered and pumped out into a FES tanker truck. Upon completion of Tank Nos. 30a, 3Ob, and 30c, the ERCS crew filled FES's 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 FES's 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 5-gallon 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.

Jim Dilorenzo, from EPA's Remedial Branch, 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.

29

MADEP representative Hutcheson and MADEP's contractor, Zecco, arrived on site and pumped out fuel oil from Tank No. 08 into a 3,000-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 flatbed 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 flatbed was loaded with drums containing sludges from Tank Nos. 12, 13, 14, 16, 27 and 29. Both flatbeds (loaded with drums) departed the Site for LWD, Inc. disposal facility to deliver the drums for treatment and/or 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 (EnTech's 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 (<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 FCI's 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, Wyoming, Rhode Island) to take down two large storage sheds on Hatheway & Patterson Company property. It would appear that the former president of Hatheway & 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 ERGS crew to enter the tank through two manways cut into the sides of the tank

30

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 ERGS 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 ERGS 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 and/or 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 ERGS 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. Aiello's 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 (ENSCO's transporter) and was used to transport 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

31

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 gravel/asphalt 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 gravel/asphalt cover. The sample locations are given in Figures A-5 through A-8, Sample Location Map(s), located in Appendix A. In addition, the field screening arsenic results are summarized in Table B-2, Arsenic Screening Results Summary, located in Appendix B.

Tuesday, 13 June 1995

ERGS personnel mobilized to the Site, including RM Blodgett's 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.

Wednesday. 14 June 1995

OSC Gardner met with abutting residents John Dwinell and Pam Gianetti to discuss site progress and future plans for the Site. Also arriving on site were MADEP representative Hutcheson and Mansfield Heath Department representative Scott Leite. The ERCS crew continued to clear contaminated areas of brush and debris.

Thursday. 15 June 1995

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 EPA's New England Regional Laboratory using a Kevex 7000 XRF analyzer. The sample locations are given in Figures A-5 through A-8, Sample Location Map(s), located in Appendix A. In addition,

j the Kevex screening results are summarized in Table B-2,

32

Arsenic Screening .Results Summary, located in Appendix B.

The ERGS crew continued to clear areas of brush and debris in preparation of the temporary graveI/asphalt cover.

Friday, 16 June 1995

ERGS crew continued to clear areas to be paved. OSC Gardner and RM Rhoad conducted a perimeter walk around the Site to inspect the condition of the fence.

Monday, 19 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 ERGS crew continued clearing and grubbing portions of the Site to receive temporary gravel/asphalt cover.

Tuesday. 20 June 1995

Lt. Joseph Sarro, from the Mansfield Fire Department, arrived on site to get an update on work progress from OSC Gardner. The ERGS crew continued to clear areas to be paved utilizing a "bush-hog" industrial mower. In addition, the crew began making repairs to some sections of the fence in the southern portion of the property. EPA/EPRB section chief Novick arrived on site to check on site progress.

Wednesday. 21 June 1995

The ERGS crew began to clear small trees, brush and overgrowth from the area around the seep outbreak in the southeastern portion of the Site.

Thursday. 22 June' 1995

The ERGS crew continued to expand the cleared area around the seep in preparation of installing geotextile fabric and gravel. In addition, the ERGS crew continued clearing and grubbing the northwestern portions of the Site for paving.

Friday. 23 June 1995

Six loads of gravel (approximately 36 tons/load) arrived on site. Locations receiving gravel are summarized in Figure A-4, Base Map - Location of Temporary Cover Map, located in Appendix A. The ERGS crew continued to prepare the northwestern portion of the Site, adjacent to the abutting residents on County Street/Belcher Court. 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.

33

Monday, 26 June 1995

Forty rolls of geotextile fabric, (150,000 sq. ft. total), arrived on site. The ERGS crew continued clearing and grubbing the northwestern portion 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.

Tuesday, 27 June 1995

The ERGS crew constructed a wooden fence around an exposed sump adjacent to the Cylinder No. 03 Building. The crew began preparation of smaller areas around and between the Kiln and the Cylinder No. 01 & 02 Building. Remaining brush and debris from the northwestern portion of the Site was moved to a central location.

Wednesday, 28 June 1995

The ERGS crew continued to hand shovel to lower the grade of the smaller areas around and between the Kiln Building, the Boiler Room and the Cylinder No. 01 & 02 Building. The ERGS crew placed fabric into the smaller prepared areas around the Mill Building and the Cylinder No. 01 & 02 Building.

Thursday, 29 June 1995

The ERGS crew continued to prepare the smaller areas around the Site for geotextile fabric and gravel. Preparations included manually shovelling material to bring down the existing grade, followed by placement of fabric and gravel.

Friday. 30 June 1995

The crew continued to prepare the smaller areas around the Mill Building, Kiln Building and the Cylinder No. 01 & 02 Building for geotextile fabric and gravel. In addition, the crew placed geotextile fabric (followed by gravel) around Tank No.8 (fuel tank) as well as around the concrete containment for the PCP tanks (Tank Nos. 05, 06 and 07). The ERGS crew secured the Site for the long holiday weekend.

Wednesday. 5 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 ERGS crew continued preparing smaller areas around the Mill Building, Kiln Building and the Cylinder No. 01 & 02 Building for grave1 cover.

34

Thursday. 6 July 1995

ERCS mobilized an Equipment Operator (EO) and a Komatsu 936 front-end loader to the Site to aid in moving and grading gravel. Surveyors from ADE completed the survey of existing grades and installed grade stakes at 50-foot intervals. 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 base/neutrals and acids (BNAs) and screened for metals at NERL.

Friday, 7 July 1995

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

The ERCS crew began placing geotextile fabric over contaminated areas adjacent to the CCA drip pad. Subsequently, an ERCS EO spread 3 - 5 inches of crushed gravel in this area with a front-end loader. In addition, the ERCS crew used the front-end loader to adjust the existing grade/slope in the northwestern portions of the Site (according to the stakes left by the surveyors). OSC Gardner updated abutting resident, James Sera, of site progress.

Tuesday. 11 July 1995

An additional six loads of gravel arrived on site. The ERCS crew completed spreading gravel adjacent to the CCA drip pad, and began grading the triangular area adjacent to County Street and the Rumford River. 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. The crew also began laying fabric and gravel in contaminated areas near the Office Building, as well as the triangular area adjacent to County Street and the Rumford River.

35

Wednesday. 12 July 1995

An additional 16 loads of gravel arrived on site, the majority of which was placed in the northwestern portion of the Site. The ERCS crew continued laying geotextile fabric in the northwestern portion of the Site, and used the front ­end loader to spread 3 inches of gravel over the fabric.

Thursday, 13 July 1995

An additional 28 loads of gravel arrived on site, the majority of which was placed in the northwestern portion of the Site. The ERCS crew continued to place geotextile fabric over contaminated areas. The front-end loader was used to apply 3 inches of crushed gravel over the fabric. The ERCS 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.

Friday. 14 July 1995

The smaller front-end loader continued to overheat, and RM Rhoad continued efforts to procure a replacement. In addition, the second (larger) loader (CAT F950) arrived on site. The ERCS crew continued to lay geotextile fabric in the northwestern portion of the Site and proceeded to spread 3-5 inches of crushed gravel on top of the fabric.

Monday. 17 July 1995

The ERCS crew continued grading the 3-5 inches of gravel in the northwestern portion of the Site. The replacement front-end loader (Dresser 520C) arrived on site. Additional areas receiving gravel cover were the long, thin strip between the fence'and the road, and the rectangular area between the river and the Dricon Building.

Tuesday. 18 July 1995

The ERCS crew continued grading the 3-5 inches of gravel in the northwestern portion of the Site as well as the contaminated strip parallel to the RR tracks. A total of 10 additional loads of gravel were delivered to the Site. Additional areas receiving geotextile fabric and gravel were the smaller areas around the Office Building as well as around the CCA building. Abutter J. Dwinell arrived on site to receive an update regarding site progress. In addition, MADEP Representatives Hutcheson and Richard Packard arrived on site to discuss site progress.

Wednesday. 19 July 1995

One additional load of gravel arrived on site. The ERCS crew continued to layout geotextile fabric followed by

36

gravel in the rectangular area located in the southeastern portion of the Site.

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.

One of the front-end loaders (Dresser 520C) was demobilized from the Site. The ERCS crew completed the area between the PCP tanks (Tank Nos. 06 and 07) and the fuel oil tank (Tank No. 08). In addition, a pipe leading into the Cylinder No. 01 & 02 Building was removed and placed inside the PCP containment. Two EOs were demobilized.

Thursday, 20 July 1995

The ERCS crew began and completed the installation of temporary cover (fabric and gravel) adjacent to the PCP drip pad and behind the Stacker Building. All contaminated areas on site were covered with geotextile fabric and gravel cover. The disposal of contaminated PPE was awarded to Capitol Environmental. RM Rhoad attached chains and locks to the manways to Tank Nos. 30a, 30b, and 30c. 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.

Friday. 21 July 1995

An ERCS welder, Daniel Corvelo, arrived on site to weld hasps onto both manways to Tank No. 1.— Subsequently, RM Rhoad applied locks to these manways. The CAT 950F front-end loader was mobilized off site. 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. Two RTs were demobilized from the Site.

Monday. 24 July 1995

The remaining ERCS crew consisted of RM Rhoad and RT Williams. RM Rhoad obtained two rolls of barb wire (approximately 1000 ft/roll). OSC Gardner assisted the ERCS crew with attaching a single strand of wire to 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 continued to prepare specifications for a fenc6 contractor.

37

Tuesday, 25 July 1995

The ERGS crew continued to make repairs to the fence in the southern portions of the Site. Repairs consisted of the addition of a single strand of barb wire to the tops of the wooden fence posts and fixing holes in the fence with pieces of barb wire.

Wednesday. 26 July 1995

Dart Trucking, Inc. (Capital Environmental Service's transporter) arrived on site to pick up the PCP-contaminated PPE. Also arriving on site was ERGS 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. RM Rhoad and RT Williams continued to make repairs to the fence in the southern portions of the Site.

Thursday, 27 July 1995

The ERGS 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 arrived on site to prepare a 4-foot wide strip for the installation of a 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 199-5

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-fcsr the Site. Representatives from the MADEP, the Town of Mansfield and EPA EPRB were present.

Thursday. 10 August 1995

Tilcon, Inc. (the paving subcontractor) arrived on site to level and compact the gravel in areas receiving asphalt.

Friday. 11 August 1995

The process buildings on site were secured with additional locks, and warning signs were posted on building entrances.

Monday. 14 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.

38

Tuesday. 15 August 1995

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

Members of the Custom Fence crew (fencing subcontractor) arrived on site to begin making repairs to the existing fence and begin installation of new sections of fence in the southwestern portion of the Site. Figure A-4, Base Map ­Temporary Cover Map, located in Appendix A, details both the old and new sections of fence located around the Site.

Thursday, 24 August 1995

Members of Custom Fence continued with the installation of new fence in the southwestern portion of the Site. OSC Gardner met with a representative of the local newspaper to discuss an upcoming article pertaining to recent site activities.

Friday. 25 August 1995

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.

RM Rhoad made arrangements to have all rented equipment and supplies demobilized off site early next week.

Monday. 28 August 1995

Members of the Custom Fence crew arrived on "site to continue the installation of new sections of fence. The following equipment was demobilized from the Site: trash dumpster, Bobcat and water cooler.

Tuesday. 29 August 1995

No site activities occurred. Best Business, Inc. arrived on site to remove the facsimile machine and the photocopier.

39

Wednesday. 30 August 1995

Members of the Custom Fence crew arrived on site and completed the installation of the fence in the southwestern portion of the Site. The crew proceeded to continue making repairs to various sections of the existing fence. START member Keefe and RM Rhoad placed additional warning signs on the new fence. Cap Cod Sandcastles arrived on site to remove their portable toilet.

Thursday, 31 August 1995

Members of Custom Fence arrived on site to continue making fence repairs and installing smaller sections of fence in the northwest portion of the Site. In anticipation of complete demobilization, the electrical and water utility services were disconnected from the Office Building (command post).

Friday, 01 September 1995

Lit. Sarro, from the Mansfield Fire Dept., arrived on site to check the fire alarm system, tie verified that the system was activated and operational. The Custom Fence crew completed the remaining fence repairs and installation of new fence. START member Keefe placed additional warning sign on the new sections of fence in the northern sections of the Site. All remaining equipment and supplies were demobilized from the Site. All gates and buildings were locked and secured. START member Keefe and RM Rhoad departed the Site.

2.10 Treatment/Disposal/Alternative Technology

Approximately 40,poo 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, which is based solely on the use of CCA (i.e. no PCP) .

Each wastestream was disposed of in the most cost-effective manner for this site, dependent upon the waste categorization. All material was disposed of at facilities in compliance with the CERCLA Off-Site Policy.

2.11 Community Relations

Involvement with the community leaders of the Town of Mansfield was coordinated by the OSC, both prior to and during the removal action.

Prior to the first week of mobilization to the Site, the local hospital, the local police and fire departments, and the health department were notified of scheduled activities.

40

Throughout the duration of the project, POLREPs were prepared initially by OSC Danek Burke'and then by OSC Gardner. All POLREPs were sent to federal, state, and local officials to keep them informed of site activities. A total of 12 POLREPs were issued between December 13, 1993 and September 6, 1995.

A press release was issued by the EPA on 23 August 1995 to the media summarizing the work completed at the Site and future plans. During the following week, several articles appeared in area newspapers documenting EPA's accomplishments in cleaning up the Site.

2.12 Health and Safety

In order to complete the removal action in a safe manner, EPA and its' contractors prepared site work and safety plans prior to site mobilization to ensure that all parties working on the Site would be adequately protected. The objectives of the site safety plan were to assign responsibilities to individuals involved with site safety, to establish personnel safety and protection standards, and to establish mandatory safety operating procedures relative to the drummed and containerized materials on the Site. Exclusion zones and decontamination areas were instituted, and a contingency plan was established to address any unforeseen emergencies that may have arisen during the removal action.

The provisions of the safety plan were made mandatory for all personnel who entered the Site during site operations. All appropriate safety equipment was available and utilized by site personnel. For a portion of this removal action OHM's HSO, Kym Mohrman, was on site to assist START/TAT members with the

« implementation of the Site Safety Program.

Air monitoring was frequently conducted by START/TAT personnel to insure that the selected levels of PPE were adequate. In addition, air monitoring was performed prior to all confined space entries.

A salamander kerosene heater caught fire on 29 December 1993. The ERGS crew successfully extinguished the fire using hand-held fire extinguishers. The rented heater was returned to the rental company the following week.

The site health and safety plan is available for review at the U.S. EPA, New England Regional Laboratory, 60 Westview Street, Lexington, MA 02173.

3.0 EFFECTIVENESS OF THE REMOVAL

3.l The Responsible Parties

To be completed by EPA Enforcement Coordinator.

41

3 .2 State and Local Agencies

The MADEP has been involved with the Hatheway and Patterson Company, Inc. Site for over 20 years, beginning with releases of oils to the Rumford River and the surrounding wetlands in 1972. On 2 May 1987, MADEP issued a Notice of Noncompliance (NON) to Hatheway and Patterson Company, Inc.. The NON required Hatheway and Patterson Company, Inc. to complete a Phase I preliminary site investigation pursuant to Massachusetts General Laws, Chapter 21E, Section 4 and 5. After reviewing the results of the site investigation, the MADEP determined that Hatheway and Patterson Company, Inc. was responsible for the release of hazardous chemicals.

During the removal action the 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.

3.3 Federal Agencies

The EPA responded to the request for assistance from the MADEP and began the removal action on 7 December 1993. An Action Memorandum was signed on 3 December 1993, and removal activities commenced on 7 December 1993. The EPA OSC employed the most cost-effective removal methods available for the particular situation while minimizing the potential threat to nearby residents.

3.4 Contractors and Private Groups

The ERGS contractor for the Hatheway and Patterson Company, Inc. Site was OHM Remediation Services, Inc. This contractor provided the personnel, materials, and equipment necessary for the successful completion of the project.

Roy F. Weston, Inc. provided the TAT/START support for this removal action. Additional support was provided under the START contract. Members of TAT/START provided the OSC with a site safety plan, monitored the ERGS contractor to ensure that proper removal procedures were used, assisted the OSC with site documentation, provided data review of disposal analyses, performed air monitoring, and assisted the OSC regarding disposal options.

4.0 DIFFICULTIES ENCOUNTERED

To prevent the Duratreet in Tanks Nos. 06 and 07 from freezing, aeration was initially performed. The tanks overflowed into the containment areas as the aeration began. OHM personnel cleaned up the spill using speedy dry and put the mixture of PGP (Duratreet) and speedy dry in 55-gallon drums. Snow that accumulated in the containment area was

42

also drummed.

Frozen pipes in the Cylinder No. 03 Building ruptured and began leaking once the temperature increased. The contents of the pipes collected in a sump, also located inside the Cylinder No. 03 Building. The material was pumped from the sump into 55-gallon drums for disposal.

5.0 RECOMMENDATIONS

5.1 Prevention of Similar Release

The release of hazardous substances may have resulted from improper closure procedures at the facility and the storage of treated lumber above "bare" ground. Proper enforcement of current environmental regulations should minimize similar releases.

5.2 Improvement of_Response Actions

To be completed by OSC.

43

APPENDIX A

ADDITIONAL SITE MAPS

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TABLE B-2 ARSENIC SCREENING RESULTS SUMMARY

HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

SAMPLE ID

HP1-A5 HP1-B5 HP1-C5 HP1-D5 HP1-E5 HP1-F5 HP1-G5 HP1-H5 HP1-I5 HP1-J5

| HP1-K5 HP1-L5 HP1-M1 HP1-M2 HP1-M3 HP1-M4 HP1-M5 HP1-N5 HP1-O5 HP2-A HP2-B HP2-C HP3-A5 HP3-B5 HP3-C5 HP3-D5 HP4-A HP4-B HP4-C HP4-D HP4-E HP4-F HP4-G HP4-H HP5-A HP5-B HP5-C HP5-D HP5-E HP5-F HP5-G HP5-H HP5-I HP5-J HP5-K HP5-L HP5-M 5T-A

COLLECTED BY

WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REACWESTON-REACWESTON-REACWESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REACWESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC WESTON-REAC

DATE COLLECTED

9/27/949/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94

I 9/27/94 ; 9/27/94 ! 9/27/94

9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94 9/27/94

j 9/27/94 9/27/94 9/27/94 9/27/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94 9/26/94

I 9/27/94

SCREENING METHOD

I SPECTRACE* SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE

I SPECTRACE

SAMPLE TYPE

Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite Composite

Grab Grab Grab

Composite Composite Composite Composite

Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab

In- Situ

ARSENIC (ppm)

270 97 J 100J 220 460 320 200 65 J 220 70 J 130 J 640 710 870 1200 2000 1300 670 i 400 i 590 58 J 92 J 1300

43008% 1400 2200 1100 780 2300 , 28OO . 2600 , 1000 . 2300 780 48U 53 J 48U 96J > 350 180

110J 180

120J 220 48U 51J 61J

I 87U |

Page 1 ofS

TABLE B-2 ARSENIC SCREENING RESULTS SUMMARY

HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

SAMPLE COLLECTED DATE SCREENING SAMPLE ID BY COLLECTED METHOD TYPE

5T-B WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-C WESTON-REAC 9/27/94 SPECTRACE In -Situ 5T-D WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-E WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-F WESTON-REAC 9/27/94 SPECTRACE In-Situ

L__ 5T-G WESTON-REAC 9/28/94 SPECTRACE In-Situ 5T-H WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-I WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-J WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-K WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-L WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-M WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-N WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-O WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-P WESTON-REAC 9/27/94 SPECTRACE In-Situ 5T-Q WESTON-REAC 9/27/94 SPECTRACE In-Situ

C1 WESTON-REAC 9/26/94 SPECTRACE In-Situ C2 WESTON-REAC 9/26/94 SPECTRACE In-Situ C3 WESTON-REAC 9/26/94 SPECTRACE In-Situ C4 WESTON-REAC 9/28/94 SPECTRACE In-Situ C5 WESTON-REAC 9/28/94 SPECTRACE In-Situ C6 WESTON-REAC 9/28/94 SPECTRACE In-Situ C7 WESTON-REAC 9/28/94 SPECTRACE In-Situ RC1 WESTON-REAC 9/26/94 SPECTRACE In-Situ RC2 WESTON-REAC 9/28/94 SPECTRACE In-Situ

HP1-M5-01 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-M5-02 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-N5-01 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-N5-02 WESTON-TAT 4/27/95 SPECTRACE Grab HP2-A-01 WESTON-TAT 4/27/95 SPECTRACE Grab

! HP2-A-02 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-5E-01 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-5E-02 WESTON-TAT 4/27/95 SPECTRACE Grab

RC1-01 WESTON-TAT 4/27/95 SPECTRACE Grab RC1 -02 WESTON-TAT 4/27/95 SPECTRACE Grab RC2-01 WESTON-TAT 4/27/95 SPECTRACE Grab RC2-02 WESTON-TAT 4/27/95 SPECTRACE Grab 5TH-01 WESTON-TAT 4/27/95 SPECTRACE Grab 5TH-02 WESTON-TAT 4/27/95 SPECTRACE Grab C2-01 WESTON-TAT 4/27/95 SPECTRACE . Grab C2-02 WESTON-TAT 4/27/95 SPECTRACE Grab C3-01 WESTON-TAT 4/27/95 SPECTRACE Grab C3-02 WESTON-TAT 4/27/95 SPECTRACE Grab

HP1-L5-01 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-L5-02 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-L5-03 WESTON-TAT 4/27/95 SPECTRACE r Grab HP1-L5-04 WESTON-TAT 4/27/95 SPECTRACE Grab HP1-F5-02 WESTON-TAT 4/27/95 SPECTRACE Grab

ARSENIC (ppm) 87 U 87 U 87 U 87 U 87 U 87 U 450 98 J 87 U 130 J 600 87 U 87 U 87 U 87 U 87 U 130 J 480 880 87 U 120 J 87 U 310 440 540 690 150 320 690 250 800 310 440 ' 610 ' 250 ' 310 290 590 410 190 '

I999&* • 120 . 270 70 J 450 490 90 J 140

Page 2 of 5

TABLE B-2 ARSENIC SCREENING RESULTS SUMMARY

HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

SAMPLE ID

HP1-F5-03 HP1-F5-04

STL- 01 5TL-02 C6-01 C6-02 C7-01 C7-02

HP1-E5-01 HP1-E5-02 HP1-E5-03 HP1-E5-04

STA-001 STA-002 STA-003 STA-004 STA-005 STA-006 STA-007 STA-008 STA-009 STA-010 STA-011 STA-012 STA-013 STA-014 STA-015 STA-016 STA-017 STA-018 STA-019

STA-020 STA-021 STA-022 STA-023 STA-024 STA-025 STA-026 STA-027 STA-028 STA-029 STA-030 STA-031 STA-032 STA-033 STA-034 STA-035 STA-036

COLLECTED BY

WESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TAT WESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TATWESTON-TATWESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TATWESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TATWESTON-TAT

DATE COLLECTED

' 4/27/95 ! 4/27/95

4/27/95 ' 4/27/95 , 4/27/95

4/27/95 4/27/95 4/27/95

I 4/27/95 4/27/95

> 4/27/95 4/27/95

! 05/09/95 ' 05/09/95 . 05/09/95

; 05/09/95 05/09/95 ! 05/09/95 05/09/95

05/09/95 05/09/95 05/09/95 05/09/95 05/09/95 05/09/95

05/09/95 05/09/95 05/09/95 05/09/95

i 05/09/95 i 05/09/95

06/15/95 06/15/95 06/15/95 06/15/95 06/15/95

i 06/15/95 06/15/95 06/15/95 06/15/95 06/15/95 06/15/95

! 06/15/95 06/15/95 06/15/95 06/15/95

| 06/15/95 06/15/95

SCREENING METHOD

SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE

SPECTRACE SPECTRACE SPECTRACE

SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE SPECTRACE

KEVEX** KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX KEVEX

SAMPLE TYPE Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab GrabGrab Grab Grab Grab Grab Grab Grab

. Grab Grab Grab Grab Grab Grab Grab Grab Grab

ARSENIC (pom)

570 130 210 240 50 J 34 U 440 370 570 120

100 J 820

190 520 190 | 45U 90 J 100J 170 400 70 J 80 J 130J 110J 110J 390 470

130J 180

120J ! 110J

87 40 28 60 250 25 122 134 6U 6U 6U 6U 6U 100 6U 6U 12J

Page 3 of 5

TABLE B-2 ARSENIC SCREENING RESULTS SUMMARY

HATHEWAY AND PATTERSON SITE MANSFIELD, MASSACHUSETTS

SAMPLE COLLECTED DATE SCREENING SAMPLE ARSENIC ID BY COLLECTED METHOD TYPE (pom)

STA-037 ', WESTON-TAT 06/15/95 KEVEX Grab > 6 U STA-038 WESTON-TAT 06/15/95 KEVEX Grab 61) STA-039 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-040 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-041 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-042 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-043 WESTON-TAT 06/15/95 KEVEX Grab 122 STA-044 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-045 WESTON-TAT 06/15/95 KEVEX Grab 12J STA-046 WESTON-TAT 06/15/95 KEVEX Grab 25 STA-047 WESTON-TAT 06/15/95 KEVEX Grab 122 STA-048 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-049 WESTON-TAT _ 06/15/95 KEVEX Grab 19 STA-050 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-051 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-052 WESTON-TAT 06/15/95 KEVEX Grab 6U STA-055 WESTON-TAT 06/15/95 KEVEX Grab 125 STA-056 WESTON-TAT 06/15/95 KEVEX Grab 28 BM+50 WESTON-TAT 06/15/95 KEVEX Grab 81 BM+65 WESTON-TAT 06/15/95 KEVEX Grab 18J BM+80 WESTON-TAT 06/15/95 KEVEX Grab 6U -A+60 WESTON-TAT 06/15/95 KEVEX Grab 178 -A+85 WESTON-TAT 06/15/95 KEVEX Grab 84 -A-t-100 WESTON-TAT 06/15/95 KEVEX Grab 37 -B+180 WESTON-TAT 06/15/95 KEVEX Grab 59 -B+195 WESTON-TAT 06/15/95 KEVEX Grab 87 -B+210 WESTON-TAT 06/15/95 KEVEX Grab 56 -E+30 WESTON-TAT 06/15/95 KEVEX Grab 6U -E+60 WESTON-TAT 06/15/95 KEVEX Grab 16

j -E+90 WESTON-TAT ! 06/15/95 KEVEX Grab 22 -F+30 WESTON-TAT 06/15/95 KEVEX Grab 63 -F+60 WESTON-TAT 06/15/95 KEVEX Grab 260 -F+90 WESTON-TAT 06/15/95 KEVEX Grab 6U -G+30 WESTON-TAT 06/15/95 KEVEX Grab 15 -G+60 WESTON-TAT 06/15/95 KEVEX Grab 25 -G+90 WESTON-TAT 06/15/95 KEVEX Grab 40 -H+30 WESTON-TAT 06/15/95 KEVEX Grab 144 -J+20 WESTON-TAT 06/15/95 KEVEX Grab 175 -K+20 WESTON-TAT 06/15/95 KEVEX Grab 68

i -L+30 WESTON-TAT 06/15/95 KEVEX Grab 87 I -M+25 WESTON-TAT 06/15/95 KEVEX Grab 97

-M+35 WESTON-TAT 06/15/95 KEVEX Grab 460 -M+45 WESTON-TAT 06/15/95 KEVEX Grab 36 -B-10 WESTON-TAT 06/15/95 KEVEX Grab 115 -D-10 WESTON-TAT 06/15/95 KEVEX Grab 100

; -F-10 WESTON-TAT 06/15/95 KEVEX Grab 62 -H-10 WESTON-TAT 06/15/95 KEVEX Grab 32 -J-10 WESTON-TAT 06/15/95 KEVEX Grab 68

C+20 WESTON-TAT 06/15/95 KEVEX Grab 275

Page 4 of 5

TABLE B-2 ARSENIC SCREENING RESULTS SUMMARY

SAMPLE ID

D+20 E+25 F+30 G+35 H+30 L+50 M+50 N+50 O+25 C-10 E-10 G-10 1-15 K-15 M-15 O-1S

STA-057 STL-2

STA-058 STA-059

u

SPECTRACE*

KEVEX**

HATHEWAYAND PATTERSON SITE MANSFIELD, MASSACHUSETTS

COLLECTED DATE SCREENING BY COLLECTED METHOD

WESTON-TAT iWESTON-TATWESTON-TAT !WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT iWESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT WESTON-TAT

06/15/95 KEVEX 06/15/95 KEVEX

06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX

06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 - KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/15/95 KEVEX 06/22/95 KEVEX 06/22/95 KEVEX 07/06/95 KEVEX 07/06/95 KEVEX

SAMPLE ARSENIC TYPE (ppm) Grab 75 Grab 100 Grab 275 Grab 28 Grab 175 Grab 61) Grab 6U Grab 27 Grab 34 Grab 66 Grab 60 Grab 244 Grab 94 Grab 19 Grab 25 Grab 28 Grab 6U Grab 420 Grab 6U Grab 6U

Denotes the analyte was not detected. The associated numerical value is the method detection limit. The associated numerical value is an estimated quantity because the reported concentrations were less than the method quantitation limit. Samples analyzed on-site for arsenic utilizing a Spectrace 9000 X-Ray Fluorescence (XRR analyzer. Samples submitted and analyzed for arsenic at EPA's New England Regional Laboratory utilizing a Kevex 7000 XRF analyzer. Parts per million (ug/g).

T:\95061015\ARSENIC.WK1 10/03/95

Page 5 of 5

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