HomeMy WebLinkAboutDEP - 7/5/1990_
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Gilbert T. Joly
Regional Director ,?
July 5, 1990
Hatheway & Patterson Co., Inc. RE: MANSFIELD--WSC/SA-4-0571
P.O. Box 177 Hatheway & Patterson
Mansfield, Massachusetts 02048 15 County Road,
Request for Short Term Measures
M.G.L. c. 21E, 310 CMR 40.000
ATTENTION: William E. Haynes
President
Gentlemen:
On May 15, 1990, at approximately 10:30 am, the Department of
Environmental Protection, Bureau of Waste Site Cleanup (the "Department"),
received a call from a resident of Mansfield reporting a release of oil
into the Rumford River from the grounds of the Hatheway & Patterson
facility at 15 County Road, a property you own and operate.
On May 16, 1990, Michael G. Moran and Marcel V. Boelitz, agents of the
Department, accompanied by Scott Leite, Board of Health agent for the town
of Mansfield, visited the site and confirmed the release of a product of
unknown chemistry along the left bank of the Rumford River. At the time of
the visit, you had completed a structure made of stakes and plywood to
contain the release. Adsorbent pads were used to sweep the product.
Because product was observed seeping into the River beyond the reach of the
containment structure, you were requested by both Scott Leite and the
Department to extend this structure downstream and upstream. Subsequent
visits by Scott Leite confirmed that this was done.
On May 16, 1990, and at two meetings with you and your consultants on
May 18 and 29, 1990, the Department informed you that the structure erected
along the Rumford River to abate the release could be used only for a
limited time, and needed to be replaced as soon as possible by a permanent
arrangement to (i) secure contaminated soils and separate -phase product and
to (ii) collect all separate -phase product reaching the River bank. These
remedial response actions were to be undertaken as Short Term Measures
("STMs") in compliance with 310 CMR 40.542. You were asked to submit a
Short Term Measure Proposal ("STMP") pursuant to 310 CMR 40.542(3)(b) and a
Health and Safety Plan required by 310 CMR 40.542(3)(d).
The Department has reviewed a report submitted on your behalf by
Keystone Environmental Resources, Inc. ("Keystone") on June 19, 1990,
Original Printed on Recycled Paper
titled " Short Term Measure Proposal" (the "STMP"), along with a Health and
Safety Plan for the site. The Department concluded that the STMP could not
be approved as submitted because it is inadequate. Comments on the STMP
were discussed with Keystone verbally on June 19, 1990. Keystone replied
on June 21, 1990.
After careful consideration of your STMP and Keytone's letter of June
21, 1990, the Department has determined that the following actions are
required at the site: ,
(a) The Department's records show that the release of product to the
Rumford River is episodic and likely to be a function of
rainfall. Therefore a STM to secure and collect product is
necessary, regardless of whether product or a release of product
to the River is actually observed on any given day.
(b) The lateral and vertical dimensions of the lens or mat of
contaminated soil whence the product is derived needs to be
defined. It is likely to extend well below the current ground
water table, and therefore cannot be adequately assessed by
sampling above the water table, whether by excavation or by
boring. A proposal to sample to background levels or to a depth
of ten (10) feet below the water table would insure that sampling
is adequate. Headspace VOC screening and logging must be
continuous.
(c) The chemistry of the product discharged to the Rumford River
needs to be determined. A sample of product if it can be
obtained, and at least three (3) worst -case samples of
contaminated soils must be fingerprinted and analyzed for Copper,
Chromium, Arsenic and other known site contaminants. Aggregate
samples may not be used.
(d) Gauging must include the Rumford River.
(e) The design of the proposed passive recovery system is inadequate.
Your consultant must demonstrate that the zone of influence of
the recovery system encompasses the entire mat of contaminated
soil even under extreme conditions of precipitation, when the
release of product to the Rumford River is most likely to occur.
The recovery well needs to be a discharge point to the River or
the adjacent aquifer if it is to develop a cone of depression
capable of drawing in product.
(f) Contaminated soils may not be backfilled. They must be stockpiled
separately from clean soil and sealed by impermeable sheeting.
Arrangements must be made to dispose of this contaminated soil in
compliance with M.G.L. c. 21E or c. 21C, as required by the
results of item (c).
-3-
The Department approves Keystone's schedule to submit a Revised Short
Term Measure Proposal that addresses the items listed above by July 27,
1990.
Your cooperation in this matter is appreciated. If you have any
further questions, please contact Marcel V. Boelitz at the letterhead
address or at (508) 946-2868. All future communications regarding this
site must reference the site number 4-0571.
i
Very truly yours,
lr
rk J egley hi
Site Remediation Section
B/MVB/lm
CERTIFIED MAIL #P707 034 877
RETURN RECEIPT REQUESTED
cc: DEP - BOSTON - BWSC
DEP - SERO - BWSC
Data Entry
Board of Selectmen
Town Hall
50 West Street
Mansfield, MA 02048
Board of Health
Town Hall
50 West Street
Mansfield, MA 02048
ATTN: Scott Leite, Tel. (508) 261-7366
Conservation Commission
Town Hall
50 West Street
Mansfield, MA 02048
Keystone Environmental Resources, Inc.
3000 Tech Center Drive
Monroeville, PA 15146