removal program preliminary assessment/site …date of inspection: 25 april 2014 ; time of...

REMOVAL PROGRAM PRELIMINARY ASSESSMENT/

SITE INVESTIGATION REPORT FOR THE

IRVING TANNING COMPANY HARTLAND, SOMERSET COUNTY, MAINE

25 APRIL 2014

Prepared For:

U.S. Environmental Protection Agency Region I

Emergency Planning and Response Branch 5 Post Office Square, Suite 100

Boston, Massachusetts 02109-3912

CONTRACT NO. EP-W-05-042

TDD NO. 01-14-01-0007

TASK NO. 0930

DC NO. R-7675

Submitted By:

Weston Solutions, Inc. Region I

Superfund Technical Assessment and Response Team (START)

3 Riverside Drive

Andover, MA 01810

June 2014

TABLE OF CONTENTS

I. Preliminary Assessment/Site Investigation Forms

II. Narrative Chronology

III. Appendices

Appendix A

Appendix B

Appendix C

Appendix D

- Figures

- Tables and Spreadsheets

- Photodocumentation Log

- Analytical Data and Chain-of-Custody Record

I. Preliminary Assessment/Site Investigation Forms

EPA REGION I REMOVAL PRELIMINARY ASSESSMENT

Site Name and Location

Name: Irving Tanning Company Location: 24 Pleasant Street Town: Hartland County: Somerset State: Maine

Site Status: ( ) NPL ( ) NON-NPL ( ) RCRA ( ) TSCA () ACTIVE ( ) ABANDONED () OTHER Tanning activities are no longer conducted on the property, but

portions of the building are rented out as storage space.

() Attached USGS Map of Location () Site I.D. No.: 01LL

Latitude: 44º 52′ 57″ North Longitude: 69º 27′ 09″ West

Referral

( ) Citizen ( ) City/Town () State ( ) Preremedial ( ) RCRA ( ) Other:

Name of referring party: Maine Department of Environmental Protection (MEDEP) Telephone: (207) 446-2564 Address: 17 State House Station, Augusta, Maine, 04333

Contacts Identified 1)Brian Beneski, MEDEP Telephone:(207) 287-4858 2)Becky Blais, MEDEP Telephone:(207) 446-2564

Source of Information

( ) Verbal: ( ) Report: () Other: Request for United States Environmental Protection Agency (US EPA) Removal Program Assistance Letter

Potential Responsible Parties

Owner: Irving Tanning Company Telephone: NA Address: NA Operator: Tasman Tanning Telephone:(207) 553-3700 Address: 9 Main Street, Hartland, Maine

1R:\14010007\Reports\PASI\0930_PA

REMOVAL PRELIMINARY ASSESSMENT

Site Access

Authorizing Person: Wayne Chase (Facilities Engineer, Tasman Tanning Company) Date: 25 April 2014 ()Obtained ()Verbal Email: [email protected] ( )Not Obtained ( )Written

Historical Preservation

( ) Site is Historically Significant or Eligible for Historic Preservation

Contacts Identified

1) State Historical Preservation Officer (SHPO) Name: Earle G. Shettleworth, Jr Telephone:(207) 287-2132 2) Tribal Historical Preservation Officer (THPO) Name: Christopher Sockalexis Telephone:(207) 817-7471

Comments:

Physical Site Characterization

Background Information: The Irving Tanning Company site (the site) is located at 24 Pleasant Street, Hartland, Somerset County, Maine (ME). The approximately 16-acre site contains a factory building that served as an annex for the Irving Tanning Company main building (ITC main building) located on Main Street. The site is bordered to the north by Pleasant Street, residential properties, and the Sebasticook River; to the west by wooded areas and a landfill; to the south by Lower Main Street and commercial/residential properties; and to the east by the Sebasticook River, Pleasant Street, and commercial/residential properties.

From approximately 1936 until 2005, Irving Tanning Company operated as a side-leather tannery at the ITC main building and at the site (i.e., the annex). In 2005, Irving Tanning Company was acquired by former management and Meriturn Partners, LLC. At that time, Irving Tanning Company had a capacity to finish over 30 million feet of leather per year.

In 2007, Irving Tanning Company merged with Prime Tanning Company and continued operations on the site. In 2010, Prime Tanning Company filed for bankruptcy, and was acquired in 2011 by Tasman Tannery. Under the new ownership, operations continue currently at the ITC main building, but have been discontinued at the site.

In January 2014, MEDEP inspected the annex and identified approximately 24 drums of chemicals used in the tanning process. Additional containers and equipment may exist on the property. MEDEP requested EPA assistance for the inventory and removal of drums and other potential hazardous materials at the site.

2R:\14010007\Reports\PASI\0930 PA

mailto:[email protected]


Description of Substances Possibly Present, Known or Alleged: Drum labels indicate the following substances: corrosives, flammables. The following substances were identified during prior investigations: ethylbenzene, methyl isobutyl ketone, toluene, 1,2,4-trimethylbenzene, xylenes, and diisobutyl ketone.

Existing Analytical Data

( ) Real-Time Monitoring Data:

() Sampling Data: In August 1995, Acheron Inc. collected 23 soil samples from the site. The samples were analyzed for volatile organic compounds (VOCs).

Analytical results indicated the following VOCs [maximum concentrations, in parts per million (ppm), in parentheses]: ethylbenzene (732.8 ppm); toluene (122.2 ppm); 1,2,4-trimethylbenzene (121.5 ppm); xylenes (2,710.9 ppm); and diisobutyl ketone (3,380 ppm).

In November 2004, Woodard and Curran collected 20 groundwater samples from monitoring wells located on the site. The samples were analyzed for VOCs.

Analytical results indicated the following VOCs [maximum concentrations, in parts per billion (ppb), in parentheses]: ethylbenzene (4,110 ppb); methyl isobutyl ketone (4,090 ppb); toluene (19,300 ppb); 1,2,4-trimethylbenzene (11 ppb); xylenes (6,714 ppb); and diisobutyl ketone (7,010 ppb).

Potential Threat

Description of potential hazards to environment and/or population-identify any of the criteria for a Removal Action (from NCP) that may be met by the site under 40 CFR 300.415 [b] [2].

i. Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances, pollutants or contaminants.

ii. Actual or potential contamination of drinking water supplies or sensitive ecosystems.

iii. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release.

iv. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate.

v. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released.

vi. Threat of fire or explosion.



vii. The availability of other appropriate federal or state response mechanisms to respond to the release.

viii. Other situations or factors that may pose threats to public health or welfare or the environment.

Prior Response Activities

( ) PRP () STATE () FEDERAL ( ) OTHER Brief Description: In the late 1980s, MEDEP requested that Irving Tanning Company conduct analyses on composted hair waste that had been disposed of on site. Cleanup activities began and were completed in 1994. MEDEP then began an investigation into the Irving Tanning Company annex (i.e., the site), where tanning chemicals were stored. At some point between 1980 and 1994, the chemicals were piped into a ditch. Twenty monitoring wells were installed on the property, and soil samples were collected. Contaminants of concern included ethylbenzene, methyl isobutyl ketone, toluene, 1,2,4-trimethylbenzene, xylenes, and diisobutyl ketone. In 1999, EPA completed a Resource Conservation and Recovery Act (RCRA) Corrective Action Environmental Indicator (EI) determination and verified “Current Human Exposures Under Control” status for the site.

Priority for Site Investigation

() High ( ) Medium ( )Low ( ) None Comments:

Report Generation

Originator: Erin Mulholland Date: 2 May 2014 Affiliation: Weston Solutions (START) Telephone: (978) 552-2107 TDD No.: 01-14-01-0007 Task No.: 0930


EPA REGION I REMOVAL SITE INVESTIGATION

Inspection Information

Site Name: Irving Tanning Company Address: 24 Pleasant Street Town: Hartland County: Somerset State: Maine Date of Inspection: 25 April 2014 Time of Inspection: 0800 hours Weather Conditions: 44° Fahrenheit, Windy, Sunny Site Status at Time of Inspection: () ACTIVE () INACTIVE Comments: Irving Tanning Company operated as a side-leather tannery from approximately 1936 until 2005. Currently, operations continue only in the main tannery building located on Main Street. The annex building is located on the Irving Tannery Company site (i.e., the site), which is the focus of this site investigation (SI). Portions of the annex building are currently leased as storage space.

Agencies/Personnel Performing Inspection

Names Program

() EPA: John McKeown U.S. Environmental Protection Agency (EPA) Region I, Emergency Planning and Response Branch (EPRB), On-Scene Coordinator (OSC)

() EPA Contractor: Eric Ackerman Weston Solutions, Inc. (WESTON), John Burton Superfund Technical Assessment and Erin Mulholland Response Team III (START) Ken Robinson

() State: Becky Blais Maine Department of Environmental Protection (MEDEP), Environmental Specialist, Division of Remediation

Current Owner Based on Field Interview:

1 R:\14010007\Reports\PASI\0930_SI

REMOVAL SITE INVESTIGATION

Physical Site Characteristics

Parameter Quantities/Extent ( ) Cylinders: () Drums: Approximately 46 drums were found in one room of the

annex building. The drums were stored on pallets. Out of these, 41 were clearly labeled. The remaining drums were unlabeled, or the labels were illegible. A complete drum inventory was performed, and the results are as follows: 27 55-gallon polyethylene (poly) drums, six 55-gallon steel drums, one 55-gallon fiber drum, three 35-gallon poly drums, four 30-gallon poly drums, one 30-gallon fiber drum, three 5-gallon jugs, and one 2-gallon jug.

( ) Lagoons: () Tanks: () Above: Three aboveground storage tanks (ASTs) were observed at

a fueling station on the southeastern portion of the site. ( ) Below:

( ) Asbestos: ( ) Piles: ( ) Stained Soil: ( ) Sheens: ( ) Stressed Vegetation: () Landfill: There is a landfill located west of the site. As of 2012,

Irving Tanning Company owned the landfill. () Population in Vicinity: There are several residential properties to the east and south

of the site. () Wells: ( ) Drinking:

() Monitoring: As part of an earlier investigation, 20 monitoring wells were installed on the site. Four of these monitoring wells were located by START personnel on the eastern portion of the property. The four located monitoring wells were 1-inch polyvinyl chloride (PVC) stick-up wells.

( ) Other:

R:\14010007\Reports\PASI\0930_SI

2


Physical Site Observations

The Irving Tanning Company site (the site) is located at 24 Pleasant Street, Hartland, Somerset County, Maine (ME). The approximately 16-acre site contains a series of interconnected factory buildings that served as an annex for the main tannery. Two portions of the building complex are currently being leased as storage. A roof in one of the leased storage areas of the building complex collapsed sometime between January 2014 and 25 April 2014. The remainder of the building complex contains abandoned equipment and machinery from the Irving Tanning Company. The site is sparsely vegetated with grass and small trees. The site is bordered to the north by Pleasant Street, residential properties and the Sebasticook River; to the west by wooded areas and a landfill; to the south by Lower Main Street and commercial/residential properties; and to the east by the Sebasticook River, Pleasant Street, and commercial/residential properties.

Field Sampling and Analysis

Matrix/Analytical Parameter CGI/O2

Field Instrumentation RAD PID FID Other3

Background 0.0% / 20.9% 10-15 µR/hr1 0.0 ppm2 0.0 ppm 0/0 Readings: Air: 0.0% / 20.9% 10-15 µR/hr 0.0 ppm 0.0 ppm 0/0 Drums: 0.0% / 20.9% 10-15 µR/hr 0.0 ppm 0.0 ppm 0/0 Other:

1 µR/hr = microRoentgens per hour 2 ppm = parts per million 3 Carbon monoxide (CO)/hydrogen sulfide (H2S)

Field Quality Control Procedures

() SOP Followed ( ) Deviation From SOP Comments: START followed the protocol outlined in the document, entitled Sampling and Analysis Plan for the Irving Tanning Company Site, Hartland, Somerset County, Maine dated April 2014.

Description of Sampling Conducted

On 25 April 2014, EPA and START personnel mobilized to the site and collected six drum samples from drums suspected of containing corrosives, flammables, or solvents. Samples were characterized by field hazards categorization (HAZCAT) for pH and flammability, before being submitted to the EPA Office of Environmental Measurement and Evaluation (OEME) New England Regional Laboratory (NERL), located in North Chelmsford, Massachusetts, for pH and flammability analyses.


3


Analyses

Analytical Parameter Media Laboratory ( ) VOC ( ) AIR () NERL ( ) PCB ( ) WATER ( ) CLP ( ) PESTICIDE ( ) SOIL ( ) PRIVATE ( ) METALS ( ) SOURCE ( ) DAS ( ) CYANIDE ( ) SEDIMENT ( ) SOW ( ) SVOC ( ) SOIL GAS ( ) FIELD ( ) TOXICITY ()PRODUCT ( ) DIOXIN ( ) ASBESTOS () OTHER: pH, flashpoint

Analytical results: See attached

Receptors

Comments () Drinking Water: () Private: Because the site is in a rural area, it

is assumed that a portion of the residents utilize private drinking water wells. () Municipal: The local municipal water supply is the Maine Water Company, Hartland Division.

( ) Groundwater:

() Unrestricted Access: The property is not gated or otherwise secured.

() Population in Proximity: Residential areas are located north and east of the property. ( ) Sensitive Ecosystem: ( ) Other:

Additional Procedures for Site Determination

( ) Biological Evaluation ( ) ATSDR

Site Determination

Depending on further information, criteria that may be met by the site include 40 CFR 300.415 [b] [2], parts:

i. Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances, pollutants or contaminants.

ii. Actual or potential contamination of drinking water supplies or sensitive ecosystems.


4


iii. Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers, that may pose a threat of release.

iv. High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that may migrate.

v. Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released.

vi. Threat of fire or explosion.

vii. The availability of other appropriate federal or state response mechanisms to respond to the release.

viii. Other situations or factors that may pose threats to public health or welfare or the environment.

Report Generation Originator: Erin Mulholland Date: 7 May 2014 Affiliation: Weston Solutions (START) Telephone: (978) 552-2107 TDD No.: 01-14-01-0007 Task No.: 0930 44444444444444444444444444444444444444444444444444444444444444444


5

II. Narrative Chronology

Narrative Chronology

Site Description

The Irving Tanning Company site (the site) is located at 24 Pleasant Street, Hartland, Somerset County, Maine (ME). The geographical coordinates at the approximate center of the site are 44° 52′ 57″ north latitude and 69° 27′ 09″ west longitude (see Appendix A, Figure 1, Site Location Map) [1]. The approximately 16-acre site contains a building complex that served as an annex for the Irving Tanning Company main building (ITC main building) located on Main Street. The site is bordered to the north by Pleasant Street, residential properties, and the Sebasticook River; to the west by wooded areas and a landfill; to the south by Lower Main Street and commercial/residential properties; and to the east by the Sebasticook River, Pleasant Street, and commercial/residential properties (see Appendix A, Figure 2, Site Diagram) [2].

The on-site building complex (i.e., the annex) consists of a series of interconnected buildings and additions and one separate, smaller building on the north-northwestern portion of the property. Tanning operations are not currently performed on site, but some portions of the building complex are actively used as storage space by Tasman Tanning. Exterior portions of the site include a paved parking area on the north and northwest sides of the buildings, and an access road that encircles the property and connects the site to Lower Main Street. There is a grassy area on the southeast side of the building complex that contains three aboveground storage tanks (ASTs). The status of these tanks is unknown. Local topography is generally flat, with one steep grade that slopes upward to the west toward the landfill. The wooded areas are vegetated with trees and tall grasses. The nearest surface water body is the Sebasticook River, which is located approximately 900 feet to the north-northeast of the site [3].

Site History and Previous Investigations

From approximately 1936 until 2005, Irving Tanning Company operated as a side-leather tannery at the ITC main building and at the site. In 2005, Irving Tanning Company was acquired by former management and Meriturn Partners, LLC. At that time, Irving Tanning Company had a capacity to finish over 30 million feet of leather per year.

In 2007, the Irving Tanning Company merged with Prime Tanning Company and continued operations on the site. In 2010, Prime Tanning Company filed for bankruptcy, and was acquired in 2011 by Tasman Tannery. Under the new ownership, operations continue currently at the ITC main building, but have been discontinued at the site [3].

In the late 1980s, the Maine Department of Environmental Protection (MEDEP) requested that Irving Tanning Company conduct analyses on composted hair waste that had been disposed of on site. In 1994, Irving Tanning Company conducted a cleanup of hair waste.

MEDEP began an investigation into the site, where tanning chemicals were stored. It was determined that at some point between 1980 and 1994, chemicals were piped into a ditch.

In August 1995, Acheron Inc. collected 23 soil samples from the site. The samples were analyzed for volatile organic compounds (VOCs). Analytical results indicated the following

1 R:\14010007\Reports\PASI\0930_PASI_IrvingTanning_Final.docx

VOCs [maximum concentrations, in parts per million (ppm), in parentheses]: ethylbenzene (732.8 ppm); toluene (122.2 ppm); 1,2,4-trimethylbenzene (121.5 ppm); xylenes (2,710.9 ppm); and diisobutyl ketone (3,380 ppm).

In November 2004, Woodard and Curran installed 20 monitoring wells on the site and collected 20 groundwater samples. The samples were analyzed for VOCs. Analytical results indicated the following VOCs [maximum concentrations, in parts per billion (ppb), in parentheses]: ethylbenzene (4,110 ppb); methyl isobutyl ketone (4,090 ppb); toluene (19,300 ppb); 1,2,4-trimethylbenzene (11 ppb); xylenes (6,714 ppb); and diisobutyl ketone (7,010 ppb).

It was determined that there was a plume of contaminated water on the eastern side of the property, which would need to travel through a wetland before reaching the West Branch of the Sebasticook River. However, the monitoring wells in the wetland indicated the plume was not moving in that direction.

In 1999, the U.S. Environmental Protection Agency (EPA) completed a Resource Conservation and Recovery Act (RCRA) Corrective Action Environmental Indicator (EI) determination and verified “Current Human Exposures Under Control” status for the site [4].

In January 2014, MEDEP inspected the annex and identified approximately 24 drums of chemicals used in the tanning process. MEDEP also determined that additional containers and equipment may exist on the property. Subsequently, MEDEP requested EPA assistance for the inventory and removal of drums and other potential hazardous materials at the site [5].

Site Activities

On 24 April 2014, Weston Solutions, Inc. (WESTON), Superfund Technical Assessment and Response Team (START) members Eric Ackerman, John Burton, Erin Mulholland, and Ken Robinson mobilized to the site. START members Mulholland and Robinson conducted a drive-by perimeter reconnaissance of the annex buildings from the access road. START members Ackerman and Burton conducted a perimeter reconnaissance on foot. START personnel documented that the annex was a series of interconnected buildings, and that these structures were not secure. Several doors were open and/or broken. START members Mulholland and Robinson noted an open storage bay door leading to a large storage room, where approximately 50 pallets of hides were being stored in the western portion of the building. START noted three ASTs in a grassy area southeast of the building complex. Southeast of the access road, in a vegetated area, four 1-inch polyvinyl chloride (PVC) stick-up monitoring wells were documented. On the western portion of the property, which sloped upward to a landfill, an access road was observed.

On 25 April 2014, START members Ackerman, Burton, Mulholland, and Robinson met with EPA On-Scene Coordinator (OSC) John McKeown and MEDEP representative Becky Blais at the site to conduct a building reconnaissance, to observe site conditions, to conduct container inventory activities, to conduct sampling of containers, and to conduct hazard categorization (HAZCAT).


START personnel established a support zone and calibrated the air monitoring instruments, two MultiRAE Plus units [with carbon monoxide (CO), hydrogen sulfide (H2S), volatile organic compounds (VOC), oxygen (O2), and Lower Explosive Limit (LEL) sensors], and one Ludlum Model 19A gamma radiation detector (RAD) meter [6,7]. Background levels were recorded as follows: VOC = 0.0 parts per million (ppm); LEL = 0%; O2 = 20.9%; CO = 0 ppm; H2S = 0 ppm; radiation = 10-15 microRoentgens per hour (µR/hr). START member Mulholland conducted a safety and operations meeting, and on-site personnel reviewed and signed the site Health and Safety Plan (HASP). The HASP was prepared as a separate document, entitled Weston Solutions, Inc., Region I START Site Health and Safety Plan (HASP) for the Irving Tanning Company Site, Hartland, Maine, dated April 2014.

Personnel began the building reconnaissance at the western portion of the building complex, in the area of the annex that is currently rented and used by Tasman Tanning as storage space. Personnel continued southeast through the building complex and documented abandoned machinery and equipment. A portion of the roof in this rented storage area had collapsed at some point after the initial site walk in January 2014. Personnel entered what appeared to be a laboratory area. No drums, jars, or containers were observed in the laboratory area. Personnel entered the drum storage area and began a preliminary drum inventory. A total of 46 drums were identified. All of the drums were closed and stored on pallets, and most had the original shipping labels intact.

Personnel continued southeast through the building complex to another storage area for Tasman Tanning. No additional drums were found. Personnel proceeded outside to access the northern part of the building complex and to conduct a brief reconnaissance of the perimeter. START member Mulholland provided photodocumentation support for site walk activities (see Appendix C, Photodocumentation Log).

START member Ackerman, OSC McKeown, and MEDEP representative Blais continued the site walk in the northern portion of the building complex. START members Burton, Mulholland, and Robinson prepared for inventory, sampling, and HAZCAT activities.

START personnel prepared a staging area for HAZCAT activities. START members Burton and Robinson proceeded to the drum storage area to inventory drums. Six drums were selected for sampling based on labels indicating corrosive or flammable materials, or that were representative of a chemical found in a large quantity. Personnel then entered the drum storage area in Level B personnel protective equipment (PPE) to collect samples [8]. The drum inventory and descriptions of samples collected on site are summarized in Appendix B, Table 1.

START member Mulholland performed ignitability and pH HAZCAT on the samples. All six samples were submitted to the EPA Office of Environmental Measurement and Evaluation (OEME) laboratory, located in North Chelmsford, Massachusetts, for pH and flashpoint analyses. The chain of custody record is included in Appendix D.

Sampling activities were performed in accordance with the site sampling and analysis plan (SAP), which was prepared as a separate document, entitled Sampling and Analysis Plan for the Irving Tanning Company Site, Hartland, Somerset County, Maine [9].


From 7 May through 15 May 2014, START received the analytical data results from OEME [10-11]. These data are summarized in Appendix B (see Appendix B, Tables 2 and 3). Complete laboratory data results may be found in Appendix D.

Analytical Data Summaries

Drum/Tank Samples

Two of the drum samples, DP-01 and DP-03, had a flashpoint of 36.5 and 38 degrees Celsius, respectively [10].

The pH of the drum samples ranged from 8.7 in DP-04 to

REFERENCES

[1] U.S. Geological Survey (USGS). 1981. Hartland, Maine. (7.5-minute series topographic map).

[2] ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP. 2011. ArcGIS.com World Imagery Map. 22 April.

[3] PR NewsWire., Prime Tanning and Irving Tanning Merger Forms Largest Leather Tannery in the U.S. 13 August. http://www.prnewswire.co.uk/news-releases/prime-tanning-and-irving-tanning-merger-forms-largest-leather-tannery-in-the-us-153418135.html. Accessed 8 May 2014.

[4] U.S. Environmental Protection Agency. 1999. RCRA Corrective Action Current Human Exposures Under Control Report. Irving Tanning Company. 5 February.

[5] Breneski, B. (MEDEP). 2014. Letter to John McKeown (EPA) RE: Irving Tanning Annex Site, Hartland. Request for USEPA Removal Program Assistance. 7 January.

[6] Weston Solutions, Inc. May 2011. Standard Operating Procedure for PID-MultiRAE (Multi-gas monitor with VOC detection and LEL) RAE Model PGM-50 Multi-gas Monitor (MultiRAE), SOP NO. WSI/S3-018, Superfund Technical Assessment and Response Team III (START), Andover, MA.

[7] Weston Solutions, Inc. May 2011. Standard Operating Procedure for Ludlum Model 19 Micro R Meter, SOP No. WSI/S3-022, Superfund Technical Assessment and Response Team III (START), Andover, MA.

[8] Weston Solutions, Inc. May 2011. Standard Operating Procedure for Drum Sampling, SOP No. WSI/S3-008, Superfund Technical Assessment and Response Team III (START), Andover, MA.

[9] Weston Solutions, Inc., 2014. Region I START Sampling and Analysis Plan for the Irving Tanning Company Site, Hartland, Somerset County, Maine. April

[10] U.S. Environmental Protection Agency. 6 May 2014. Office of Environmental Measurement and Evaluation. Laboratory Report. Project No. 14040019. Irving Tanning Co., Hartland, ME– Flash Point Determination.

[11] U.S. Environmental Protection Agency. 8 May 2014. Office of Environmental Measurement and Evaluation. Laboratory Report. Project No. 14040019. Irving Tanning Co., Hartland, ME – pH in Product.


http://www.prnewswire.co.uk/news-releases/primehttp:ArcGIS.com

III. Appendices

Appendix A

Figure 1- Site Location Map Figure 2- Site Diagram

Site

I

0 10.5 Miles

0 10.5 Kilometers

ME_g s rv ng Tannery gure 1.mxd

Figure 1

14-01-0007 E. Mulholland

31 January 2014 Irving Tanning Company

24 Pleasant StreetHartland, Maine

Site Location Map

Superfund Technical Assessment and

TDD Number: Created by:

EPA Region I

Response Team (START) IIIContract No. EP-W-05-042

Created on:Modified by: E. Mulholland Modified on: 22 April 2014

E:\ i \I i \MXD\Fi

Topos: MicroPath/USGS Quadrangle Name(s): Hartland, Maine All other data: START

Data Sources:

Leased Storage Areas

Pleasant Street

LowerMain S

treet

Sebasticook River

Landfill

Annex Building Complex

Leased Storage Areas

E:\ME_gis\Irving Tannery\MXD\Figure 2.mxd

Figure 2

I Imagery: Esri, DigitalGlobe, GeoEye, i-cubed,USDA, USGS, AEX, Getmapping, Aerogrid,IGN, IGP, swisstopoTopos: MicroPathAll other data: START

14-01-0007E. Mulholland31 January 2014

Irving Tanning Company24 Pleasant StreetHartland, Maine

Site Diagram

Data Sources:

EPA Region ISuperfund Technical Assessment and

Response Team (START) IIIContract No. EP-W-05-042

TDD Number:Created by:Created on:Modified by:Modified on:

LegendSite Boundary

S. Bitzas28 May 2014

0 130 260 390 52065 Feet

Appendix B

Table 1 Drum/Container Inventory Table 2 Summary of Flash Point Results, Drum Product Samples Table 3 Summary of pH Results, Drum Product Samples

TABLE 1

DRUM/CONTAINER INVENTORY IRVING TANNING COMPANY

HARTLAND, MAINE

Description Containers Approximate Quantity Sample No./ Scribe No.

Field Screening Sample Description HAZCAT Number Type Volume PID (ppm) Phase Color Viscosity pH Flammability

PrimeTan (Flammable Liquid 3) 1 DM 55-gallon Full DP-01/ R114010007JM-0001 97.60 Liquid Amber Oily 7 Flammable

CR 13505p (Glycolic Acid) 1 DF 30-gallon Full DP-02/ R114010007JM-0002 - Liquid Clear Thin 2 Non-flammable

Rodavisc DE (Flammable Liquid) 1 DF 2-gallon 3/4 full DP-03/ R114010007JM-0003 Max Top - Liquid Bottom - Solid Top - Clear Bottom - White Top - Thin Bottom - Thick 7 Non-flammable

Chemtan DR43 M 6 DF 55-gallon Full DP-04/ R114010007JM-0004 1.10 Solid - Thick 7 Non-flammable

Lubritan (Gx) 3 DF 55-gallon Empty - 1/4 full DP-05/ R114010007JM-0005 2.10 Liquid Brown Oily/Thick 5 Non-flammable

Sulphat H700 2 DF 55-gallon - DP-06/ R114010007JM-0006 Max Liquid White Oily 5 Combustible

Chemtan 74R-74CC 2 D 55-gallon - NS NS - - - NS NS

Salem R 2 D 55-gallon - NS NS - - - NS NS

Neschem CA-1 1 DF 55-gallon - NS NS - - - NS NS

Nescehem CA-1 1 DF 35-gallon - NS NS - - - NS NS

Apex Clay 2 DF 35-gallon - NS NS - - - NS NS

Relca MillGround A 2 D 55-gallon - NS NS - - - NS NS

XC9635WF 1 D 55-gallon - NS NS - - - NS NS

Durmanall Swn-paste 1 D 55-gallon - NS NS - - - NS NS

Addiderm Fast Brown 1 D 55-gallon - NS NS - - - NS NS

XL 9642-WFD 1 D 55-gallon - NS NS - - - NS NS

RC 21-067 2 D 55-gallon - NS NS - - - NS NS

Lacquer CLB 50 2 D 55-gallon - NS NS - - - NS NS

Table 1_Drum Inventory Log.xlsx Page 1 of 2

TABLE 1

DRUM/CONTAINER INVENTORY IRVING TANNING COMPANY

HARTLAND, MAINE

Description Containers Approximate Quantity Sample No./ Scribe No.

Field Screening Sample Description HAZCAT Number Type Volume PID (ppm) Phase Color Viscosity pH Flammability

Chemtan R106-W 1 D 55-gallon - NS NS - - - NS NS

FurDpol G 1 D 55-gallon - NS NS - - - NS NS

BayDerm Fix 1 DF 5-gallon - NS NS - - - NS NS

Rodacare 57 3 DF 30-gallon - NS NS - - - NS NS

CR 13565 p 1 DF 30-gallon - NS NS - - - NS NS

Illegible/No label 2 DF 5-gallon - NS NS - - - NS NS

Illegible/No label 2 DF 30-gallon - NS NS - - - NS NS

Illegible/No label 3 D 55-gallon - NS NS - - - NS NS

NOTES:

DM = Metal drums, barrels, kegs DF = Fiberboard or plastic drums, barrels, or kegs D = Drum, material category not available CF = Fiber or plastic boxes, cartons, or cases DP = Drum Product sample TP = Portable tanks PID = Photoionization Detector > = greater than ppm = parts per million NS = Not sampled or screened NA = Not applicable

Table 1_Drum Inventory Log.xlsx Page 2 of 2

TABLE 2

SUMMARY OF FLASH POINT RESULTS

DRUM PRODUCT SAMPLES

IRVING TANNING COMPANY SITE HARTLAND, MAINE

SAMPLE LOCATION SAMPLE NUMBER

LAB NUMBER SAMPLE MATRIX

DP-01 R114010007JM-0001

AB47685 PRODUCT

DP-02 R114010007JM-0002

AB47686 PRODUCT

DP-03 R114010007JM-0003

AB47687 PRODUCT

Flash Point (Degrees C) 36.5 No Flash 38

SAMPLE LOCATION SAMPLE NUMBER

LAB NUMBER SAMPLE MATRIX

DP-04 R114010007JM-0004

AB47688 PRODUCT

DP-05 * R114010007JM-0005

AB47689 PRODUCT

DP-06 R114010007JM-0006

AB47690 PRODUCT

Flash Point (Degrees C) No Flash NA No Flash

NOTES:

1) Samples analyzed by U.S. EPA Office of Environmental Measurement and Evaluation (OEME) using EPA Region I SOP INGPH4.SOP, pH in Product. 2) NA = Not Analyzed. 3) * The sample (solid) was too viscous and not amenable to this method of flash point determination.

R:\14010007\Analytical\Summary Tables\Table 2 - Drum Samples FlashPoint Summary.xls

TABLE 3

SUMMARY OF pH RESULTS DRUM PRODUCT SAMPLES

IRVING TANNING COMPANY SITE HARTLAND, MAINE

SAMPLE LOCATION DP-01 DP-02 DP-03 SAMPLE NUMBER R114010007JM-0001 R114010007JM-0002 R114010007JM-0003

LAB NUMBER AB47685 AB47686 AB47687 SAMPLE MATRIX PRODUCT PRODUCT PRODUCT pH 3.6

Appendix C

Photodocumentation Log

PHOTODOCUMENTATION LOG Irving Tanning Company ● Hartland, Maine

SCENE: View of the main parking area taken in front of the Irving Tanning Company annex buildings. Photograph taken facing southeast. DATE: 24 April 2014 TIME: 0804 hours PHOTOGRAPHER: Erin Mulholland CAMERA: iPhone 4S

SCENE: View of an Irving Tanning Company sign on an Irving Tanning Company annex building.

DATE: 24 April 2014 TIME: 0804 hours PHOTOGRAPHER: Ken Robinson CAMERA: iPhone 4S

TDD No. 14-01-0007 Page 1 of 11 TASK No. 0930


TO

P

SCENE: View of leather products in the storage area in the Irving Tanning Company annex building complex.

DATE: 24 April 2014 TIME: 0844 hours PHOTOGRAPHER: Erin Mulholland CAMERA: iPhone 4S

TO

P

SCENE: View of the collapsed roof inside of the storage area of the Irving Tanning Company annex building complex.




TO

P

SCENE: View of a laboratory area within the Irving Tanning Company annex building complex.


TO

P

SCENE: View of drums in the Irving Tanning Company annex building complex.




TO

P

SCENE: View of polyethylene (poly) drums in the Irving Tanning Company annex building complex.


TO

P

SCENE: View of drums not stored on pallets, in the Irving Tanning Company annex building complex.




TO

P

SCENE: View of a “flammable” label on a drum in the Irving Tanning Company annex building complex.


TO

P

SCENE: View of “CHEMTAN” label on a drum in the Irving Tanning Company annex building complex.




TO

P

SCENE: View of “CHEMTAN ACID” label on a drum in the Irving Tanning Company annex building complex.


TO

P

SCENE: View of a drum label, “Leukotan”, in the Irving Tanning Company annex building complex.




TO

P

SCENE: View of “glycol ether” label on a drum in the Irving Tanning Company annex building complex.


TO

P

SCENE: View of bags of Plenatol material in the Irving Tanning Company annex building complex.




SCENE: View of labels denoting “Bases” and “Tops” in the drum storage room in the Irving Tanning Company annex building. DATE: 24 April 2014 TIME: 0859 hours PHOTOGRAPHER: Erin Mulholland CAMERA: iPhone 4S

TO

P

SCENE: View of an empty drum labeled “rain water”.




TO

P

SCENE: View of the second area rented for storage in the Irving Tanning Company annex building complex.


SCENE: View of drum DP-01 in the Irving Tanning Company annex building complex.




SCENE: View of drums DP-02 and DP-03 in the Irving Tanning Company annex building complex.





Appendix D

Analytical Data Chain-of-Custody Record

United States Environmental Protection Agency Page 1 of 5Office of Environmental Measurement & Evaluation 60 Westview Street

Lexington, MA 02421-3185

Laboratory Results

May 06, 2014

John McKeown - Mail Code OSRR02-2 US EPA New England R1

Project Number: 14040019 Project: Irving Tanning Co.- Hatland, ME Analysis: Flash Point Determination Analyst: Paul Carroll

Analytical Procedure:

All samples were received and logged in by the laboratory according to the USEPA New England "Sample Login, Tracking and Sample Disposition Standard Operating Procedure", most current version.

Sample preparation and analysis was done following the EPA Region I SOP, FLASH6.SOP.

Flash Point determinations were made using a Stanhope-Seta Setaflash Tester. The SOP is based on ASTM Method D3278-78 " Standard Test Methods for Flash Point of Liquids by Setaflash Closed-Cup Apparatus"

Date Samples Received by the Laboratory: 04/28/2014

Data were reviewed in accordance with the internal verification procedures described in the EPA New England OEME Chemistry QA Plan.

Results relate only to the items tested or to the samples as received by the Laboratory. This analytical report shall not be reproduced except in full, without written approval of the laboratory.

If you have any questions please call me at 617-918-8340 .

Sincerely,

Digitally signed by Dan Boudreau DN: cn=Dan Boudreau, o=EPA, ou=EIA, 14040019FLASH [email protected], c=US Date: 2014.05.06 14:51:48 -04'00'

http:2014.05.06mailto:[email protected]

Flash Point Determination

Irving Tanning Co.- Hatland, ME

US ENVIRONMENTAL PROTECTION AGENCY NEW ENGLAND LABORATORY

Page 2 of 5

Matrix: Product

Field ID

R114010007JM-0001

Lab ID

AB47685

Collected

04/25/2014

Date of Analysis

05/01/2014

Flash/ No Flash Result Degrees C

Flash

Finite Flash Point Result Degrees C

36.5

Qualifier

Comments:

R114010007JM-0002 AB47686 04/25/2014 05/01/2014 No Flash

Comments:

R114010007JM-0003 AB47687 04/25/2014 05/01/2014 Flash 38

Comments:

R114010007JM-0004 AB47688 04/25/2014 05/01/2014 No Flash

Comments:

R114010007JM-0005 AB47689 04/25/2014 05/01/2014 NA

Comments: NA - This method is used to determine the flash point of a material with viscosity less than 150 stokes (liquid). This sample (solid) is not amenable to the method.

R114010007JM-0006 AB47690 04/25/2014 05/01/2014 No Flash

Comments:

Page 1 of 2

of 5

Laboratory Duplicate Results



Laboratory Sample

ID

AB47687

Parameter

Flash Point Determination

Flash/NoFlash

Sample Result

Flash

Sample Result Finite

38

Flash/NoFlash

Duplicate Result

Flash

Duplicate Result Finite

38

Precision RPD

%

0.0

QC LIMITS (%RPD)

20

Comments: Sample / Sample Duplicate results are reported as degrees celcius.

Page 2 of 2

of 2

Lab# Sample# Location

R114010007JM- DP-01 0001

R114010007JM- DP-01 0001

R114010007JM- DP-02 : 0002

R114010007JM- DP-02 0002

R114010007JM- DP-03 0003

R11401 0007 JM- DP-03 ; 0003

R114010007JM- DP-04 0004

i R114010007JM- DP-04 0004 R114010007JM- DP-05 0005

R114010007JM- DP-05 0005

R114010007JM- DP-06 0006

Analyses

Flash point

pH

Flashpoint

pH

Flashpoint

pH

Flash point

pH

Flashpoint

pH

Flashpoint

CHAIN OF CUSTODY RECORD

Irving Tanning Company

Contact Name:

Contact Phone:

Matrix

Product

Product

Product

Product

Product

· Product

Product

Product

Product

Product

Product

Collected

4/25/2014

4/25/2014

4{25/2014

4/25/2014

4/25{2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

Numb Container Cont

1 Jar

1 Jar

1 Jar

1 Jar

1 Jar I

1 Jar

1 Jar

1 Jar

1 Jar

1 Jar I

1 Jar

No: 04/28/14-0001 Cooler#:

Lab: NERL

Lab Phone:

Preservative MS/MSO

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C . N I

4C N

SAMPLES TRANSFERRED FROM

Special Instructions: Please f01ward results to EPA OSC John McKeown: [email protected] or (617) 918-1793 CHAIN OF CUSTODY #

Items/Reason Relinquisi}Jld by Date I Received by I Date Time ltemsfReason Relinquished By Date Received by Date Time

/i;;:;j~ ·I tJ/,!$/1~. /4~s y/~1¥ .i5 · S"~ I ~/ /

I i I

Page 4

of 5

140400

19FLAS

H140

40019P

H-P

of 2

Lab# I Sample# Location

R11401 0007JM- DP-06

' 0006 I

i

!

Analyses

pH


INing Tanning Company

Contact Name:

Contact Phone:

Matrix

Product

i '

I

Collected

4/25/2014 !

~

Special Instructions: Please forward results to EPA OSC John McKeown: [email protected] or {617) 918-1793

~

I

i

Numb Container Cont

1 Jar

;

'

No: 04/28/14-0001 Cooler#:

lab: NERL

Lab Phone:

Preservative MS/MSD

4C N


CHAIN OF CUSTODY#

I Items/Reason Relinquished by~ Date Received by Date Time Items/Reason Relinquished By Date Received by I Date Time

Li!L i~ Q o//,t.t/1'7 ~ ./ floi'Jtli 1.!,--:-S) ! ' '/ '

I !

I I

I

I ! I

! .

I ' i

Page 5

of 5

140400

19FLAS

H140

40019P

H-P

United States Environmental Protection Agency Page 1 of 6Office of Environmental Measurement & Evaluation 11 Technology Drive

North Chelmsford, MA 01863-2431

Laboratory Results

May 8, 2014

John McKeown - Mail Code OSRR02-2 US EPA New England R1

Project Number: 14040019 Project: Irving Tanning Co.- Hatland, ME Analysis: pH in Product Analyst: Bhavita Patel

Date Samples Received by the Laboratory: 04/28/2014

Analytical Procedure:

All samples were received and logged in by the laboratory according to the USEPA New England Laboratory SOP for Sample Log-in.

Sample preparation and analysis was done following the EPA Region I SOP, INGPH5.SOP.

The pH analysis SOP is based on Method 9045C pH Electrometric Measurement as stated in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, 3rd Edition, Update IIB, Volume IC, Chapter 6, Revision 2, January 1995".

Results relate only to the items tested or to the samples as received by the Laboratory. This analytical report shall not be reproduced except in full, without written approval of the laboratory.

Data were reviewed in accordance with the internal verification procedures described in the EPA New England Quality Manual for NERL.

If you have any questions please call me at 617-918-8340.

Sincerely,

Digitally signed by Dan Boudreau

DN: cn=Dan Boudreau, o=EPA, ou=EIA,

[email protected], c=US Date: 2014.05.08 10:47:00 -04'00'

http:2014.05.08mailto:[email protected]

of 6Qualifiers: RL = Reporting limit ND = Not Detected above Reporting limit NA = Not Applicable due to high sample dilutions or sample interferences NC = Not calculated since analyte concentration is ND. J = Estimated value J1 = Estimated value due to MS recovery outside accceptance criteria J2 = Estimated value due to LFB result outside acceptance criteria J3 = Estimated value due to RPD result outside acceptance criteria J4 = Estimated value due to LCS result outside acceptance criteria E = Estimated value exceeds the calibration range L = Estimated value is below the calibration range B = Analyte is associated with the lab blank or trip blank contamination. Values are qualified when the observed concentration of the contamination in the sample extract is less than 10 times the concentration in the blank.

14040019PH-P


Page 3 of 6


pH in Product

Lab IDSample Number

Matrix: Product

R114010007JM-0001 AB47685

Pale yellow in color Comments:

Collected

04/25/2014 0

Analysis

05/06/2014 10:22

pH Concentration

3.6

Qualifier

R114010007JM-0002 AB47686 04/25/2014 0 05/06/2014 10:28

US ENVIRONMENTAL PROTECTION AGENCY Page 4 of 6 NEW ENGLAND LABORATORY


Laboratory Duplicate Results

SAMPLE SAMPLE DUP PRECISION QC RESULT RESULT RPD LIMITS

SAMPLE ID PARAMETER pH pH % (%RPD) AB47685 pH in Product 3.6 3.5 2.8 25 AB47688 pH in Product 8.7 8.8 1.1 25 AB47689 pH in Product 4.8 4.8 0.0 25

14040019PH-P

of 2

Lab# Sample# Location

R114010007JM- DP-01 0001

R114010007JM- DP-01 0001

R114010007JM- DP-02 : 0002

R114010007JM- DP-02 0002

R114010007JM- DP-03 0003

R11401 0007 JM- DP-03 ; 0003

R114010007JM- DP-04 0004

i R114010007JM- DP-04 0004 R114010007JM- DP-05 0005

R114010007JM- DP-05 0005

R114010007JM- DP-06 0006

Analyses

Flash point

pH

Flashpoint

pH

Flashpoint

pH

Flash point

pH

Flashpoint

pH

Flashpoint


Irving Tanning Company

Contact Name:

Contact Phone:

Matrix

Product

Product

Product

Product

Product

· Product

Product

Product

Product

Product

Product

Collected

4/25/2014

4/25/2014

4{25/2014

4/25/2014

4/25{2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

4/25/2014

Numb Container Cont

1 Jar

1 Jar

1 Jar

1 Jar

1 Jar I

1 Jar

1 Jar

1 Jar

1 Jar

1 Jar I

1 Jar

No: 04/28/14-0001 Cooler#:

Lab: NERL

Lab Phone:

Preservative MS/MSO

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C N

4C . N I

4C N


Special Instructions: Please f01ward results to EPA OSC John McKeown: [email protected] or (617) 918-1793 CHAIN OF CUSTODY #

Items/Reason Relinquisi}Jld by Date I Received by I Date Time ltemsfReason Relinquished By Date Received by Date Time

/i;;:;j~ ·I tJ/,!$/1~. /4~s y/~1¥ .i5 · S"~ I ~/ /

I i I

Page 5

of 6

140400

19FLAS

H140

40019P

H-P

of 2

Lab# I Sample# Location

R11401 0007JM- DP-06

' 0006 I

i

!

Analyses

pH


INing Tanning Company

Contact Name:

Contact Phone:

Matrix

Product

i '

I

Collected

4/25/2014 !

~

Special Instructions: Please forward results to EPA OSC John McKeown: [email protected] or {617) 918-1793

~

I

i

Numb Container Cont

1 Jar

;

'

No: 04/28/14-0001 Cooler#:

lab: NERL

Lab Phone:

Preservative MS/MSD

4C N


CHAIN OF CUSTODY#

I Items/Reason Relinquished by~ Date Received by Date Time Items/Reason Relinquished By Date Received by I Date Time

Li!L i~ Q o//,t.t/1'7 ~ ./ floi'Jtli 1.!,--:-S) ! ' '/ '

I !

I I

I

I ! I

! .

I ' i

Page 6

of 6

140400

19FLAS

H140

40019P

H-P

On 25 April 2014, START members Ackerman, Burton, Mulholland, and Robinson met with EPA On-Scene Coordinator (OSC) John McKeown and MEDEP representative Becky Blais at the site to conduct a building reconnaissance, to observe site conditions, to condu...START personnel established a support zone and calibrated the air monitoring instruments, two MultiRAE Plus units [with carbon monoxide (CO), hydrogen sulfide (H2S), volatile organic compounds (VOC), oxygen (O2), and Lower Explosive Limit (LEL) sensor...Personnel began the building reconnaissance at the western portion of the building complex, in the area of the annex that is currently rented and used by Tasman Tanning as storage space. Personnel continued southeast through the building complex and d...

barcode: *565578*barcodetext: SDMS Doc ID 565578

removal program preliminary assessment/site …date of inspection: 25 april 2014 ; time of...

Documents