i' State of Ver-morit

AGE:"CY OF E:"VJl\ON.IENTAL CO:"SERVATION

D"I"- :,'n,")t 01 F"" a"dWildlj!BC C,,"" :;,,~nt of For~SI" Parks and Recreation1;""-','" '"w,n "~ \'.' c, ," Resources & Environmental Engineering1':,','" .-, I",.'\"."ccs Conservanon Council

June 23, 1986

Hr. Brad ThomasRutland Group, Inc.Route 4Hendon, VT 05701

I\lontpeller, Vermont 0561.12.,Department of Water Resources :'-'

and - -~-Environmental Engineering

.~ .-,-,.-.e-

RE: site Assessment at the Ludlow Mintzer Brothers site

Dear Mr. Thomas:

The Agency has received and reviewed the May 16, 1986 r~port

prepared by Aquatech, Inc. detailing the evaluation of the "'Co>'.'.-

Mintzer Brothers site in Ludlow, VT. Based on this and otherreports and site investigations we performed, we have determinedthat there is no significant contamination of the groundwaters •. "SoilS analyses also indicate that no further remediation is war­ranted. You have fulfilled your obligation detailed in the 6610aOrder issued to Mintzer Brothers, Inc. in March of this year' andwe appreciate your efforts. We will however, retain this site on"our VT Hazardous Waste Sites List in our Class 6 Category vtri.cn; "axe sites where we believe appropriate remedial act.Lon has been -.-',completed. .'~~'\

~1lY~ ilic-/~lohn Malter, irecto;(~\~aste Management Division

JFA:JAM::cmc

cc: Mintzer Brothers, Inc.Roger Binkerd, Aquatech

", ..-

',-''",

Regional Offices, Barre/Essex Jct./Pitts1ord/N, Sprinqfietd/St. Johnsbury

-

June 13, 1986

State of VermontAgency of Environmental Conservation

Department of Water ResourcesState Office BuildingMontpelier. VT 05602

Attention: Mr. John F. Amadon

Reference: Mintzer Brother. Inc.Ludlow, Vermont

Dear John:

I have enclosed a copy of the Hazardous Waste Evaluation, as prepared

and submitted by Aquatec. Inc., for your information and review.

Should you have any questions and/or comments pertaining to this matter,

please do not hesitate to contact me.

Respectfully submitted.

RUTLAND GROUP. INC.CONSTRUCTION DIVISION

~~Bradford B. ThomasProject Manager

BBT/mmd

Enclosure

RUTLAND GROUP INC. RT.4 MENDON,VT. 05701

o·

May 19, 1986

My. John AmadonState of VermontHazardous Waste DivisionMontpelier, VT 05602

Reference: Mintzers/Ludlow

Dear John:

We have excavated the pile of debris at the above referencedsite and did not find any buried drums. We did find a bent uproof panel at the spot that Aquatec detected metal.

Please call if you have any questions.

Sincerely,

THE RUTLAND GROUP, INC.CONS~CTION DIVISION

Bra~~homasProj ect Manager

BBT/nem

RUTLAND GROUP INC. RT. 4 MENDON,VT. 05701 (802) 775 0 1981

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DRAFT COpy

For:

Rutland G<ooI>, Inc•Route 4

Mendon, YeDllXlt 05701

By:

AqUatec, Inc.75 Green Mountain Jkive

SOUth Burlington, ~""""t 05401

14 April 1986

DRI\f1 CO?~

On 11 March 1986 a meeting was held at the Rutland Group

office in Rutland, Vennont to review the findings of an initial

investigation at a Ludlow, Vennont deveIopment; site owned by The

Mintzer Brothers, Inc. Present at the meeting were several

representatives of the Rutland Group, rnc.j Kinney, Pike, Bell &

Conner, Inc.: Aquatec, Inc.: the State of Vermont Waste

Management Division: and The Mintzer Brothers.

After review of a report by Aquatec, Inc. entitled "Initial

site Visit at Ludlow Devekopment; Site," Mr. John Amadon of the

State of Vermont Agency of Environmental Conservation indicated

the Agency would be issuing a 10 V.S.A. section 6610a order

requiring the present owner, The Mintzer Brothers, to conduct

further site investigations and other work on the site.

Immediate response measures required by the stare' s order

were coordinated between the Rutland Group, represent.inq '!he

Mintzer Brothers, and xquatec, Samples were collected on 19

March 1986 from the buried tank at top, mid, and bottom depths

and held for future analysis. On 19 March 1986, a soil boring

was collected from the subsurface pit for volatile organic and pH

analysis. One air sample was collected inside the building in

the northeast corner on 12 March 1986 and analyzed for methylene

chloride.

New England Marine Contractors (NF...MC) was retained by the

Rutland Group to pump, dispose, and clean contents in the buried

tank. Aquatec provided NEM.C with analyses of the material in the

buried tank to determine the amount of eodi.um hydroxide required

to neutralize the acid prior to pumping. The tank was pumped and

cleaned on Friday, 28 March 1986. Final rinse water samples were

collected by NEMC and delivered to Aquatec for analysis on 1

April 1986.

3. NEARFIEID/FARFIEID STI'E MlSESSIIDlr

The 6610a order was received by Aquatec and the Rutland Group

on Friday, 28 March 1986. A copy of the order is in Appendix A.

Site assessment activities began on Monday, 31 March 1986. The

implementation of the order followed the flow diagram developed

by Aquatec in Figure A-I, Appendix A. This diagram includes the

Lmmediate response activities described in section 2.

3.1 Nearfield Site Activities

The nearfield activities included a search for water mains,

sewer lines, and other buried tanks and/or lines around the

parameter of the building. The municipal water main was located

using a Geonies EM31 magnetrcrneter. The water main location was

later verified in a sketch provided by Mr. Loren Greenslet of the

Ludlow Wastewater Treatment Plant. '!he location of the water

main is sheen on Figure 1.

The location of the sewer line between the building and the

sewer main remains uncertain at this time. Interviews with Mr.

Oliver Tucker, a former general contractor who originally built

the building for T.A. Electronics, and Mr. Herbert Van Guilder of

Tapper Plumbing who did the interior plumbing, indicate the line

exists on either the south or west sides of the building, but

neither gentleman was certain of its exact location. There are

no records at the treatment plant indicating where the line ties

into the main sewer. Construction plans received on 9 April 19B6

fran the District Environmental Crnmission in Springfield,

Vermont show a sewer line leading from the south end of the

building and tying directly into the sewer line. A copy of these

plans are enclosed in Appendix B.

The previous site visit identified that an inside pit and an

outside tank were involved in the chemical process for T.A.

Electronics. Interviews with Mr. Van Guilder and Mr. David

DRAFT COpy3.2 Farfield Site Activities

The farfield site activities included an electromagnetic

search for buried drums using a Geonics EM31 magnetraneter. A

snow pile and a rubble pile consisting of soil, stumps and debris

were surveyed to attempt to locate two buried drums that were

excavated by a bulldozer operator. A grid was staked out

southeast of the building and surveyed for buried drums. This

grid area was not formerly owned by T.A. Electronics but coqers

an area where the drums had initially been excavated.

4. lFF-5ITE RBOCRIAISS1INlE

Personal and telephone interviews with several people associ­

ated with the original construction of the T.A. Electronics

building and fanner employees indicate there was only one outdoor

buried tank and one inside pit used for the chemical treatment

processes. Personal interviews with Mr. Tucker and Mr. Van

Guilder confinned the locations of the inside pit and outside

tank. They have also indicated that those were the only sub­

surface tanks that were associated with the chemical process. A

fuel oil tank may be buried off the south end of the building as

indicated in the proposed construction plans sutxnitted by Tucker

Construction to the District Environmental Office in springfield,

Vermont.

The proposed location of two 1, 200-gallon tanks and one 500­

gallon tank depicted on the plans submitted to the District

Environmental Office by Tucker Construction do not agree wi th the

location of plans submitted to the Agency of Environmental

Conservation, Pennit section. The plans sutmitted by Tucker

Construction shos three tanks adjacent to the north end of the

west wall. The schematic sulmi.tted to the AEC shows the location

of the three tanks adjacent to the north wall. Neither plan

agrees in size, number or location of the tanks actually found.

5. PIE7.<J4ETER AND~y WEIL lNSTALIATIOO

Prior to installation of a fully-screened exploratory well

near the outside tank, the local groundwater flow direction was

determined to ensure that the exploratory well would be dCMt1­

gradient of this tank. To estimate the local horizontal flow

direction, four piezaneters were installed to supplement tw:>

wells that were in the area. Adams Engineering began the

installation of four piezaneters on 'tuesday, 1 April 1986 (Figure

1) • These piezcmeters were surveyed and references to a bench

mark that was established during a study by rufresne-Henry, Inc.

on li..tdlow's alternative water supply. Two observation wells,

84-16 and 84-17, installed by Dufresne-Henry were monitored for

water levels.

Piezaneters were pumped by a vacuum pump irrmediately follow­

ing installation. '!he piezcmeters were allowed to recharge for

several hours after purging before water level measurements were

made. The Ludlow alternative water supply well is operated from

2300 hours to 0700 hours each day. Water levels were measured at

the observation wells at 2200 hours to minilnize the influence of

drawdown due to the supply well.

Based on these piezometer measurements, an exploratory well

was located downgradient of the buried tank (Figure 1). The well

was drilled on 3 April 1986. The first attempt at installing a

sandpack around the screened section of the well failed due to an

excessive amount of sand and silt inside the augers. The first

hole was abandoned and a second hole was drilled a few feet away.

The hole was washed to remove sand and silt that entered the

auger when the plug was removed prior to installing the screen.

The screen was installed, sandpacked, and air developed. The

well was then bailed by hand a total of three volumes and al.Lowed

to stabilize overnight. The -well was purged and sampled the

following day, 4 April 1986.

Field measurements for pH were measured for all soil samples.

A soil paste was prepared by taking 10 grams of soil and adding

25 milliliters of 1 M potassium chloride and allowing the mixture

to stand for one hour before measuring.

Continuous readings were recorded for pH, temperature, and

conductivity during the purging of the exploratory well, EX-L

The well was purged with a Teflon'" bladder pump. The measuring

probes were placed in a flow-through cell.

7. RHSULTS

7.1 IDm!diate Response

The air sample collected in the northeast corner of the

building on 19 March 1986 was analyzed by gas chranatography.

Methylene chloride was detected in this sample but at a concen­

tration not reliably quantifiable.

A sludge sample, RG3P, was collected fran the inside pit at a

depth of nine feet below the surface of the pit on 19 March 1986

and analyzed by gas chranatography/mass spectrceet.ry for halo­

genated volatile organics. Canpounds analyzed for, if present,

were below detection limits.

Three samples collected fran the buried tank on 19 March 1986

were used to determine that 18.3 gallons of 50% liquid sodium

hydroxide would be required to neutralize 2,800 gallons of acid

to a pH of 4. The temperature increase caused by neutralization

would be approximately 3°F. This infonnation was transmitted to

NEMC by phone on 27 March 1986. POrtions of these samples will

be stored in our laboratory until the integrity of the outside

tank is determined.

me tank was neutralized and pumped on 28 March 1986 by NEMC.

The final rinse water was analyzed by Aquatec for pH, zinc,

copper, and tin. Table 1 below shows a canparison of results of

the material that was in the tank prior to pumping versus the

final rinse water after cleaning.

Table 1

Tank #1Lab No. 56391

Final RinseLab No. 57041

pH(std. units)

1.4

6.8

Zinc(l1'9/1)

24

0.10

COpper(l1'9/1)

300

6.6

Tin(l1'9/1 )

500

0.21

7.2 Nearfield Resu1ts

A survey using a portable photoionization detector (PIO) of

the area under the slab was made by a State Hazardous Waste

Division representative. 'I'he PID indicated a reading of 7.5 ppn

on the zero scale adjacent to the pit inside. This reading may

have been due to aranatic volatile gases emitted fran a

petroleum-based adhesive used to attach the Styrofoam'" insulation

to the interior frost walL

Soil samples were collected by

sampling fram each soil boring location

pH results are listed betoe in Table 2.

Table 2pH in soil

3 April 1986

continuous split-spoon

shown on Figure 1. The

sample In

8B1.18B1.28B1.3SBl.4

l'.'!

6.555.065.004.12

Depth franGrade (inches)

13-3434-5555-7979-103 saturated

~

OR/\f1 COP~ ~Table 2 (continued)

5ample 10

5B2.15B2.25B2.3

5B3.15B3.25B3.3

5B4.1584.2584.35B4.4

5B5.1

5B6.15B6.28B6.38B6.48B6.58B6.6

Depth fran.!'!! Grade (inches)

6.16 7-285.40 28-527.01 52-64

5.22 0-305.13 30-574.87 57-90

5.05 0-305.26 30-615.63 61-895.62 89-120

7.06 Grab at surface

6.65 0-365.38 36-855.32 85-1205.24 120-151 saturated5.30 151-1865.33 186-214

Soil samples SB1.4 and SB6.3 were selected for Inductive

COUpled Plasma Analysis and Volatile Oocganic Analysis by GC/MS,

EPA Method 624. Sample SBI. 4 was selected for further analysis

due to a lCM pH value (4.12 std. units) and a distinct color

change in the sample core from brosn medium sand over two inches

of white crusty sand over brown sand with traces of white sand.

soil sample SB6.3 was collected in the vadose zone just above the

water table at a location hydraulically dCMngradient fran the

buried tank and the fonner chemical process area. Soil sample

SB1.4, Aquatec lab no. 57242, shews a concentration of 13 micro­

grams per kilcgram of methylene chloride. No other canpounds

analyzed for were detected above their detection limits. No

canpounds analyzed for were detected above their detection limits

in soil sample SB6.3.

GRAFT COpyTable 3 below shows results of eight elements analyzed by ICP

for soil samples 881.4 and SB6.3.

Table 3Metals by ICP, rrg/kg

Sample ID:Aquatec Lab No.:

CadmiumChromiumCopperLeadNickelTinZincMercury

SB1.457242

1.464.760<5

12.4<l

17.3<0.05

SB6.357243

1.6110.317.3

<5n.8

<114.3

<0.05

The results in Table 3 appear to be within the normal back­

ground range for native soils and are sUnilar to previous results

of soil samples reported in the initial site visit report except

for the amount of copper in sample 881.4. The concentration of

copper in previous samples fran "the oil change site, II Aquatec

lab no. 56389 (21 ng/kg), and lithe buried drum sfte ," Aquatec lab

no. 56389 (19 ng!kg), are similar to sample SB6.3, Aquatec lab

no. 57243 (17.3 rrg/kg). '!he concentration of copper in sample

SB1.4, Aquatec lab no. 57242, is three timss higher at 60 mg!kg

but in the same order of magnitude.

7.3 Exploratory wen Results

The exploratory well was developed by air purging and hand

bailing on 3 April 1986. The well was allowed to stand over­

night. The following day, 4 April 1986, the well was purged with

a Teflon'" bladder punp for 100 minutes at a flow rate of 0.5

gallons per minute. The pH, temperature, and conductivity

measurements started at 30 minutes lapsed time. Values are

recorded below in Table 4.

COntinuous pH,

DRAF1 COP~Table 4

Temperature, and COnductivity MeasurementsEX-1

4 April 1981

Time pH Temperature Conductivity(min. elapsed) (std. units) ( 'C) (US/em)

30 6.10 8.4 95.135 6.15 8.3 94.240 6.16 8.3 94.245 6.17 8.4 94.550 6.19 8.4 94.960 6.23 8.4 94.475 6.23 8.5 94.190 6.26 8.4 93.4

Samples for volatile organics and metals were collected after

100 minutes. The metals sample was filtered under anoxic

conditions using a 0.45 micron filter.

Results of volatile organics analysis of the water sample

EX-I, Aquatec lab no. 57228, using EPA Method 624, indicated no

compounds analyzed for were detected above their detection

limits. rcp analysis for metals fran water sample EX-I indicated

no elements analyzed for were above their detection limits. All

laboratory results can be found in Appendix D.

7.4 Geology/Rydrogeology Results

The site is located in a topcqraphtc lCM on the south edge of

the Black River. The site is within the IOO-year flood plane of

the Black River and is included in the core of depression of an

alternative water supply system (see n..tfresne-Henry report dated

March 1995). The local soils encountered in the drilling proqrem

consisted of brown fine sands to coarse gravel throughout the

site.

The local horizontal groundwater flCM direct was determined

by piezometric head measurements in 4 one-inch piezometers. The

groundwater flow direction is from west to east eosards the Black

River. The gravel aquifer appears to be at least thirty feet

thick.

ORl\f1 cor;8. FARFIELD RESUI:rS

The results of the farf ieid electranagnetic survey revealed

two locations in the large rubble that may contain the 55-gallon

drums that were previously excavated. The two locations are

close to a third drum that was exposed. The heavy equipnent

operator, Mr. David Gilman who excavated. the drums earlier, pre­

viously stated that he pushed all three drums at the same time.

These two possible locations of the buried drums have been

staked, but no attempt to remove these drums has been made.

Further survey of the farfield revealed an old crushed drum

exposed at the ground surface. About 20 feet away from the

crushed drum, buried metal material is present. 'I11.ese locations

are shown in Figure 1.

9. <nTCllEIINS

The material in the inside pit does not contain hazardous

materials as indicated by the results of samples analyzed.

An air sample collected and analyzed by Aquatec on 12 March

1986 and a field survey by State officials on 6 March 1986 using

a portable photoionization detector indicate the indoor air was

acceptable for normal working environment.

The exact looation of the sewer line fran the building is

uncertain. No records have been found shewing whether or not

T.A. Electronics discharged into the municipal sewer system.

'!he plumbing scheme associated with the chemical process area

shews the 3-inch PVC lines along the north and west walls flCM by

gravity into the buried tank outside. '!'he material in the buried

tank most likely was pumped into the subsurface pit inside

through the 2-inch PVC line. The material in the pit may have

been pumped back into the buried tank by switching valves. The

DRAFT COpyonly lines located outside were the 2-inch and 6-inch PVC linesbetween the northeast comer and the buried tank.

The results of the analysis of 8B1.4 indicate a spill may

have taken place adjacent to the pit or within the pit itself.

The ground around the pit has settled or been undermined six to

eight inches. '!he acid stains detected in the soil along the

two-inch and 6-inch lines between the building and the buried

tank also support the hypothesis of a previous spill.

The water sample collected fram well EX-l located down­

gradient of the spill site shows a copper concentration bejoc

drinking water standards.

There may be traces of methylene chloride in the local soils.

small aroounts were found in soil sample SBl.4 and in surface soil

samples reported in the previous report. All soil pH

rreasurements appear to have normal soil pH values.

Aquatec recrnmends that the concrete sleeve over the outside

buried tank be removed and the tank filled with gravel and

ccmpacted, Then, a bentonite cap should be constructed on top of

the tank to prevent water from infiltrating into the tank.

Two monitoring wells should be installed in the farfield

dCMngradient of the drum sites and roonitored for volatile

organics. A second sample should be collected from well EX-I and

analyzed for volatile organics.

After the results of the farfield roonitoring well are known,

the buried drums should be excavated after the results of the

farfield monitoring well are known, Excavated drums should be

sampled to determine their contents. The results of the drum

samples will detennine the appropriate disposal method.

uRAFT COpyOnce the drums are removed and the farfield quality is

evaluated, the risk assessment can be coepl.eted, Further inves­

tigation to determine the size, location and integrity of a

buried fuel tank should be performed before further site excava­

tion takes place on the south end of the building. Determination

should be made of whether or not this tank should be categorized

within the Vennont Underground Storage Tank Program.

Appendix A

Stole of Vermolll

Aqenc:y of Fnvi ronmen t.a l Ccus orva ti on

In Tile 1·latter of: Mi ntzer Or-others, Inc.60 Strongs AvenueRutland, Vermont 05701

Hazardous waste storage on ludlow site

Violation of 10 V.S.A. Section 6606(a)Hazardous ~Iaste Without Certification.

Storage of a

The Secretary ("Secretary") of the Vermont Agency of Environmental

Conservation ("Agency") in tile exercise of his authority under '10 V.S.A. Section

6610a, hereby makes tile following:

Findings

1. Mintzer Brothers, Inc. ("/>lintzer") own a site located in the Industrial

Park on Bridge Avenue in Ludlow. Vermont. ['lintzer is currently

developing the property for a retail store. Hintler also owns a retail

lumber and construction materials business located at 60 Strongs Avenue

in Rutland, Vermont .

. 2. The Rutland Group, Inc., Route 4, 1'1endon, Vermunt is tile contractor' for

!·1jntzer on the project. TIle Rutland Group is renovating an existing

building and is conducLing site excuva t ion {Hid w-ac!ifl<j work on the

property. ~I i seII's Exca'lat i ng and Landscep: n'], Inc .. Rochest.er .

Vermont is the suocor.t ractor fur the site H'jt~,.

---- ---- - ------------------------

- 2-

3. In 1980, T.I~. EleC'Lmnics Company, Inc. ("TI\ Elcclrollics") operated an

electroplating business on the site. LA. Electronics plated copper,

nickel, zinc, tin and some mercury on electronic circuit [wards and

parts. Tile cnem ce l s used by this industry included etclling acids and

_ solvents. ~iastewater generated by tile electroplating process was

discharged to the Ludlow Sewage Treatment Plant (L.S.T.P.) following

pretreatment on site. Pretreatment consisted of precipitation of

metals from solutions and pH adjustment of these solutions before

di scnarqe to tile L.S.T.P.

4. I.A. Electronics went bankrupt after one year of operation. A fire

destroyed the bu i l d i nq vs interior about the time of bankruptcy.

Subsequently, the bui Iding was boarded up and unoccupied urrt l I 1984

when Mintzer Brothers purchased the property from the bank. Before

renovat-ion of the building commenced, New England ~larine Contractors,

Inc., a hazardous waste disposal firm, was hired to remove and dispose

of chemicals in drums and tanks in the building. The chemicals were

transported out of state and disposed of at an approved hazardous waste

disposal facility.

5. On 1·larch 5, 1986, the Agency was notified that an employee of \Hsell "s

Excavating ned developed a body rash after unearthing three 55-gallon

drums and a large holding tank on the property. .The employee uncovered

the drums and tank on Friday, February 28, 1986. He returned to work

on 1·londay, 11arch 3, 1986 and had a headache most of the day. That

evening he developed a rash wi th blisters on his back, abdominal area,

back of legs and tile underside of his forearms. He reported these

.. J-

symptoms to 11 i s supe rv i SOt on Iuesuey , narcn II, 19%, dlHI was sent to

tile Emeq]ency Room of tile Rut l and Req iona l Nedical reruer. SitQ

oxcavat i on work \-,1(15 SLopped at th l s t rmo .

6. On Ha rcn 6. 1986, Agency personne I conducted a pre I imi na ry

investigation en tile ~~intzer site in Lurll ow , On th i s same day,

Aquatec, Inc., an environmental services finn, retained by f~lntzer, was

conducting soil and water sampling. Agency investigators observed a

single 55-gal Ion drum wh i ch was collapsed and empty on a pi Ie of

stumps, brush, snow, cables and soil. An inground tank filled wi th

1iquid and located off the northeast corner of the bui Iding was

examined. Photoionization measurements, both inside and outside the

bu i Iding, showed no detectable vapors prcsont .

7. On Harch 11,1986, Aquatec released the results of t ne sampling

performed, in a report ·titled "Initial Site Visit at ludlql'/ Development

Site." The report was distributed at a meeting in Hendon at the

offices of the Rut l and Group, Inc. Present at this meeting It/ere

representatives from nrntzer , their insurance agent and Agency

personnel ..liquid in the inground tank has a pH of 1.4 and contains

relatively high concentrations of methylene chloride, acetone and

tetrachloroethylene among a fe~1 other organic compounds and heavy

metals. Soil samples at two locations showed methylene chloride and

acetone present.

I

8. :·llritl€r nas agreed 1.0 cooperate witt] tile Agency by conducting rurtner

site l nves t i qatons for the purpose of i dentl fy i nq additional

contentnant s , I,jintzer has a Iso agreed to have tile 1iquid contents of

the inground tank and the 55-gallon drums removed from tile site.

Bas-c:d on tne foregoing findings and under the eutnor i tv of 10 V.S.A. Section

6610 a, tile Secretary issues the following:

ORO E R

,j 1. J.1intzel" shall remove the contents of tne inground tank as 500n as

possible, but in no event later than I'larch 31,1986. The work shall be

performed by a certified hazardous waste disposal finn and disposal

shall be at an out-or -s t ate disposal facility cer-t rrted to accept

hazardous waste. ~1I1en the contents are removed, the tank, concrete

tiles and manhole shali be thoroughly cleaned on all interior surr eces .

/2. Soi I borings shall be conducted around tile perimeter of tile inground

tank as soon as the contents are removed and no later than April 7,

1986. The purpose Of soil borings is to collect soil samples for

chemical analysis and for the installation of groundwater monitoring

we l l s to determine wate r quality in the vicinity of tile tank. The

Agency shall be notified before the soil borings are conducted, so tnat

Agency personnel can be present on the site when tile investigative work

commences. The results of this investigation wi II determine jf

additional subsurface' testing and monitoring is required.

-J-

3. HintzeI' snal ) commence a gene:'al si te investigation no inter tnon April

7,1986, to de termi ne if additional t.ank s and/cr drums are buried on

tile property. The investigation plan shall be sulnni LLed to tile Agency

for review prior to implementation. !·leUlOds employed in uu s

investigation shall be interviews with former LA. Electonics

- employees, ludlow town employees and appropriate geopllysical methods.

. 4. In conjunction with (3) above , t'lintzer shall locate and remove two 55­

gallon drums I-ihich were buried in the pi le of stumps, snow and other

debris on the site. These drums, along wi th the. single 55-gallon drum

exposed on the pile, shall be examined carefully for any signs of

leakage and, if appropriate, handled as a hazardous waste by

individuals trained to deal Idth tnese materials. If these drums

contain a hazardous wa ste , they shall be disposed of at a certified

out-of-state disposal facility as soon as is possible.

\/5. On or before "'larch 31, 1986, l'iintzer shall conduct an air monitoring

program for volatile organic compounds in the workspace wi th.i n tile

bui Iding undergoing renovation.

6. When parts of the concrete bui lding floor are removed to accomodate

drains and wastewater pipes, rtntzer shali collect soil samples from

these areas for chemical analysis. Samples shall be analyzed for

volatile organic compounds using EPA method 624 and for concentrations

of the metals: cadmium, chromium, copper, lead, mercury, nickel, tin and

zinc.

7. !,iinLzer sha l l remove the ingrounej lank and any other tanks \~hicll are

found, upon completion of tile soil lJOl'iWI and moni t orinq proqrnn

provided tnat tdnk(s) remova l does not intel'rere witf any on-uotnq site

monitoring activities. Disposal of the t ankIs ) wil l be at a certified

landfill in Vennont following a thorough cleaning of all parts.

8. - HintzeI' shall Forward all investigative report s and results of soil and

water testing to tile Aqency for its review and approval. Reports and

test results shall be torweroed as soon as they are available. These

reports and results ~1i]J be used by tile Agency tv de te nni ne the degree

of site contamination, the need for an on-going or expanded monitoring

program, and the need for remedial actions. The Agency shall be

notified \1hen any site excavations or borings are to be performed.

Date

. .

-r-)---,-f>! \uA{,,,'.( /'/ Jonathan t.ash , Commissioner

Department of Water. Resourcesand

Environmental EngineeringAgency of Envi ronmentaJ .Conservat i on

Appendix B

STATE OF VERMONTENVIRONMENTAL BOARD

DiSTRICT ENVIRONMENTAL COMMISSION #RR #1, BOX 33, NORTH SPRINGFIELD, VT 05150

TEL: 885-5751

April 7, 1986

fZ.e-G-;cI 4 /q /ec"Mr. Roland LuxenbergAquatec75 Green Mountain DriveSouth Burlington, VT 05401

RE: Land Use Permit #250467T.A. Electronics, Co.Ludlow

Dear Roland:

In response to your request for plumbing plans for theformer T.A. Electronics Company bUilding in Ludlow, Ireviewed our files and found the enclosed information. Ihope it is of some use to you.

Sincerely,

~a~o0'Charles A. BridgesAssistant District

Coordinator

CAB:gv

Enclosure

._.==--

'JOt{ cteetl:oltleJ eo" !lltC,49 Pearl Street

SPRINGFIELD, VERMONT 05156

TA Electronics Co., Inc. will be engaged in the manufacturingo£ Printed Circuit Boards.

The related process involves the waste of solid metals such ascopper and tin/lead and acids such as sulphuric and hydrochloric.Although the actual consentration of waste is minimal, steps arebeing taken to further minimize the possibility of waste watercontamination.

"All rinse waters having a solid metal content are being recycledand filtered before entering the waste holding tank. Once the wastewater is in the tank, remaining solids are parcipitated out of thewater and the PH adjusted be£ore disposal to the sewer. The wastesludge is then sold as scrap metal.

The chemical in itself is not disposed of in the sewer. Afterthe chemical is spent. it is returned to its original container andremoved by the chemical supplier. Such as in the case of copperetchants.

-Most of the equipment used has either a double "rinse chamber withrecirculator or a filter system on both. Thus further minimizingthe d~sposal of hazardous wast~.

18021 885·4876

TABLE I

The proposed process and equipment are as followsl

1. All waste water other'than sanitary waste, will be fedinto a 1000 gallon tank (1) where the ph will monitoredand adjusted for optimum precipitation of contaminants.

2. The waste will flow by gravity into tank #2 (1000gallons) where flucculent will be added to aidfiltration.

3. It will then be pumped through a 50 gpm diatomaceousearth filter (5 hp pump). Solid waste will be collectedfor disposal in approved dumps.

4. This will be followed by a 50 gpm p~lishing filtercoated with diatomaceous earth and Xanthate or suitablesubstitute to reduce contaminants below 0.5 ppm.

6.

The effluent from above will gravity flow into a 500tank for final ph adjustment after which it will passthrough a mixed bed ion exchange unit to remove salts.

The ph of effluent from the ion exchange unit will bemonitored and recorded continuously and the effluentitself will be recycled or fed to sewer as required.

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N<l,u,~1 R~'OUfC~S Con~"r ....'(,Ol' Council

Hr. Ni.cho Las DeGiglio'1'A Electronics Company, Inc.~9 Pearl S't ree cSpringfield, VT 05156

Gentlemen:

i\l,,"lpdi"r_ V\'liIiOII! ().'illlJ~

I t'·p.lrllll'·ld q( \\ .ucr t{t'~Il11l"l-CS

RE: Discharge to Hun Lc Lpa L SNJer Sys t em

l'u c Lo s e! is your copy u f ch e n b o v c rcrcrcu c o d

p e rm t t \-1111cll h u s been s t gn c d by ch o Sc c r e r a r y of t hcAg811CY of Enviro!llilentill Conscrv~tiOll.

1']l!:ISl~ I'v.ld tile cn c Lr c p erm Lc c n rc tul t y .tnc!fnlni1i~rize yourself with all it:s terms ~Ild callJi~jD;IS.

Your attention is p a r c Lc u Ler Ly dLr c c t c d to ch o s e coi. d tc to n swl,icll may rQqllir~ writtcl1 r~BpDI\SeS bv ccrrriill Jat~~. Pleasecb e ck to see t h n t all pages a r c Ln c Lud c d in y o ur pc rm Lt .

[ fplease

you hilV02 <lnycontact us at

questionsonc~ .

c o n c o rn an g YUUl' ·pel·l::! t I

HIIF/bj

Vary truly yours,

) " . "I \ !.ilju, c/ ,I, /1, ,,,' -".,.,I h'il.lnl"d n. Fvi rnham

[nvir011ilI011l:ill I~llgineer

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Permit No. 3-0360

l'ERHlT FOR DISCHARGE TO HUNICIPAL SEI,'ER SYSTEN

In compliance with th provisions of the Vermont Hater Pollution ControlAct, as amended, (10 V.S.A., Chapter 47 § 1251~. ~j the "Ac c i ) ,

T A Electronics Company, Inc.

is authorized to discharge from a facility located at/-:~u - /C; cU3tf"~ ~_-,;;::¢l..g, Vermont

to the municipal sewer sys nm of

Lud O·.oJ Nuni clpnL Sewage 'rrc atment rLan c

in accordance wi th di.schar e limitations, monitoring requirements and otherconditions set forth in Pu cs I, II, and III hereof.

This permit shall b ec me effective on June 1, 1980

This permit .und the at thorlzation to discharge shall expire at midnight,

Nay 31, 1985

1\Signed this S' day of I~}f!

Form \,R-SO

/98

A.

During the period beeinning June 1, 1980f c Ll ow i ng d Ls c h a rg e s (s e r i a l numb e r s sbo.... n) are

Elcctroless Fl e t Lng Line R'in s e

and iast i ngauthor i z c d :

th rou~:'1 Hay 31. 1985

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u i s chc r gc{Lb s yday ) O't her Un l t s

~:on~ tor in)', Rcc u i r ec.c n t s

(Spcc Lf v )

j-tca s ur ecent 'S<1 ~,;) 1c

O.J. i 1)' ~:ax Freq~cncy 'IY?C

(.0005) Continuous D:l i l~' ~!~l:': .,

,:''''r·"0.1 mg/1 1 x Non tb ly Ccrapost r C'

0.1 mg/! 1 Yo !'lonthly Ccmp os .i r r-

0.5 mg/l 1 x NonthLy Compos i Lv

O. 1 mr-/I 1 x Bi-annlJ;1l]y COT::!),-''!' i ~ c ~

0.1 mg/l 1 x R'i-rannua Lly (O::IPOS; t c1 x Non til 1:.- Cccpos i : (.

Daily Avg

(fJ0035)

O.:1ily !-:.J.XDe i l y Avg

(HGD)

Tin~!'lng.:.mesc ~.

He rcu t-y :-:0 det cc t ob Le ccncen t r a t f ons obove background LcveLs«

fl0w_m3 IDa,;,

1..e a dCopper?\ick('l

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The pH 5h311 not be less than 6and shall be monitored

s t anda r d units nor greater t h an 8.5 s t a nd a r d un t c s

"a cc r

Samples taken in compli;:mce with the monitoring reguiremE'nts specified above: shall be taken"---<jatthe follo;.nn ....... loca:ion(s), A S Li - -, 1-t ,.:Imp .111iJ p i r p r i o r t o .... tv ch ar gc into Non I c i pn I SySt02"l. -'!-;<,::I.:

Supply b e Fo r e a dcl-it Lon of process chnm i c a Ls and effluent s.:.mples ah a Ll be tested for uc r curymon ttr l v • This r oqud r cmcnt OlI;Jy he de Lc.... ced c I t cr (1 monttis a t. the d t sc recs t o» of t hr- dcpo r trsc-it •

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:':o;:e: The' r-ecene rnn t for the ion-exchange un Lt ah a Lj not be d Ls p os c d .o f in the e Ef Iuo n t .

or cbc rc gcnc rnn t is acccp r ob Le p r ovd dcd re gcncr.n t r ccc ives crc ot.men t in the vcst o streamp r ec Lp Lt n t Lo n , settling and ion-exchange.

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PART I

Pngn 2 of 1.0

Penni t No. 3-0360

I. Till' p"Imiec;,>£! shu L! achieve complaince with the effluent l Imi t a t i onsspecified for l i s cha r gus in accordance 'With the fo Llov Lng echedu l e :

An e f f Luen r; sa np Lf.n g pit and £101.] meter shall be Lns t aLl edprior to camille cement of discharge.

,.. No later t1131\ 4 c:llendar days following a date identified in theabove schedule of compliance, the pct-cu c r cc ah811 submit e Lt h c r areport of prog css or, in the case of specific actions beingrequired by id'ntifled dates, a written notice of compliance ornoncornp l Lan c e , In the latter case, the notice sh a Ll include thecause of noneo p Li a nc c , [lI\y remedial uc t Lons taken, and thep r o bab i l t r y of meeting the next scheduled requirement.

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;

PART I

of 10

c. HON nOllING AND REPORT INC

S"mples and mea s 'Cements taken as required herein shn l l ber ep r es ent a t tve of the volume and nature of the nont ro r eddischarge.

P~rlnit No. )-0360

/-;onito1'10g'results shall be reported on ac c ep t cb l e , forms submittedto the following ad,lress:

State of VermontAgency of Environmental ConservationDepartment of Water ResourceSState Office BuildingHc nt p e Li e r , Vermont 05602

'Lhcse reports s li II be submitted on the 10th tiny of [110...' m(,\ntll fU~!.O\Jing the

s'.!2!.lpJi ng .zs l"!:.-~~.Th c in it t a 1 r e po t is d ue on ~JC,,"l,)C'-=1,°2,..-:1,90.::8,° _

J. De f Ln Lt i ons

Irup Lerncn t a t Lon S hedule - An abatement program cons Iu t t ug of:

a. A plan of i tended design, construction. and operation ofnc .... or modi, Led facilities to pretreat the discharge; and

b. A timetable setting forth the dut ca b y vh i ch all d t ochuvge smos t be in -omp Lia nc e with the Llml t n c t ons of this permit,The s chcdu Lb shall include (if epp r o pr La t e ) Lnt e r Lm and f Lna Idates to ac cmp Lte b :

(1 ) Comple ion of preliminary plans and engtncering report(2 ) Comple ion of finnl p13ns(3) Contra t a.... nrd(4 ) Commen ume nt of constructton(5 ) Comple 100 of cous r ruc t Ion nnt! c omneucemcnt of operation(0) Attain nen t of operutional level

Compo ai t e Sa'l\rIe - A s nmp l o cone t s c t ng of II mLntn.uai ofsamp l c s col l ec ted at r cgu l a r intervals over /1 no rrc.r l ,-'per-atin;.;.lnd combined pro ort rona l to flo ...·, or a s amp Le cou t t n uously(-.Jl!t,c':,·d pr.J[l,H l ouu l to t I ov 0\"'1" a no rm.r l cpe r a c tng day.

, . -, , '"_-'::':'::":'::=~~~~_._--'-_._ .. _-_-... ..•_~ ...- .-" ......_--_.-...... .._._---

PART I

1"~r1111 t No. 3-0360

r.rabe1l:1 n

~;:lruP~I' - rIo individual sumple collected In It perI od o I lcnsl~ 11l11111tC~.

4. T~3t Procedure

Test procedureregulae ions p uPoll ut ion CantGuidelines estin t hc Pe d e r e I16, 1973.

for the analysi~ of polilltonts shall conform toLf.s hed pu r aunnt; to Section JOtI (g) of the Federal ve c c r01 Act, under which such procedures may be r equire d ,b l Ls hLng che s e test procedures hove been publishedRegister as Vol. J8 No. 199, Part II, dated October

'i. Rc c or dt ng of It suits

For each men s uot th i s permit

emen r or s nmpl e taken pursuant to the requirementsthe permittee shall record the' Io Llovtng tn Io rcac i on :

,

---1""\-

PART I

Page 5 of 10

permit No. 3-0360

.1. The cxnc t p l a c o , date, lind t Lme of uemp l Lng ;

b. 'LIC' da r c s tho aua l y s c s were performed;

6.

c. The personfS) vue performed the analyses;

d. The analyrCal techniques or methods ue ed ;

c. The reSUljS of all required ann l ys es ; a nd ,

f. Weatllcr C ltdltions, plant operstillg condition,or abnorm 1 condltion shall also be noted.

Additional tto» [t o r Lng by Permittee

and any unusual

7.

If the pe rrnt t t e monitors any pollutant at the Ioce r Iont s ) designatedherein rao r e fr queu t l y than required by this pc rmt c , us Ing approvednna l yc Ic a I me t l ods as specified above, the results of such monitoringshall be inc l uded in the monitoring reports outlined above. Such!ncre~sed freq eocy shall also be indicated.

~ecorJs Retenti[,n

All records and i.nfo rma t i on resulting from the monitoring activitiesrequired by this permit including all records of ana Iys c s performedand c e l Lbra t Iou and ma Lnt cnancc of instrumentation and t-e c o r d ingsfrom continuous monitoring Ina t rumenc a r Ion shn l I be retained for aminimum of rnre (3) years, or longer if requested by the Secretary.

", ,..~_~jj.:.ii.'~...::.:.._.,' .'-- ,,----'--..- _..

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PART 11

of .l.O

I. Ctlilngc io Oisctlnrge

Permi r No. 3-0360

,\11 discharges authorized herein shall be consistent wLth the termsa nd conditions of thLs permit, The discharge of lilly pollutantidentified in this permit more frequently t han or LIt a Leve I inexcess of th a t authorized shall constitute a v Lol nrton of the permt r .Any anti,cipated facility expansLol\, production iocreH~es, or processmod i Li c a t Lons which will result ln new. d l I Ee re nt; , o r i nc r en s eddischarges of pollutnnts must be reported Ily Bubmisolons of a n~w

pormi t epp Lt c a c ton or, if such changes will not violate tile discharge1 i mt t a t i ons specified in this permit, by notice to the pe rmt c t osutngauthority of such changes. Following such notice, the pe rmt c mily bern od i f Led to specify and limit a~y pollutants not previously limited.

Houc omp l i.anc e No t i f i c n t i on

If. for <Iny r c a s on , the permittee docs not comply vt tlr or v i l l beunab l c to comply v i th any daily maximum Hmtre c Ion sp e c i f Led in thisl'i'rmit. the permittee shall provide the Secretary v Lth the followinginformation, in ..... r Lr Ing , within five (5) days of becoming aware ofsuch condition:

a. A description of the discharge a nd cause of non c omp Li.nnc e ; and

h. The p e r i od of noncompliance, including e xnc t da c e s an d times;or, if not' corrected, the anticipated t Lme the noncomplianceis c xp ec r e d to continue, nrul steps being t ck cn to r cduco ,eliminate and prevent recurrence of the noncomplying d t e cherge .

I. fnciliclcs Operation

Tl1£' permittee shall at a I I times nm i n t a Lu In good vork tng o rdc r andopc ra c c as efficiently a s possible all p r c t r ca tmeu c or controlfacilities, or syStprnS installed or usctl by tile pct"lnittcc to achievecompliance with the t e rms and conditions of t h i s pe rmi c .

.', Aovers c Lmpnc t

'fhl:' pe rm i f t e e sha l I r ak e ;1}1 rc a s o nabLc s t eps t c- min i m t vo ,In::

:hh{'r~e irapac t; r o the u.un t c Lpn l r.r cur.u.cu c fucilit:: id\,I,("r t oll;l\'i'-;,lb~~ v aro rs r os ol r t ng from nonccr.rpj fenc c I.'ill! i.!ll'/ t tnu tat t onu

sp,'cifieJ in t ni s pe r-mt c , including e uc u o c c c Le ra r cd or' audi r i onn lU,u:11turing as IH'C~S$,I!'y to <ll~t·'r('lllh: t.he on r u r e <Ind !CI:P;,Ct of the1\"llt;)r~r~yilli; di:;dlilq',t'.

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I'I\RT II

7 (J f .10

Pe rmt c No. 3-0360

Any d tvc r s ton t r on. or t.yp a s s of pretreatment fuc I I Lc Lc s necellsll1:Y toma Lut u t n compliance with the r e rma and conditions of t h Lu permit t a

_ prohibited except; where unnvo Ldab l c to prevent loss of Lff e ors.eve r e property domag e . The pe rmt t t e c ahe l I promptly notify the~ c c r e t a ry in vrt t ing of each such diversion or bypaas ..

6. xr-novcd Suns t anc es

Sc l i ds , s I odgc s , filter back..... Ash. or ocbe r po t Juteucs r ernove d ill thecourse of pretreutment or control of wastewaters ~ltall he diop6sedelf (1) in a manner s ccu as to prevent any pc Ll utenc from sucho.a t c r i a l s from entering navigable wa t e r s , and (2) in a maun e r andlocation acceptable co the Agency.

7. Power Failures

In order to ma Ln t n i n compliance .... ith t he dLe clju r-gc luatc e t i ons andproh ib i t i ons of this permit, the permittee shalt either:

fl., In accordance with the Schedule of Comp Lfunc e cout a ined inPart 1,. pr c v i d e an alternative power eourc c sufficient tooperate the pre t r e a tme nt; facilities;

or, if sucll alt~rnative power source is not itl existence, and noda t e for its implementation appears in part I,

b. na l t , .r cdu c c or otherwise cont ro l production nnd/or a l Idischarges upon the r edec t ton , Loe e , oc Fu Ll ut-e of theprimary SOUl"Cl! of power to the p r e t re n tment; f ac i Li t i cs .

11. RE::;PONS 11\ lLITlES

1. Right of Entry

The permittee shu I I ul l ov the h e ad of the State «ac e r po l Iut t oncontrol agency nnd Zor his autho rLz ed representatives, upon thepresentation of credentials:

a. To enter upon tile permittee's premIses wll~rc " JIS(:lurl;e isl oc a t.cd o r in \Jhi.ch any reco r ds arc r cq uired t o b·~ kr-pr. underr he r e r ms aile! c ond i r t cos of cu Ls pe rmi t."; and

b. ,'It \·,'.15011Hb!(' tl,,)(':; to hnve aCCCSf; to and ":"1"':1 .ru',' r ucords

r"quit"ed to !'l· k.'pt nnde r the ccrms "lId c ooot r tcu.. of tt.t s:,<~n.,jc; to j:I';IIl~Cl ,lilY t~;<I!jillJrln;~ ('qull'l;.,·nl ur 1;"J"it.I·lil'~; .c tncdr ..qut re d in t.ht s pcnlllt; Hili t o ~,,:j'id(' ,Illy d;~;~I'<lr/.12 l"

,hlLiut"nts,

PART II

B of 10

Pc cmtc Nc , 3-0360

/.. 'l'rans f e r of O.....nersu t p or Cou t ro l

III rhc- event of ~ll\y cbnugc in cont r o l or owuu rah t p of [Ill': l t Lt t cs fromwhich the authorized d t s cb a r gcu cmeunt c , the p e rmLt t e e uhu l L notifythe s uc c ce d Lng ovuc r or controller of the existence of chis pc rmt.t

"by letter, a copy of which e he j I be forwarded to the Sc-cn:t8'!'».

3. Ava Ll ab t l i t y of Reports

Except for data determined to be confldentlal under Sectiun 1259 (e)of tl\e Act, all rCpDrta prepared in accordance with tfle termS ofthis permit shall be available for public rne pec t rou fit the officesof the State vat e r pollution cont r o I ugency . As r-equLr ed by theAct. d Lscha r ge data shall not he cone t derec conf td cn t La l . Knov Lugl ymaking any La l s e statement on ;}f\Y such report may r e s uj r t n theLmpos t t t un of criminal penalties as provided for in Section 1275 (b)of the Act,

'.. pe rmft hod i f Lcn z Lon

After notice an d opportunity for a hcs r Lng , this permit may hemodified, suspended, or revoked in .....hole or in part during its termfor cause including, but not limited to, the fc Ll ov Lng .

a, Violation of any t e rms or conditions of this pc rmt t ;

b. Obt aLn i ng chis permit by ml e r cpree en t e t Lon or failure todisclose fully all rcleva~t facts; or

c. A change in any condition thilt requires e Ltl.e r a t ernpo r nry orpermanent reduction or e l Lmlnn t i on of the nuthc r Lzed d Ische r ge .

S. Toxic Pollutants

Notwithstanding par c II, II-I, above, t f ,I toxic c f f Lucnt s t nndnr d orprohibition {Lu c Lud Lng any schedule of c orap l i au c e s pe c t Li cd in suchcf Ll uent standard or prohibition) is c e t ab l t uh ed nuuer- Section 307 (a)of t1\0 Federal Water Pollution Control Act for a toxic lJollutant....hJ..eh is present in t he discharge nnd such standard or prohibitionis no r e s r r i ngc nc t hau any l ImLt a t Lon for such pol l ot anc hi tu tupe rm i t , this pend t sba l l oe r ev Lscd or modified in ac c or dancc \I!.thtlle toxic ~ffillcl\t stnL1Jard or prohibJ..tlon nnd thB perm!tt~e Souot Lf i e d .

--- --_._-_._'-~- --'._--_...._-

PART II

of 10

Permi t No. J-O)GO

i, , Civil :1001 Crilllilln! LiHbilily

E~,C"PI ;IS prov i de d in permrt conditions on "Hypauu ing" (llllrt 11.,,;-5) and "Po....tcr F:\ilures" (Part II, A-7), no th Lng in t h In permit

_f:h.lll be cous c r ccd to re l t cve the permt t t ee I rom c i v Ll or criminalpenalties for noncompliance.

7. u t I and lla za rduus Substance Liability

.tor b t ng in this permit sha l.I be construed to preclude the institutionof any legal aLtion or relieve tllC !,crmittee from ally respollsibilitLes,liabilities, or penalties to .... hich the permittee is or may b e subjectunder Section 1281 of tlte Act.

8. ~;tate and Local La~~, Regulations, Ordinances, etc.

N(lt!ling il\ tllis rcrllit shall be construed to preclude the institutionof any legal action o r relieve the permittee from any responsibilities,liabilities, or pen3lties established pursuant to nny apl)lic:~ble

State of Lcc c l Iii .... or regulation, e cc . , undc r authority p r e s c r ved bySec c ton 510 of the Pcde r a I Water Pollution Control Act.

'). Property Rfght s

Issuance of this permit does not convey any property riglltH ineither real or personal property, or nny exclusive privileges, nordoes it authorize any injury to p r Lva t e prope r t y o r uny invasionof personal r Lgb t n , nor any infringement of federal, State or locall a .... 5. or r egu l a t ions.

10. Sevt.'J:ability

The provisions of this permit are severable, lind if /lily provisionof this permit, or the application of Clny provision of this permitto any-c t r c ums r anc e , Ls held invalid, thc app l Lcn t t on of nuchprovision to other c t r c ums t onc e s , and the remainder of this permit,sball not be affected tbereby.

11. Authority

This permit is issued under nu rho r Lt y of Section 1259 (If ellt.' Ac t'..,I,ich requires a p orn-t t Lor d i s churg c into fI publicly o'.-uc.: c r o.vrme nc

· .., .---.~'''''''''''-'--'''--

,

.",~-- ,~,- --_.._---...........-.-'-_._------- .._-----_..._-- -- '., ._._.,,_.-------------~. -_.,._~--_.~--_._-

PART r t

Page 10

l'ennit Nn.

'.Jurlu. ;01/ w:I~;l" wh i ch in t orLer es v Lth , pa~;~,·:; tlll·OII!,.h c i.thour

t rcatr.nm t , (I[ i s otherw i s e Lncompn c Lb l c Ylth such wo r ku or would11~v~ n subst3ntial aJv~rse effect on suel) ~orks.

PART III

OTHER I:£QU lREHENTS

of 10

3-0360

,,,",

Appendix C

,

.~n ;;.::, '~~)~ :. :'03Jnd,~,~!j 1.J., v t, 1,~4f':!

t ?~-.,:::.;::,

;';r. .Jobn ut cnoi~'::UD :-.e c Inc.75 G=zen Mount~i~ Dr.So . Bu r I .inq t o n , v t . {;S4Cl

The Eo11o~in~ are the bori~~ 100$ ~or ~h2 Lu110w i'rcjactccnduc t ed un.Jc r I:i,,-,' di r e c t Lc n 0:: '(::::1 r apre s e n t I no; e cne t oc Lnc ,

.4SPVC-'Ie':\co.Sa q s SG.n~j: 1

'k==.ter LeveL: e.c.ue cec'rop slot -t-e.bove -;"£'10 ... <,.;~(t~·r: 3£'10"

p-l

~d 15#

r~ 4/(11 /r~ sUJDtC't. si

-t;.7'

.... o t a Lr:: .... '••'",." C·I.~,-J.Ci\ L:~·.L •..

30,25 123,19 (010\0,1$ f r o.n a #14C hammer falling 3D" to drive astan~ard p0~atration sa:npler 6" -blow cou~ts ate notintended for. load bearing Lnforme t i cn , 1.e; er-rpbaa La is ens emp Le r.2CO\:c·Cj) Le rqe c ru s hed vb I t;e a t.c ne o:1U «rev c I .Re Eu s e L, r ocks •4 r~ttel~\pts-:,jo ru.c the r s aup j e s-caock s t

H():"Hl'OR. tliEI"LI" F6ctcry threaded & Slotted (.020'1)

Slot·tei~ sec t Ioo s r ' Sc.Li.d Rd ne r e Lb 'Sand Pac\ To belc4 q~aja:-12' Betonite Pluq:5 ~ of 3/8 ~s at &1

~- ~ ~" ,~ "''_." .,

?ii'':-l'e;,lCO.22'o'~:::: Sand: 1

( .02C")

v ,,:, t" j c 0 ,I'<lc. (; t.e-1 •b r own f i ne .:_n~l med i.u.n

tl)reada:! & Slotte0ScLi d R.iser:15'

If:,~~6,:2.3 Ljgtt o ("O'fl{, c r-ave L e nd coe r s e ee no 3ithsilt lenses, setur~te~. ~a~er =ccu~~ at .. ~-5'

P,.:;,~~,4. Li?Lt/ -

1 " :;0- c/:· -, cv~c;; '-'. t

aec t i one L '

-G.t l

-J.L'

si.oce.e-r5snj ?ac~ To belo0 q~ade:-131

(;.:: I

'I'o t.e L o ;,~"'.1c;.- '." '- ..~ .' ~;;.'l t.er 1: e ve Le'[to fl

, /-'/('..'t, ~ 0<:

L["i!)i,:J'fl ;:'\

-5'

-6.6'

- 9 . f~. '

p-3lC,b,7,5 Bnown :1<:~jl:~·. ':It:::.:lq,.-r. ;:::(),.! C02.r:;;{~. s an-t ~:ith SO(!1<..~ o r e v e Iover m:)ttle~ fi~e sanJ.3,6,7 ErOWil fine sand an.! ~ilt ov~r ~e0iu~ coerse sand ~nj

gr~vel, saturate:J.Br-own C!)F.\r:--)~ o enci v i th ~~O;'k' I.i(..·-;.i~>'~l e-nd aome ~1.'Ca·...el,e a t u r a t ed ,

-11. ,

mm7 •

'-;~l n .! ,

..'• "! 'J

,\;S- f' t

~)VC':"";f,'?mc() •nag:; S3n(~: 1

?lur~:lr,i; of 3/8

tsro v-: c(:.";t",';:O' :3.~\·'~ 2:r...: '.;~'i";..«e tu r z.t.-.j .!'It.pn;;;:.r.ir~,::; :><tni<· O!: coc x-i-: "'11:,1 :.......~ .i.i (;:,., .s e n.! (3-·~1I) ve r ve a tn r et e.f.:",~"li'l"~ ."'n;! COe(,:::·: '>2.n:J c» t.e,;., 0:: o x id i zc-r i c r anqc i'i(~'jiLlii1

bo~h .cor:taill a little silt.s r c-..... n coe r s e ee n-r an.i nco i o.n sand ever~ine san.l and silt.

-17. z'

-22 '

1" ~&ctorv threaJe~ & Slotted (.020")s t ot r et sGction:l' so r I-t ni:':F:'1;:12'Said .t;~c:': 'I'o be Lo-c qrz:.:::e:-13.S' Be t c n i t.e

we t.ar Le veL: Acuat.e c'Ie:; s Lc t. -i-e co ve -ioc Low Hel t e r s ee Lo.e

'I'c t e L <?it>-=:l~ .15'titie'.;. UF: I.!,'

,.,..

11,

\1

_7.4'

-lC.;'; I

-22.3'

-17.3'

-1J.ql-15.1'

LUD(;~I\'i F'; P-l-~.ti' ·5,15,20,26 Light l,rown ~rv Ein~ and medi'Jffi ssnd with grav.;;l

p r oceb Lv fill.3,3,3,.; ~.!~(liur'i an(~ cce r s e sand wi t h some q re ve l. o nd a Ld t t.Lesilt, :.la~'l?

2,2,3,251;0··,,,1 s a t.u r a t ed coe r s a sail,] a no q r a ve L, ve te r occur'Sac o u t 7'.5,S,4,~ Coarse and me~iu~ hro0rl san~ over gravel, saturated.6,12,9,7 SatlJrate~ layers of coarse sand ~ith gravel andmeJiu~ ~and (3-4 H

)

BrC0~ coarse san~ and gr9vel with SOM~ roe1i'J~ sand.~affie, sl~~rr:ati;l; b~nds coarse san~ an~l gravel.~ "- .... '_"••.. c: •

'..;a t er,

vvc-ue tu r t cb .Bags Sand:l.7.5 .~9

'PJ.l'::'~1:1:::;# c r 3/f-: ~:$ e t;

~5t~~,Level:9.5'

'[or slot +a~ove -~elo.J

threa~&J 5 Slotte~ (.flO")So Li d Ri s e r . 2C 1

c r e.de e r-Lk ' Be t.c ni t.e

3/4" sec t c r vSlottei section:2'oS.?n:.!. PeC"; 'I'c oe Lo :v'I'o t.e.L Pir8:~('.::·'

-4.1:'_7.:'

3,<:,3,:, ::ill,~;ravel': s'}.'IL rjnu sua L 1" ;':CO,":l 0:«:'.1:0'=-' :'\2.;"'.;:.

9,~,11,~3. ?o3sible fill, ~ravelly 5ao·1, ~educed t,&nJ.

" .. ..,\ .. -~~.)

-S'aro..n s i Ltv S2!r:~~ till.3,3,?,':'.Lir;r:t ~):-o',.;n coe re e c an ..1 ,'5, s ome c r ave L,

-7.t' 5,7,lO,~. Setur~t2d coarse sand 0itl1 littl,e silt & gr~vGl.

-10.7' 3,(,4,~. Li0ht l,rC0n fine GanJ & lensG of (;rAvsl.Fow~r ~~seJ rig & '~rill steel.

}-;C;-·~I'i·:)[--:: \·i:~I,rJ

-7.1'

-le'

-12.1)'

~ 5 SB-6, EX-I9,9,18,1(i. Gr~velly SatlJ fill, over gre01t siltylerlse ove=1&lil~ coarse send ~it;l some silt.3,t',i5,":'. ~~n':02'1 b t own o r e ve Ljv .'3·:1rL: .r itl. 30m~~ silt, o r a n-j eexirl8zcrl layer, Ja~~.

7,&,2,3. Satur~ted qr~vel & cnerS8 san~ & srnne Ein~ rlar%brown sa!ld ban0/~.

sand) ,;:;.lso

• 4Ssvc-ue i.Je i cr.,

Baq s Sa nd r IsP1U9: 25~- of 3/8

~ome fine & somg co~rsewithBrown ffip,lium s~n'~

::,,':.,~,i'. ~_:r:)\vll ~"",!:·l.r;tt-- l coe rv e "';":1,1 & c r ave I v i t t.e Lt e rne t Lno l a v e re c,;: -ie- r k lvr o.c n CC2.n,(! e en.l , :::.:.'t~:r'Jt~"·~.

3/<1,~,7. Cc er s r ';~i(,·~ 01, to,' of r-e.Liun -s an.j be c ooi i nc f i n-e r •

vct.u r c t e-L2,J,S,S. Al t.e r na t.Lu.. b""'-l.!::: of rned i ur-Vcoe r s c s a n-t I'- o r avc..d.3,3,:1,5. 11f~"i:i.1Jm e en-: [,. o r e vr-L ove r Cine .s a nd , 's a t.u r e t c f &b r own ,

-17. t· '

1 c- t; t- ~ .' . "

-2lJ.()'_"lC; 1.1

<- ~ ...

-LI.C' 2,3,3,ti.sanu .

-29. 7' J~·5,·5-. Los t; s emp Le flustJE"a out.-]2.4 1 -,3,3,6.Bro~11 satur&te~ me~iu~ ;3&nd.Installed Hell but could not oac k it :,.lith*-'......i·t.h s a nd (Elo,,]in~1'

air punpArt very siltv fine 33n1, ~rilled anot~;er holedifficult clue to E16~ing £anJ.

,"10N!T:)R. :"'SLL2~ Factory threacla~ & Slotted (.0],0")

g Lo t t.e.I section:2G ' Solid Ri ae r e?"Sand Pack To below grade:-4.5 1 Be t.o n i te

r

I"

'I'1I'I:1j,

2.5 1

Stic1{ Up:2 1

Air pumpeC cleanTo~ slot +above -belo~ water:

at bottom brown at tOQ of Bcreen.2'+-

Gerard Ada~s

-, ",

Appendix D

()aquatecENVIRONMENTAL SERVICES

7S Or~~fl Mountllin Drive, So. Burlillgton.VT 05401TEl... 8021658<1074

ANALYTICAL- REPORTThe Rutland Group

Date: 3/18/86Project No: 86019ETR No: 7070Sample(s) Received On: 3/12/86Page 1 or 1

Standard analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA-600!4/79-020,Test Methods for Evaluating Solid Waate, SW-846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mgll unless otherwise noted.

Parameter 56571

resorptdon Effic~~of Methylene Chlar'

(%) 83.4

Methylene Chloride iJug/liter of air at

60°F and 1 atm. <0.04

,!

-

Lab No. Sample Description

56571- Charooal tube Erorn Ludlow developrent site at RG. COllected 3/12/86 inN.E. corner of building. -

! -.

Submitted BY•.:;! f}1fMm !J;lv/JPi? A

Aqua tee Inc.

)

()aquatecENVIRONMENTAL SERVICES

7S Gr«n Mountain Drive, So. Burlington, VT 05401TEL. 8021658-1074

ANALYTICAL REPORT

Aquatec Lab No.: 56688ETR No.: 7111, Project 86019Sample Received On: 19 March 1986Sample Identification: Rutland Group, sediment sample #RG3P from

the pit inside the building on 3/19/86 at0945

Volatile organic Ccrepounda in ug/kg wet

trichlorofluoromethanel,l-dichloroethenel,l-dichloroethanetrans-l,2-dichloroethenechloroform1,2-dichloroethaneL, 1 , 1 trichloroethanecarbon tetrachloridebranodichloranethane1,2-dichloropropane

trichloroethenecis 1,3-dichloropropenedibromochloramethane1,1,2 trichloroethanebranoformtetrachloroethene1, 1, 2, 2-tetrachloroethanechlorobenzenemethylene chloride

<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5

Rutland GrOUp

()aquatecENVIRONMENTAL SERVICES

75 Gre<:n Mountain Drive, So. Burlington. vr 05401TEL.80Zl658-1074

ANALYTICAL REPORTDate: 4/4/86Project No: 86019ETR No: 7213

Sllmple(s) Received On: 4/1/86Page 1 of 1

Standard-analyses were performed in accordance with Methods for Analysis of Water and WllStes, EPA~600/4./79-020,Test Methods for Evaluating Solid Waste, SW-846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mg!1 unless otherwise noted.

Parameter 57041

zinc 0.10

Copper 6.6

Tin 0.21

pH (std. units) 6.8

Lab No. Sample Description

57041. Rinse water after the cleaning tank, collected 3/28/86 at the Illdlow site.

Aqua tee Inc.

()aquatecENVIRONMENTAL SERVICES

7S Green Mountain Delve, So. BlIrlingron, VT05401TEL. 8021658-1074

ANALYTICAL REPORTDate: 3/31/86

Rutland Group Project No: 86019ETRNo: 7167Sample(s) Received On: 3/26/86Page 1 of 1

Standarq analyees were performed in accordance with Methods for Analysis of Water and Wastes, EPA~600/4/79~020,Test Methods for Evaluating Solid Waste, SW-84.6, or Standard Methods for the Examination of Water and Wastewater.

All results are in mg!1 unless otherwise noted.

Parameter

pH 1.4 1.3 1.5.

Acidity to pH = 4(as Caco

3) 6200

Vc UITe of 0% NaOH w/w requ red to r ~utraliz 2828go Ions of the site (1 ~ no. 5€912) to H = 4i' 18.3 ga Hons , atu e Lncree Ise. effe :ted byre I>traliza :ion """'Jd be abo t 3°F.

Lab No. Sample Description

56909. Liquid sample ro11ected fran the surface on 3/12/86, ID. R61T.

56910. Liquid sarrple oollected from 6 I below the water on 3/12/86, ID. R62T.

56911. Liquid sarrpje ro11ec:ted from 12' below the water on 3/12/86, ID. R63T.

56912. Composf.te sarrple, famed by Aquatec of OOlT, RG2T, ani RG3T, 3/26/86.

Submitted By, t? I he: ch'1 /hvj/lop Aquatec Inc.

(}aquatecENVIRONMENTAL SERVICES

7SGreen Mountain Drive.So. Burlington, VT054011CL.802/658-1074

AN AL YTICAL REPORT.

The Rutland GroupD ate , 4/11/86Project No: 86019ETR No: 7252Sample(a) Received On: 4/7/86Page 1 of 1

Standarq analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA~600/4/79.020,

Test Methods for Evaluating Solid Waste, SW-846, or Standard Methods for the Examination of Water and Wastewater.All results are in mg!1 unless otherwise noted.

Parameter 57228

cadmium <0.01

Chrcmium <0.01

Copper <0.015

Lead <0.10

M=ury <0.0005

Nickel <0.015

Tin <0.05

Zinc <0.01

Lab No. Sample Description

57228. Filtered portion of sample from Ludlow devejoprent; site, 4/4/86, No. EX-I.

Submitted By: J? /lv,~. /7L Pb,Aquatec Inc.

--

(}aquatecENVIRONMENTAL SERVICES

75 G.""n Mountain Drive, So. Burlington, VT05401TEL 8021658-1074

ANALYTICAL REPORT,

Date: 4/11/86The Rutland Group Project No: 86019

ETRNo: 7257Sample(s) Received On: 4/7/86Page 1 of 1

Standard analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA-600/4/79-020,Test Methods for Evaluating Solid Waste, SW_846. or Standard Methods for the Examination of Water and Wastewater.

All results are in mg/I unless otherwise noted.

Parameter 57242 57243

All Results are inmg/Kg

cadmium 1.46 1.61

Chromium 4.7 10.3

Copper 60 17.3

lead <5 <5

I'.ercury <0.05 <0.05

Nickel 12.4 11.8

Tin <1 <l

Zinc 17.3 14.3

Lab No. Sample Description

57242. Soil sample labeled SB1.4.

57243. Soil sample labeled SB6.3.

Submitted By: K//lC0/h ~ahAquatec Inc.

(}aquatecENVIRONMENTAL SERVICES

75 Green Mountain Drive, So. BurlingtOn,vr 05401TEL. 8021658-1074

ANALYTICAL REPORT

Aquatec Lab No.: 57242ETR No.: 7257. Project 86019Sample Received On: 7 April 1986Sample Identification: Rutland Group, soil sample labeled SBl.4

vokat; He Organic Compounds in ug/kg wet

acrolein 100 U methylene chloride Beacrylonitrile 100 U chloranethane 10 Ubenzene 5 U brancmethane 10 Ucarbon tetrachloride 5 U branoform 5 Uchlorobenzene 5 U b~odichloromethane 5 U1,2-dichloroethane 5 U dibrcmJChloranethane 5 U1,1, I-trichloroethane 5 U tetrachloroethene 5 U1,1-dichloroethane 5 U toluene 5 U1,1,2-trichloroethane 5 U trichloroethene 5 U1,1,2,2 tetrachloroethane 5 U vinyl chloride 10 Uchloroethane 10 U acetone Nrn2-chloroethyl vinyl ether 10 U 2-butanone 10 Uchloroform 5 U carbon disulfide 5 U1,1-dichloroethene 5 U 2-hexanone 10 U1,2-dichloroethene 5 U 4~thyl-2-pentanone 10 U1,2-dichloropropane 5 U styrene 5 Utrans 1,3-dichloropropene 5 U vinyl acetate 10 Ucis 1,3-dichloropropene 5 U tbtal xylenes 5 Uethylbenzene 5 U

No volatile organic ccmpounds not on the Hazardous ,Substances List (compoundslisted above) were found in reportable concentrations.

Key to the letters used to qualify the results of the analysis:

U - The compound was analyzed forbut not detected. The numberis the detection limit for theeatpOUnd.

NOB - Quantitation is not possibledue to the relative concentra­tion of the compound in theblank.

K - The ccepound was analyzed forand detected, but at a con­centration not reliably quan­tifiable. The number is thedetection limit for the canpound.

C - The resul t has been correctedfor the presence of the canpoundin the blank.

(}aquatecENVIRONMENTAL SERVICES

75 Green Mountain Drive, So. Burlington, VT 05401TEl.. 8021658-1074

ANALYTICAL REPORT

Aquatec Lab No. : 57243ETR No.: 7257, Project 86019Sample Received On: 7 April 1986Sample Identification: Rutland Group, soil sample labeled S86.3

volatile Organic Corepounde in ug/kg wet.

acrolein 100 U methylene chloride NOOacrylonitrile 100 U chloranethane 10 Ubenzene 5 U brcmanethane 10 Ucarbon tetrachloride 5 U brcm:Jform 5 Uchlorobenzene 5 U branodichlorcmethane 5 U1,2-dichloroethane 5 U dibramochloramethane 5 Ul,l,l-trichloroethane 5 U tetrachloroethene 5 Ul,l-dichloroethane 5 U toluene 5 U1,1, 2-trichloroethane 5 U trichloroethene 5 U1,1,2,2-tetrachloroethane 5 U vinyl chloride 10 Uchloroethane 10 U acetone NOO2-chlorcethyl vinyl ether 10 U 2-butanone 10 Uchloroform 5 U carbon disulfide 5 Ul,l-dichloroethene 5 u 2-hexanone 10 U1,2-dichloroethene 5 U 4-methyl-2-pentanone 10 Ul,2-dichloropropane 5 U styrene 5 Utrans-l,3-dichloropropene 5 U vinyl acetate 10 ucis-l,3-dichloropropene 5 U total xylenes 5 Uethylbenzene 5 U

No volatile organic canpounds not on the Hazardous Substances List (ccmpoundslisted above) were found in reportable concentrations.

Key to the letters used to qualify the results of the analysis:

U - The compound was analyzed forbut not detected. The numberis the detection limit for thecompound,

NDB - Quantitation is not possibledue to the relative concentra­tion of the canpound in theblank.

K - The canpound was analyzed forand detected, but at a con­centration not reliably quan­tifiable. The number is thedetection limit for the ccrpound,

c - The result has been correctedfor the presence of the cempoundin the blank.

()aquatecENVIRONMENTAL SERVICES

75 Green Mountain Drive, So. Burlington. VT 05401TEL 8021658-1074

ANALYTICAL REPORT

Aquatec Lab No.: 57227ETR No.: 7252, Project 86019Sample Received On: 4 April 1986Sample Identification: Rutland Group, water sample from Ludlow devel.opnent;

site, 4/4/86, iEX-l

Volatile Organic compounds in ug/l

acrolein 100 U methylene chloride Nffiacrylonitrile 100 U chloranethane 10 Ubenzene 5 U brananethane 10 Ucarbon tetrachloride 5 U branoform 5 Uchlorobenzene 5 U bromodichloromethane 5 U1,2-dichloroethane 5 U dibramochloramethane 5 Ul,l,l-trichloroethane 5 U tetrachloroethene 5 U1,1-dichloroethane 5 U toluene 5 U1,1,2-trichloroethane 5 U trichloroethene 5 U1,1,2,2-tetrachloroethane 5 U vinyl chloride 10 Uchloroethane 10 U acetone Nffi2-chloroethyl vinyl ether 10 U 2-butanone 10 Uchloroform 5 U carbon disulfide 5 Ul,l-dichloroethene 5 U 2-hexanone 10 U1,2-dichloroethene 5 U 44nethyl-2-pentanone 10 Ul,2-dichloropropane 5 U styrene 5 Utrans l,3-dichloropropene 5 U vinyl acetate 10 Ucis-l,3-dichloropropene 5 U total xvjenes 5 Uethylbenzene 5 U

No volatile organic canpounds not on the Hazardous substances List (canpoundslisted above) were found in reportable concentrations.

Key to the letters used to qualify the results of the analysis:

u - 111e compound was analyzed forbut not detected. The numberis the detection limit for thecanpound.

NOB - Quantitation is not possibledue to the relative concentra­tion of the canpound in theblank.

K - The corrpound was analyzed forand detected, rut at a con­centration not reliably quan­tifiable. The number is thedetection limit for the compound,

C - The result has been correctedfor the presence of the canpoundin the blank.

equeiec INC. ENVIRONMENTAL SERVICES

75 GREEN MOUNTAIN DRIVE, SOUTH BURLINGTON, VERMONT 05401, TELEPHONE (802) 658·1074

1 April 1986

Mr. John AmadonAgency of Environmental ConservationWaste Management DivisionMontpelier, VT 05602

Dear Mr. Amadon:

Enclosed is our outline of work activities to implement the orderfrom the State of Vermont, 10 V.S.A. Section 6610a, dated March23, 1986. This outline, Flow Diagram of site Assessment, wassubmitted to the Rutland Group on 28 March 1986 and is presentlybeing implemented.

The tank was pumped out and cleaned by New England Marine on 28March 1986. A final rinse sample was submitted to Aquatec foranalysis on 1 April 1986. This sample will be analyzed for zinc,copper, and tin, three metals that were high in the initial wastewater.

Mr. John Diego and Mr. Roland Luxenberg will be at the siteduring the week of 31 March-4 April 1986. The objective of thisweek of work is to complete the "Tank Assessment" portion of theflow diagram of site assessment and to complete the "Nearfield/Farfield site Assessment" through the geophysical search forburied tanks, lines, and drums.

If you have any questions, please do not hesitate to call.

Very truly yours,

~7V~ ..:Ic-<" CRoger C. Binkerd, P.E.

k/3.101

Enclosure

c: Mr. Brad Thomas, Rutland Group, Inc.

Hydrographic Studies and Analyses e Water Quality StudleaEcological Studies a ComputerSlmulations e

e Analytical LaboratoriesIndustrial Waste Surveys

fOLD AT (-I TO AT DRAWING BOAAD EHVEl.OPE' EW10P

[E The Drawing BOard". NOTE-O-GRAM •POBOX 220505 DAl-l-AS TEXAS 75222 REORDER TEM" NN 3CALL TOLL FREE 1800-5279530 I 7

RUTLAND GROUP, INC.PaC a BDX 365. RUTLAND, VERMDNT 05701 • (80Z) 775-19a1

M E 5 5 A G E R E P L V

I I CATETO

kr'"n-> , (J1)M..J AM.." ....~

l..:: ::..lCATE IMtZ-<+i 3/ 198 {p

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~ -n+£ :D ISPOS>tt- c# ;2.Jcc. ~.JS

P<.JMf'e.:> M«>M -r>-rE -'-""'-~ "TANK

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L-VOU>W Vez.~. p,-€~ CALL

,,c 10'-' 1#tV"- "''''--1 (i)UG=~'" -.J'O,tfN- JM~"cf.d- IfVA- 3d'ttC:L 3

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•• KE!';PVEU..OW=pv.... ElEND ........... AND PINK C(3PlEB INTACT.

INlO1'1'IUCTlCNS TO "'!,;CSve...

1.WR.... FII!Pl..V. ... cETACH S1lJB, KEEf'PlNI< ClOPV. ""'TuRN....,.,m;: ClOPY'TO SENCER.

March 28, 1986

State of VermontAgency of Environmental ConservationMr. John AmadonState Office BuildingMontpelier, VT 05602

Reference: Soil Borings at Mintzer Site

Dear John:

The general site investigation for additional buriedlines, and drums is scheduled to start Monday, March 31,

tanks,1986.

We will have a drilling rig at the site on Tuesday, April 1for soil borings around the tank.

If you have any questions regarding this, please do not hesitateto contact me.

Sincerely,

THE RUTLAND GROUP, INC.CON~~N DIVISION

Bradford B. ThomasProject Manager

BBT/nem

cc: Mr. Arthur H. Lennox, II

RUTLAND GROUP INC. RT. 4 MENDON .VT. 05701 (802) 775· 1981

75 GREEN MOUNTAIN DRIVE, SOUTH BURLINGTON, VERMONT 05401, TELEPHONE (802) 658.1074

28 March 1986

Mr. Brad ThomasRutland Group, Inc.Route 4Mendon, VT 05701

RE: Modification to Rutland Group Contract, Sections 8 and 13Aquatec Project No. 86014

Dear Mr. Thomas:

Enclosed is a flow diagram proposal of the work to be performedat the Ludlow Development site. Mr. John Amadon has reviewedthis proposal and has concurred with it in conjunction with theState of Vermont's 6610(a) order.

Aquatec has conducted further testing of samples previouslycollected from the tank to determine the method of neutralizingand mixing of the tank for New England Marine Contractors. Thetank is scheduled to be pumped on March 28, 1986. New EnglandMarine Contractors will collect final rinse waters for analysisto verify adequate decontamination. Once the verification andsite investigation are complete, the tank may be disposed offollowing procedures outlined in Section 7 of the 6610(a) order.

The Tank Assessment tasks are scheduled to begin on Monday, March31, 1986. I anticipate completing these tasks by April 4, 1986.The evaluation of the data will be started the following week,April 7, 1986.

Some of the Nearfield/Farfield Site Assessment tasks will beperformed in conjunction with the Tank Assessment Tasks; however,I do not anticipate completing the "Geophysical search for buriedtanks, lines and drums" by April 4, 1986.

It is important to complete the Tank Assessment task before April7, 1986 as indicated in the 6610(a) order.

Hydrographic Studies and Analyses Water Quality StudiesEcological Studies Comou ter Simulations

Analytical LaboratoriesIndustria! Waste Surveys

·'

Mr. Hr.an Thomas?~ -ta r ch 19r1!)Pe q c 7.

The cost estimate to pe r f or-m s e r v i ce s during the we o k at: Ne r cb31, lqBf) through April 4, 1986 is The actual cost mayvary, depending on depth of wells and pie7.ometer, materialsneeded, and the actual number of samples collected for analysis.

The intent of this letter is to act as a modificationscope of work Eor the Aquatec-Rutlanrl Group contract.sign where indicated below and return one copy to our

If you have any questions, please call Our office.

Very truly yours,/ ' r........

. /nit,;f uJU'7"Jjhn R. DiegoEngineer

k/7.25

Enclosure

c: Mr. Stan Cocnielle

to thePlease

office.

Accepted for Rutland Group, Inc.

By:

Date:

Accepted Aquatec, Inc.

Date:

"Vi'L '::'J ';I''',JP, I' c.;\<rJ"t,_,c I',-ojc,ct :W. H(,()19

1'1.0':.' ;Jl,v;'<AN {iF si-rt: i\S~I<SS~IENT

IN 1,\;I)L01l', VI-:HMONT, W,HCII 27, 198G

1-----------l)lL1'bl'.,l,' n'''iutlsc',.oj 1, "i,-, t.:lllk ;melpit il""l ",is

IDetennin~ q .."'"tity ,Iof NaOli to neutre l.Lzctank contents

)NearfieldjF<ll:f ield

Sit" !\.<;scsSllIentI!'IaiOOve and dispos" 0' I:~rial in bur'Ied

i:';O~';iifiii'i"i'iiJo~o~oif~-~~O;-~ -,.J Off-si te rcconnai.s- II-~-------------~I tamination of w.nk by I -I ~ance plans, maps,final rinse analysis I~:,"~~~~~,:e:,,:.!;:,:;;:;;;:::;:;;:~

IInst"ll p~e=ters

IGeophysical searchfor buried canks ,lines and drums I

IInstall exploratoryrroni taring well ooen­o ,

Collect continuous 1['split spoon samples wifield pH lTl:'>asu~nts

ISurvey ,.;ell for _ Ilocation and elevation I I

Install monitoring\''ells!piezanetel-s

Collect split spoons""lJ1es lv/field pH

uremmts I

,I

)

I

fo< Ielevationl

pure],;, ")1(1 sample

Survey wellslocation and

IIlJ1alyzc s<o"ples

I

I

~!::>nitOf p!l and oon­ductivi ty duringI

I '-U-/-,,'.-,,,~;;ct,c'-'",oc- ~ ['ie" "';;:;"",:;;----'1L·.. ,-----·--------------'11':";';';':'":",,1'/'/""'''' '''''','''' ""'.~J ----.---------------------- -----,----

:-WG'-

Svall.latc data

?l.lfge ood!/-bn i tor pH andI <;'01ductivity during~OMq

equetec INC. ENVIRONMENTAL SERVICES

75 GREEN MOUNTAIN DRIVE, SOUTH BURLINGTON, VERMONT 05401, TELEPHONE (802) 658-1074

24 March 1986

Mr. stan CornielleWaste Management DivisionAgency of Environmental ConservationMontpelier, VT 05602

RE: Rutland Group, Inc.; Aquatec Project No. 86019

Dear Mr. Cornielle:

Enclosed are results of analysis of additional samplescollected at the Mintzer Brothers development site inLudlow, Vermont. Also enclosed is a brief scope ofservices that will be provided to the Rutland Group byAquatec.

Aquatec will follow with a more detailed technical proposalregarding sections B4 and B5 of Exhibit A.

If you have any questions, please call our office.

~ truIy:~ours/r-

I::~h e Vu.yJohn R. DiegoEngineer

JRD/kjn

Enclosures

c: Mr. John Amadon

________~~~_~iHydrographic Studies and Analyses 81 Water Quality Studies

Ecological Studies ., Computer Simulations ..e Analytical Laboratories

Industrial Waste Surveys

()aquatecENVIRONMENTAL SERVICES

75 Green Moun";n Dlive. So. Burlinl(ton, VT 05401TEL. 8021658-1074

Aquatec lab No.: 56688ETR No.: 7111, Project 86019Sample Received On: 19 March 1986Sample Identification: Rutland Group, sediment sample #RG3P from

the pit inside the building on 3/19/8e at0945

Volatile Organic Compounds in ug!kg wet

trichlorofluoromethanel,l-dichloroethenel,l-dichloroethanetrans-l,2-dichloroethenechloroform1,2-dichloroethane1,I,I-trichloroethanecarbon tetrachloridebrornodichloromethane1,2-dichloropropane

trichloroethenecis-l,3-dichloropropene

1,1,2-trichloroethanebranofonntetrachloroethene1,1,2,2-tetrachloroethanechlorobenzenemethylene chloride

<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5<5

(}aquatecENVIRONMENTAL SERVICES

75 Green Moum3in Drive, So. Burlington, VT 05101TEL. 8021658-1074

~. • ...., ' '>. ' '.

The Rutland Group D.'" 3/18/86Proje<::t No: 86019ETR No: 7070

Sample(s) Received On: 3/12/86Page 1 of 1

Standard analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA-600j4/79.020,Test Methods for Evaluating Solid Waste, SW-846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mg/l unless otherwise noted.

Parameter 56571

Desorption Efficienqof M8thylene Chlorick

(%) 83.4

M=thylene Chloride .ir~g/liter of air at

60°F and 1 atm. <0.04

Lab No. Sample Description

56571. Charcoal tube from Ludlow developrent site at RG. Collected 3/12/86 inN.E. corner of building.

Aqua tee Inc.

()aquatecENVIRONMENTAL SERVICES

75 Green Mountain O,ive, So. Burlington. VT 05401TEL. 8021658-1074

Aquatec Lab No.: 56391E:TR No.: 7030Sample Received On: 3/6/86Sample Identification: water sample from Tank #1

Acid Extractable Semivolatile Organic \~unds in ug/1

2,4,6-trichlorophenolp-chlor~-cresol

2-chlorophenol2,4-dichlorophenol2,4-dimethylphenol2-nitrophenol4-nitrophenol2,4-dinitrophenol4,6-dinitro-2~ethylphenol

pentachlorophenolphenol 680l:enzoic acid2-methylphenol4;nethylphenol2,4,5-trichlorophenol

200 U200 U200 u200 U200 U200 U

1000 U1000 U1000 U1000 U

1000 K200 U200 U

1000 U

Key to the letters used to qualify the results of the analysis:

U - The compound was analyzed forbut not detected. The numberis the detection limit for thecompound.

NOB - Ouantitation is not possihledue to the relative concentr~­

tion of the compound in theblank.

K - The compound was analyzed forand detected, but at a con­centration not reliably quan­tifiable. The number is thedetection limit for the compound.

C - The result has been correctedfor the presence of the compoundin the blank.

()aquatecENVIRONMENTAL SERVICES

7S Glecn Mountain Drive. So. Burlington. VT 05401TEL. 8021658-1074

;A N AL.YTICA:f:R'EP'bRT. . . '.' . ..Aquatec Lab No.: 56391= No., 7030Sample Received On: 3/6/86Sa~ple Identification: Water sample fr.om Tank *1

Base/Neutral Extractable 8emivolatile Organic Compounds in ug/l

acenaphthenebenzidine1,2,4-trichlorobenzenehexachlorobenzenehexachloroethanebis (2-chloroethyl) ether2-chloronaphthalene

1,3-dichlorobenzene1,4-dichlorobenzene3,3 1-dichlorobenzidine

2,4-dinitrotoluene2,6-dinitrotoluenefluoranthene4 chlorophenyl phenyl ether4-bramophenyl phenyl etherbis (2 chloroisopropyl) etherbis (2-chloroethoxy)methanehexachlorobutadienehexachlorocyclopentadieneisophoronenaphthalenenitrobenzeneN-nitrosodimethylamine

N-nitrosodipropylaminebis (2-ethylhexyl) phthalate

200 U1000 U

200 U200 U200 U200 U200 U200 U200 U200 U400 U200 [J

200 U200 U

200 U200 U200 U200 U200 U200 U200 U200 U

390

benzyl butyl phthalate _di-n-butyl phthalate

benzo(a)pyrene

benzo(k)fluoranthenechryseneacenaphthyleneanthracenebenzo(ghi )perylenefluorenephenanthrene

indeno(l,2,3-cd)eyrenepyreneanilinebenzyl alcohol4-chloroanilinedibenzofuran2~thylnaphthalene

2-nitroaniline3-nitroanilinea-ni.eroenlLinemixed phenoxyethanols 12000

200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U200 U

1000 U1000 U1000 U

Key to the letters used to qualify the results of the analysis:

U - The compound was analyzed forhut not detected. The numberis the detection llinit for thecanpoun(j.

NOB - Ouantitation is not possihle(jue to the relative concentra­tion of. the compound in theblank.

K - The compound was analyzed forand detected, but at a con­centration not reliably quan­tifiable. The number is thedetection limit for the compound.

C - The resul t has heen correctedfor the presence of the ca~und

in the blank.

EKHIBIT A

SCOPE OF SERVICES

A. Inmediate Response (work completed on 11 March 1986)

Step 1:

Aquatec provided sampling and analysis of suspected contam­

ination of a Ludlow development site owned by the Mintzer

Brothers. This work was as discussed with Nicholas C. Santo of

Aquatec on 5 March 1986. Analysis included pH, volatile organics

(VOC) as on the EPA Priority Pollutant List, and an Iep scan for

metals.

Step 2:

Based upon the results of Step 1 and discussions with the

Rutland Group on 7 March 1986, Aquatec felt that it was in the

best interest of all parties to conduct further analysis of other

toxic metals, namely cyanide, -hexavalent chromium, pesticides,

and base/neutral acid extractables. (These chemicals are all

named as hazardous compounds on the EPA Priority Pollutant List.)

This work was essential for health and safety and will be needed

for disposal of materials. These chemicals were not included in

Step 1 since they are relatively expensive to conduct and would

probably have been unnecessary if the results of Step 1 indicated

that organic compounds were not present.

Step 3:

Aquatec, Inc. prepared a report and attended a meeting on 11

March 1986 with the Rutland Group, the owners of the site, and

the State to discuss the preliminary findings f.rom work in Steps

1 and 2 above.

-1-

B. Site Assessment

1. Air Monitoring

Aquatec will collect one sample from inside the building for

analysis of methylene chloride.

2. Buried Tank

Aquatec will sample the buried tank at three levels (top,

mid, and bottom) and save the contents for possible analysis.

Equal portions of each sample constitute a composite sample.

Aquatec will provide technical support for the contractor hired

to transport material from the site to a hazardous waste

facility. Technical support may include, hut is not limited to,

determination of chemical contents and methods for pretreatment

of waste. After removal of contents and cleaning of the tank,

Aquatec will sample the final rinse water for tin, copper, and

pH.

3. Pit Tank

'!his tank is located in the building. Aquatec will sample

the sludge in the tank and analyze for pH, chlorinated hydro­

carbons, and metals.

4. Soil Samples in Building

Aquatec will sample soil

building. Analysis will include

5. Nearfield Site Assessment

under existing lines in the

pH and chlorinated hydrocarbons.

The nearfield site assessment refers to an area immediately

adjacent to the building, approximately within 35 feet. The

objective is to locate, or assist in the location of, any

additional buried tanks. This investigation will involve inter­

views, tracing paths of existing pipes, and direct inspection.

If tanks are discovered, they should be analyzed as neces~ary for

hazardous waste.

-2-

After the contents of the existing buried tanks are removed,

Aquatec will establish an exploratory well downgradient of the

buried tank. Groundwater will be collected and analyzed for

hazardous waste. The specifications for the well will be deter­

mined by Aquatec, approved by the State's representative, and

installed under supervision of Aquatec. A composite soil sample

and water sample will be analyzed for chlorinated hydrocarbons

and pll , Additional borings will be made in the vicinity of the

buried tank and split-spoon samples will be collected for

analysis of chlorinated hydrocarbons and pH. A report will be

prepared documenting the nearfield site assessment.

c. Farfield Site Assessment

Infonnation will be gathered on the farfield site prior to

field investigation. This information will be used to define a

specific field prcgram agreed upon with the sbabe'.a representa­

tives. It is anticipated that this prcgram will include the

search for buried drums since drums have already been uncovered

on the site.

The farfield site assessment may include the mapping of the

location of drums, excavation of d~DTIS, sampling, and analysis of

drum contents. Additional sampling will depend upon the

discovery of buried drums , At least one exploratory well will be

required downgradient of the site. The exact number and place­

ment of wells or borings for soil samples will depend on the

information gathered.

D. GrnERAL COIISULTm3

Aquatec will provide consulting services as required which

will include, but not limited to, phone and meeting consulta­

tions, arranging for subcontracts, and review of data and status

report with the State of Vermont , Depar-tment; of Envirorunental

Conserve t ion.

-3-

State of Vermont

Agency of Environmental Conservation

In The Matter of: Mintzer Brothers, Inc.60 Strongs AvenueRutland, Vermont 05701

Hazardous waste storage on Ludlow site

Violation of 10 V.S.A. Section 6606(a) - Storage of aHazardous Waste Without Certification.

The Secretary ("Secretary") of the Vermont Agency of Environmental

Conservation ("Agency") in the exercise of his authority under 10 V.S.A. Section

6610a. hereby makes the following:

Findings

1. Mintzer Brothers, Inc. ("Mintzer") own a site located in the Industrial

Park on Bridge Avenue in Ludlow, Vermont. Mintzer is currently

developing the property for a retail store. Mintzer also owns a retail

lumber and construction materials business located at 60 Strongs Avenue

in Rutland, Vermont.

2. The Rutland Group, Inc., Route 4, Mendon, Vermont is the contractor for

Mintzer on the project. The Rutland Group is renovating an existing

bUilding and is conducting site excavation and grading work on the

property_ Wisell's Excavating and Landscaping, Inc., Rochester,

Vermont is the subcontractor for the site work.

-2-

3. In 1980, LA. Electronics Company, Inc. ("TA Electronics") operated an

electroplating business on the site. I.A. Electronics plated copper,

nickel, zinc. tin and some mercury on electronic circuit boards and

parts. The chemicals used by this industry included etching acids and

solvents. Wastewater generated by the electroplating process was

discharged to the Ludlow Sewage Treatment Plant (L.S.T.P.l following

pretreatment on site. Pretreatment consisted of precipitation of

metals from solutions and pH adjustment of these solutions before

discharge to the L.S.T.P.

4. T.A. Electronics went bankrupt after one year of operation. A fire

destroyed the building's interior about the time of bankruptcy.

Subsequently, the building was boarded up and unoccupied until 1984

when Mintzer Brothers purchased the property from the bank. Before

renovation of the building commenced, New England Marine Contractors,

Inc., a hazardous waste disposal firm, was hired to remove and dispose

of chemicals in drums and tanks in the building. The chemicals were

transported out of state and disposed of at an approved hazardous waste

disposal facility.

5. On March 5, 1986, the Agency was notified that an employee of Wisell's

Excavating had developed a body rash after unearthing three 55-gallon

drums and a large holding tank on the property. The employee uncovered

the drums and tank on Friday, February 28, 1986. He returned to work

on Monday, March 3, 1986 and had a headache most of the day. That

evening he developed a rash with blisters on his back, abdominal area,

back of legs and the underside of his forearms. He reported these

-3-

symptoms to his supervisor on Tuesday, March 4. 1986. and was sent to

the Emergency Room of the Rutland Regional Medical Center. Site

excavation work was stopped at this time.

6. On March 6, 1986, Agency personnel conducted a preliminary

investigation on the Mintzer site in Ludlow. On this same day,

Aquatec, Inc .. an environmental services firm, retained by Mintzer, was

conducting soil and water sampling. Agency investigators observed a

single 55-gallon drum which was collapsed and empty on a pile of

stumps, brush, snow, cables and soil. An inground tank filled with

liquid and located off the northeast corner of the building was

examined. Photoionization measurements, both inside and outside the

building, showed no detectable vapors present.

7. On March 11, 1986, Aquatec released the results of the sampling

performed, in a report titled "Initial Site Visit at Ludlow Development

Site." The report was distributed at a meeting in Mendon at the

offices of the Rutland Group, Inc. Present at this meeting were

representatives from Mintzer, their insurance agent and Agency

personnel. Liquid in the inground tank has a pH of 1.4 and contains

relatively high concentrations of methylene chloride, acetone and

tetrachloroethylene among a few other organic compounds and heavy

metals. Soil samples at two locations showed methylene chloride and

acetone present.

-4-

8. Mintzer has agreed to cooperate with the Agency by conducting further

site investigatons for the purpose of identifying additional

contaminants. Mintzer has also agreed to have the liquid contents of

the inground tank and the 55-gallon drums removed from the site.

8ased on the foregoing findings and under the authority of 10 V.S.A. Section

6610 a. the Secretary issues the following:

ORO E R

1. Mintzer shall remove the contents of the inground tank as soon as

possible, but in no event later than March 31, 1986. The work shall be

performed by a certified hazardous waste disposal firm and disposal

shall be at an out-of-state disposal facility certified to accept

hazardous waste. When the contents are removed, the tank. concrete

tiles and manhole shall be thoroughly cleaned on all interior surfaces.

2. Soil borings shall be conducted around the perimeter of the inground

tank as soon as the contents are removed and no later than April 7,

1986. The purpose of soil borings is to collect soil samples for

chemical analysis and for the installation of groundwater monitoring

wells to determine water quality in the vicinity of the tank. The

Agency shall be notified before the soil borings are conducted, so that

Agency personnel can be present on the site when the investigative work

commences. The results of this investigation will determine if

additional subsurface testing and monitoring is required.

-5-

3. Mintzer shall commence a general site investigation no later than April

7, 1986, to determine if additional tanks and/or drums are buried on

the property. The investigation plan shall be submitted to the Agency

for review prior to implementation. Methods employed in this

investigation shall be interviews with former T.A. Electonics

employees, Ludlow town employees and appropriate geophysical methods.

4. In conjunction with (3) above, Mintzer shall locate and remove two 55­

gallon drums which were buried in the pile of stumps, snow and other

debris on the site. These drums, along with the single 55-gallon drum

exposed on the pile, shall be examined carefully for any signs of

leakage and, if appropriate, handled as a hazardous waste by

individuals trained to deal with these materials. If these drums

contain a hazardous waste, they shall be disposed of at a certified

out-of-state disposal facility as soon as is possible.

5. On or before March 31, 1986, Mintzer shall conduct an air monitoring

program for volatile organic compounds in the workspace within the

building undergoing renovation.

6. When parts of the concrete building floor are removed to accomodate

drains and wastewater pipes. Mintzer shall collect soil samples from

these areas for chemical analysis. Samples shall be analyzed for

volatile organic compounds using EPA method 624 and for concentrations

of the metals: cadmium, chromium, copper. lead, mercury, nickel, tin and

zinc.

7. Mintzer shall remove the inground tank and any other tanks which are

found, upon completion of. the soil boring and monitoring program

provided that tank(s) removal does not interfere with anyon-going site

monItoring activities. Disposal of the tank(s) will be at a certified

landfill in Vermont following a thorough cleaning of all parts.

8. Mintzer shall forward all investigative reports and results of soil and

water testing to the Agency for its review and approval. Reports and

test results shall be forwarded as soon as they are available. These

reports and results will be used by the Agency to determine the degree

of site contamination, the need for an on-going or expanded monitoring

program. and the need for remedial actions. The Agency shall be

notified when any site excavations or borings are to be performed.

Date Jonathan Lash, CommissionerDepartment of Water Resources

andEnvironmental Engineering

Agency of Environmental Conservation

MEMORANDUM

TO: Jonathan Lash, Commissioner, Department of Water Resources

THRU: John A. Malter, Director, Waste Management DiVi.SiO~Reginald A. LaRosa, Chief of Operations tI'

FROM: Stanley Corneille s,e,DATE: Marco 20, 1986

RE: Mintzer Brothers, Inc. Ludlow Site Contamination

Attached for your review and signature is a draft 661D(a) order requiring

Mintzer Brothers, Inc. to take specific cleanup and investigative actions on the

site they are developing in the Ludlow Industrial Park. They have agreed to

cooperate with us in the cleanup "effort. The order formalizes the process. One

employee working on the site uncovered a buried tank and some 55-gallon drums

while bulldozing. He developed a body rash. Site work has stopped. We must

issue this order in timely fashion, since the situation in Ludlow could become

more serious.

ESC/bj I

STATE OF VERMONTAGE;NCY OF HUMAN SE:RVICE:S

March 18, 1986

Dean BrownLudlow Town ManagerLudlow, VT 051lj9

DEPARTMENT OF HEALTH

60 MAIN STREET

P.O. BOX 70

BURUNGTON, VERMONT 05402

RE; Ballpark Well Hazardous Waste Investigation

Dear Mr. Brown:

This letter follows my Friday, March 7, 1986 telephoneconversation regarding hazardous waste investigations underwayby the Agency of Environmental Conservation (AEC) i~ theindustrial park adjacent to the demonstration well at theBallpark site.

I relayed the results of my recent discussion with StanCo1'08111e, Investigator from AEC. Stan mentioned the following:

1. The investigation was ongoing at the TA Electric site whichIs located directly uphill of the sewage treatment plantalong Pleasant Street.

2. Investigation waS warranted because the Rutland Group isdeveloping this site for the Mintzer Brothers Lumber Co.for a proposed lumber yard and retail outlet. Friday,February 28, 1986, the bulldozer operator unearthed threebarrels and piled them with snow and dirt and other refuse.Monday, March 3, 1986, at the end of the workday theoperator of the bulldozer developed a rash during theworkday he changed the oil on site. It is uncertain whetherthe rash is related to an exposure to a hazardous chemical.Later in the week, Stan Corneille met on site anddiscovered one of the barrels had a label of methylenechloride.

3. TA Electric Co. was a plating company which used severalheavy metals and had a. discharge permit to the municipalsewage treatment plant.

Enclosed is a copy of the possible cone of depression map fromthe Dufresne Henry report that shows the location of thedemonstration well and the area in which the demonstration well

may draw from. My present understanding is that this wellincludes the site of the TA Electronics.

I called Brian Quaker at the AEC to discuss the dischargepermit for TA Electric. Brian Quaker was unable to find thepermit because it had expired and the firm was no longer inbusiness but would order a copy of it from their archives.Based on his files, he learned that TA Electric was an electriccircuit board manufacturer and that like industries have wasteswhich include volatile organic chemicals and metals. Brianmentioned that trichloroethylene may be a contaminant in thiswaste stream.

I called Nick Santo of Aquatec to learn the turn around timefor an analysis for methylene chloride. He mentioned that the62~ sample could be turned around in a matter of days if theyrush priority were put on it.

I called Dean Brown, Town Manager, and Red Dufresne, TownEngineer, to alert them to the problem and request that samplesbe taken for volatile organics and metals. Metals shouldinclude chromium, cadmium, silver, mercury, lead, copper, zinc,selenium and nickel.

The enclosed copy of the map is in part intended for JohnAmadon and Stan Corneille to mark the location of the drumsfound and return to the Health Departmenbt for our files. Thesites of any other known waste should also be identified atthat time.

Please call if I can be of further assistance.

Sincerely,

Winslow Ladue, HydrogeologistDivision of Environmental Health

WL/lfcc: Red Dufresne

John AmadonStan CorneilleHarold SargentBen Sargent

BALL PARK WELL

POSSIBLE CONE OF DEPRESSION

"~.··4..~ '•• ~ ." I -"'!.' " ...." .-<7"

,.,'; ._~ ',- '*'.,;'..;, . ';';.': " ....,

••

Client No. 122-0388

Proj. Mgr. RED

Date flUDLOW. \'-2 VERMONT

\'i 'II

FIGURE 5-1

Dufresne-Hem,

..~ j"~".", ..,,,~("n>~NQj,ISO

A

.»

..

SCALE: 1": 416' APPROX.

STATE OF VERMONTAGENCY OF HUMAN seRVICES

March 18, 19'86

Dean BrownLudlow Town ManagerLudlow, VT 05149

DEPARTMENT OF HEALTH

60 MAIN STREET

P.O. BOX 70

BURUNGTON,VERMONT 05402

RE: Ballpark Well Hazardous Waste Investigation

Dear Mr. Brown:

This letter follows my Friday, March 7, 1986 telephoneconversation regarding hazardous waste investigations underwayby the Agency of Environmental Conservation (AEC) in theindustrial park adjacent to the demonstration well at theBallpark site.

I relayed the results of my recent discussion with StanCorneille, Investigator from AEC. Stan mentioned the following:

1. The investigation was ongoing at the TA Electric site whichis located directly uphill of the sewage treatment plantalong Pleasant Street.

2. Investigation was warranted because the Rutland Group isd~veloping this site for the Mintzer Brothers Lumber Co.for a proposed lumber yard and retail outlet. Friday,February 28, 1986, the bulldozer operator unearthed threebarrels and piled them with snow and dirt and other refuse.Monday, March 3, 1986, at the end of the workday theoperator of the bulldozer developed a rash during theworkday he changed the oil on site. It is uncertain whetherthe rash is related to an exposure to a hazardous chemical.Later in the week, Stan Corneille met on site anddiscovered one of the barrels had a label of methylenechloride.

3. TA Electric Co. was a plating company which used severalheavy metals and had ~ discharge permit to the municipalsewage treatment plant.

Enclosed is a copy of the possible cone of depression map fromthe Dufresne Henry report that shows the location of thedemonstration well and the area in which the demonstration well

may draw from. My present understanding is that this wellincludes the site of the TA Electronics.

I called Brian Quaker at the AEC to discuss the dischargepermit for TA Electric. Brian Quaker was unable to find thepermit because it had expired and the firm was no longer inbusiness but would order a copy of it from their archives.Based on his files, he learned that TA Electric was an electriccircuit board manufacturer and that like industries have wasteswhich include volatile organic chemicals and metals. Brianmentioned that trichloroethylene may be a contaminant in thiswaste stream.

I called Nick Santo of Aquatec to learn the turn around timefor an analysis for methylene chloride. He mentioned that the624 sample could be turned around in a matter of days if theyrush priority were put on it.

I called Dean Brown, Town Manager, and Red Dufresne, TownEngineer, to alert them to the problem and request that samplesbe taken for volatile organics and m~tals. Metals shouldinclude chromium, cadmium, silver, mercury, lead, copper, zinc,selenium and nickel.

The enclosed copy of the map is in part intended for JohnAmadon and Stan Corneille to mark the location of the drumsfound and return to the Health Departmenbt for our files. Thesites of any other known waste should also be identified atthat time.

Please call if I can be of further assistance.

Sincerely,

Winslow Ladue, HydrogeologistDivision of Environmental Health

WL/lfco: Red Dufresne

John AmadonStan CorneilleHarold SargentBen Sargent

· ...

SCALE: 1": 416'APpnOX. \,\FIGURE 5-1

BAll PARK WEUPOSSIBLE CONE OF DEPRESSION

Client No. ! 22-0386

Pr-oj. Mgr. RED

Date 'LUDLOW, V-2 D-IVERMONT.

.."-,,,,,,,, .... ~

..~ ~,,,,,,., .. h'V... moo'05l~1)

A

''''

",'- ... . -'. -"'" .

. ,.,..... , .....'-'INDUSTRIAL.

)"rtr'~. ~<)" .'. ·i'. '--", ~ .._. ,. ~ ", .

.~. ~ ,... -.-

SCALE: 1":::; 416' APPROX.

State of Vermont

AGENCY OF ENVIRONMENTAL CONSERVATION

Department of Fish and Wildlife

Department of Forests, Parks and RecreationDepartment of Water Resources & Environmerllal EngineeringNatural Resources Conservation CouncilState Geologist

Montpelier, Vermont 05602Department of Water Resources

andEnvironmental Engineering

MEMORANDUM

TO: Mintzer Brothers Ludlow File

FROM: Stanley Corneille

DATE: March 17, 1986

RE: Meeting with the Rutland Group

A meeting was held in Mendon at the Rutland Group, Inc. office onMarch II, 1986. The list of attendees is attached to this memo andincludes the owners of Mintzer Brothers, Inc., Aquatec, K.P.B.I.C.Insurance Agency and personnel from the A.E.C. The purpose of themeeting was to present Aquatec sampling results and to determine thefuture course for resolving. The contents of the buried tank weredetermined to be hazardous, pH 1.4 and concentrations of methylenechloride, acetone, and tetrachloroethylene at 2,000,3,200, and 1,100ppb respectively. Soil sampling in the area where David Gilman lay tochange dozer oil and where the drums were unearthed, contained levelsof methylene chloride and acetone around 100 ppb and lower. TheAquatec report is part of the file.

Mintzer Brothers has agreed to remove the contents of the tank.Aquatec will be retained to conduct further site investigationsincluding a survey to determine if more drums may be buried on theproperty and soil and groundwater monitoring around the tanks initially.If contamination is found. the investigation will expand to includeadditional soil borings and monitoring wells.

The Agency will issue a 6610a order to Mintzer Brothers toconduct the investigation.

ESC/bj 1

Regional Otfices . Barre/Essex Jct./Pittsford/N. Springfield/St. Johnsbury

, I

;,( f

,,

6/<::

, ,

-...o....-.:;....:-~-J"-,)"\

,:0,

"'.t /-\ .. -.'

" ,

\ '\

(';

; \

,'\

INITIAL SITE VISIT

AT LUDLOW DEVELOPMENT SITE

For

The Rutland Group Inc.

Route 4

Mendon, Vermont

byAquatec Inc.

75 Green Mountain DriveSouth Burlington, Vermont

March 10, 19B6

1. IN'JJJOIDCTION

In a phone conversation between Mr. Roger Bi.nkerd and Mr.

John Diego of Aquatecr with Mr. "Brad Thanas of The Rutland Group

Inc. on Wednesday, March 5 and Thursday March 6, 1986, Mr.

'rticnas explained that a heavy equdpnent operator had crawled

under his machine to change the oil at a Ludlow deve'lopnent !'>ite

and had broken out in a rash prompting sore concern over the

quality of the soil. Mr." Thomas retained Aquatec to initially

collect soil samples at five locations on site and a liquid

sample from an inground tank adjacent to the huilding. The site

is located just off Route 103 east of the center of Ludlow. The

site borders on the south side of the Black River directly across

from the Ludlow wastewater treatment plant.

Present during the sample collection visit was Mr. Bradford

Thomas and Mr. Rod Anderson of The Rutland Group; Mr. David

Gilman, heavy equipment operator; Mr. John Amanon and Mr. Stanley

Cornielle of the Wa~te Management Division of the State of

vermont and Mr••John Diego of. Aquatec ,

Mr. Thomas indicated that New England Marine Contractors had

removed several drums of. hazardous materials preceeddnq a eire in

the former electronics building.

2. SAMPLING

A liquid sample was collected in a teflon bailer fran an

inground fiberglass storage tank. The location of the tank is

depicted in Figure 1. The tank is about five feet in diameter

and has a concrete cover. Access to the liquid in the tank was

through a man-hole cover. 111e liquid level was about; five feet

below the top of the man-hole cover and about 6 inches below the

top of the fiberglass tank. There is a Seam between the con­

crete cover and the fiberglass tank. Dried sludge was noticed in

the seam between the t~ sections of the tank. There are two PVC

lines leading into the tank jUgt aoove the seam. Roth lines were

broken at the outside of the tank. The tank had been excavated

about; eight f.eet below grade.

A second liquid sample was collected fran a pit inside the

building. The location of. the pit is depicted in Figure 1.

A soil sample was collected at the approximate location

Where Mr. Gi.Iman changed the oil in his rrachine , The surf.ace was

scraped up and a composite of. the soil was collected f.or

analysis.

A fourth sample was collected in the area where Mr. Gilman"

had excavated sane buried 55 gallon drums. The soil sample was

collected in the same fashion.

In talking with Mr. Gilman, he expl.a ined that he had pushed

several drums into a large pile east of the butIdinq. There was

one drum visible in the pile labeled "Methylene Chloride" fran

Ashland Chemical Company, There was liquid frozen in the drum,

but no sample coul.d be obtained without di.aturblnq the drtm,

FUrther discussion with Mr. Gilman regarding his rash in­

dfcated that it was primarily where his body came into contact

with. the machines seat and arm rests.

3. RESULTS

Mr. Amadon of. the State of. Vermont, surveyed the area with a

portable photoionization detector, but received no positive

readings at the sample locations or at the abandon drum.

Laboratory analysis for volatile organics indicate that

concentrations of organic compounds were detected in three of the

four samples collected. Listed in Table 1 are the volatile

organic concentrations detected at each sample location.

TARLE 1

volatile Organics P,PA Method 624-2AS

(ppb)

Lab # 56389 RG-2. Oil change site

Methylene Chloride

Aoetone

75

88

Lab #: 56390 RG-4, Buried drum site

Methylene Chlor-ide 110

Acetone 45

Lab # 56391 ~Ta9Chloranethane -

Methylene Chloride 2000

Acetone 3200

Methyl Ethyl Ketone 380

Tetrachloreth~ne 1100

Ethylbenzene 150

Xylenes 960

Lab # 56392 RG-3, Pit inside building

No compounds detected

pH values measured at Aach location indicate normal soil pH

values, but a low pH value of 1.4 was measured from the 1 iqu id

in thp. underground tank.

TARLE 2

pH Values (Std. Units)

Sample

Lab No. Description Value

56389 RG-2, Oil change site 6.8

56390 RG-4, Buried drum site 7.2

56391 RG-l, Underground tank ~56392 RG-3. Pit 6.7

The results of the metals scan performed by ICP indicate the

metals in the soil are at normal background levels. The results

of the underground tank sample show significant concentrations of.

metals. Listed in Table 3 are the results of analysis.

The anion results listed in table 4 dndi.cate acids were

dumped into the tank.

4. <nICLUSlOO

The site visit on Thursday, March 6, 1986 and the rp.sults of

analysis of samples collected during the etre visit show that

many different types of chemicals were used and/or stored on the

site. The underground tank results show that solvents and acids

were dumped into the tank. Results of. soil samples containing

solvents indicate that the underground tank may be leaching or

that the drums that were excavated may be a source of contamina­

tion of organic solvents.

The complex organic and inorganic compounds detected in

the tank represents a hazardous situation. Evidence of buried

drums on site and concentrations of volatile organic solvents in

the soil represents an unknown extent of contamination.

TABLP. 3 f'\Metals Scan bv rep

mg!Kg tot,,,",,,, -r.-I:--mg!l p,f

alc~ to 1ft

ParaJ'l'eter 503A~- 561~0 50:1<11 50392---- --- -- -- ---l\llnninum 50000 4~000 300 60

Antimony <10 <10 <1 <1

Arsenic <5 <5 <5 <5

Reryllium <5 <5f <5 <5

c"limiurn .2 2 <0.1 <0.1

Chranium 10 13 ~~ <0.1

Cobalt 32 33 <0.1 <0.1

CoDper 21 1~ (300 2,Iron >20 >40 34 30

lead 7 7 3 6

Mercury <5 <5 <5 <5

Molytx1emnn <5 <5 <5 <5

Nickel 14 15 1 0.1

Selenium <5 <5 <5 <5

Silver <5 <5 <0.5 <0.5

Tin <5 <5 ( 500 9\ -

Titanium 500 600 3 <0.5

Zinc 42 41 24 2

TABLE 4

<20540

56392

!'9fl.<~\ 0.010~ 0.007

7000 cioo1500 <20

<5

Ion Chromatography Results

56390 50391

<5

50389--" !'9!l<g

0.07 0.091\

<0.5 ~<25 <25

<5 <5

wet Chemis try and

Parameter

Cyanide

Hexavalent Chromium

Sulfate

Fluoride

Chloride

+ RG- 2:. Oil Chcn\le Sile

)

~"Ao SM.....,".....86019

)

Oaquatec'M'.ENYIIlON"1ENT...L SEIlYICESSOUTH eUIlL,NGTON.Y(IlIdONT

FIGURE I.

,uo..,nco

oHon Drumed Methylene Chloride

ApproximateLoc:;otio"~

••..""

-$- RG - 4, Buried Drum Site

-( t;- .

• 'JI

(2,(if- RG-3 .en o o RG-I. Tonk

'& 55 •Lobel,

I

<,;

Porking '" Existing B'!,i1dinll

(90' x 120" .II

~C ./'

.IJ I I ' ;:'-"I

SCALE, Inr ••, ,.ac eo ,. c ...••pp - ---- ,-- ,

..

••"~

,,,~

.. //,,; . "1528"

/

/

APPENDIX

()aquatecENVIRONMENTAL SERVICES

75 Green Mountain Drive, So. BurlingtOn.vr 05401TEL.802I658·t074

ANALYTICAL REPORT

Aquatec lab No.: 56389l:l'R No.: 7030Sample Received On: 6 March 1986Sample Identification: RG-2, Soil - oil change site

volatile Organic Compounds in ug/Kg wet

acrolein 100 Uacrylonitrile 100 Ubenzene 5 Ucarbon tetrachloride 5 U"Ch"1"o=r"O"be'2;'n"ze,,n"'e::.:-.==- --i5 U1,2-dichloroethane 5 UI,l,l-trichloroethane 5 Ul,l-dichloroethane 5 U

-i'lL',"1<.;'2<--..;t"r"'i"c;'h"lo"'r"oe""t"h"'a"n"'e=,..,.-__-;5 U1,1,2,2-tetrachloroethane 5 Uchloroethane 10 U2-ch1oroethy1 vinyl ether 10 Uchloroform __-is Ul,l-dichloroethene 5 Ul,2-dichloroethene 5 U1,2-dichloropropane 5 U

cis-l,3-dichloropropene 5 Uethylbenzene 5 U

methylene chloridechloranethanebrClfOCl!nethanebraroform

dibramochloromethanetetrachloroethenetoluenetrichloroethenevinyl chlorideacetone2-butanone~Od[surfide2-hexanone4~thyl-2-pentanone

styrene _

7SC10 U10 U

5 U5 U5 u5 U5 u5 u

10 u88C

10 u5 u

10 U10 U

5 UlOU

5 u

Key to the letters used to qualif.y the results of. the analysis:

U - The compound was analyzed forrut not detected. The numberis the detection limit for theOO11jXJUnd.

NOB - Quantitation is not possibledue to the relative concentra­tion of the compound in theblank.

K - The compound was analyzed forand detected, but at a con­centration not reliably quan-tifiable. The number is thedetection 1imi t for the conpound,

C - The resul t has been correctedfor the preSence of the ccmpoundin the blank.

(}aquatecENVIRONMENTAL SERVICES

7SGreenMountain Drive, So. Burlington, vr 05401TEL.8021658-1074

ANALYTICAL REPORT

Aquatec Lab No.: 56390E:I'R No. : 7030Sample Received on: 6 March 1986Sample Identification: RG-4, SOil - buried drum site

Volatile organic COmpounds in ug/Kg wet (ppb)

acrolein 100 U methylene chloride HOCacrylonitrile 100 U chloranethane 10 Ubenzene 5 U bromanethane 10 Ucarbon tetrachloride 5 U brcrroform 5 Uchlorobenzene 5 U bromodichloramethane 5 U1,2-dichloroethane 5 U dibromochloromethane 5 U1/1,I-trichloroethane 5 U tetrachloroethene 5 U1,1-dichloroethane 5 U toluene 5 U1,1,2-trichloroethane 5 U trichloroethene 5 U1,1,2,2-tetrachloroethane 5 U vinyl chloride 10 Uchloroethane 10 U acetone 45C2-chloroethyl vinyl ether 10 U 2-butanone 10 Uchloroform 5 U carbon disulfide 5 Ul,l-dichlor.oethene 5 U 2-hexanone 10 Ul,2-dichloroethene 5 U ~thyl-2-pentanone 10 UJ,2-dichloropropane 5 U styrene 5 Utrans-l,3-dichloropropene 5 U vinyl acetate 10 Ucis-l,3-dichloropropene 5 U total xylenes 5 Uethylbenzene 5 U

Key to the letters used to qualify the results of. the analysis:

U - The compound was analyzed forbut not detected. The number'is the detection limit for thecanpound.

NOB - Quantitation is not possibledue to the relative concentra­tion of the compound in theblank.

K - The compound was analyzed forand detected, but at a con­centration not reliably quan­tifiable. The number is thedetection limit for the compound.

C - The result has been correctedfor the presence of the compoundin the blank.

()aquatecENVIRONMENTAL SERVICES

75 Gr«n Mounmin Drive. So. Burlington, VT 05401TEL 8021658_1074

AN ALYTICAL. REI,>ORT

Aquatec Lab No.: 56392E:l'R No.: 7030Sample Received On: 6 March 1986Sample Identif.ication: RG-3, Pit - inside

Volatile organic C'..ompounds in ug/1

NDB10 U10 U

5 U5 U5 U5 U5 U5 U

lOUNOB

10 U5 U

10 U10 u

5 U10 U

5 U

2-butanone

44ffiethyl~2-pentanone

styrene -=-------,-ivinyl acet"'a"'t"e:,- -=-;;-.;;total xylene"'s"- "--"

2-hexanone

trichloroethene

brancrn.ethane

tetrachloroethene

brcmJform,.-,-,.,--~bromodichloromethanedibranochloranethane"-------c

vinyl chlorideacetone

toluene

carbon disulfide

methylene chloridechloranethane

5 U

5 U

5 lJ

5 U

5 U

5 U5 u

5 U5 U

10 U10 U

100 U100 U

1,2-dichloropropane1,2-dichloroethene

cis-l,3-dichloropropene

1,1,2-trichloroethane1,1,2,2-tetra~c~h~1~o~r~oe~thLa~n~e~--~~

l,l-dichloroethene

~lbenzene

1,1,I-trichloroethanel,l-dichloroethane

acrylonitrile

chloroform

chloroethane2-chloroethyl vinyl ether

acrolein

benzene(;irbon tetrachloridechlorohenzene1,2-dichloroethane

Key to the letters used to qualify the results of the analysis:

U - The compound was analyzed forbut not detected. The mmoeris the detection lLmit for thecanpound.

NDB - Ouantitation is not possibledue to the relative concentra­tion of the compound in theblank.

K - The compound was analyzed forand detected, rut at a con­centration not reliably quan­tifiable. The number is thedetection limit for the compound.

C - The result has been correctedfor the presence of the compoundin the blank.

·()aquatecENVIRONMENTAL SERVICES

75 Green Mounta;n Drive, So. Burlington. VT 05401TEL. 8021658-1074

ANALYTICAL Rim;ORT

Aquatec Lab No.: 56391EITR No.: 7030Sample Received On: 6 March ]986sampl.e Identification: RG-l, Tank

Volatile Organic Compounds in ug/l

acrolein 1000 U methylene chloride 2000C~cry Ionitrile 1000 U chloromethane lOOKbenzene 50 U bromanethane- 100 Ucarbon tetrachloride 50 U brcrnoform 50 Uchlorobenzene 50 U branodichloranethane 50 U1,2-dichloroethane 50 U dibrornochloromethane 50 Ulrl,l-trichloroethane 50 U tetrachloroethene 1100~l-dichloroethane 50 U toluene 50 UlrI,2-trichloroethane 50 U trichloroethene 50 U1, 1, 2, 2-tetrachloroethane 50 U vinyl chloride 100 Uchloroethane 100 U acetone 3200C2-chloroethyl vinyl ether 100 U 2-butanone 380chloroform 50 U carbon disulfide 50 U1, i-eichloroethene 50 U i-hexanone 100 U1,2-dichloroethene 50 U 4~thyl-2-pentanone 100 Ul,2-dich~~opropane 50 U styrene 50 Utrans-l,3-dichloropr~ne 50 U vinyl acetate 100 Ucis-l,3-dichloropropene 50 U total xylenes 960ethylbenzene 150

sample was diluted 10 fold for analysis.•

Key to the letters used to qualify the results of the analysis:

U - The ccnpound was analyzed forbut not detected. The numberis the detect ion 1imi t for thecOfll{;:Ound.

NOB - Quantitation is not possibledue to the relative concentra­tion of the canpound in theblank.

K - The compound was analyzed forand detected, but at a con­centration not reliably quan­tif.iable. 1118 number is thedetection limit for the compound,

C - The result has been correctedfor the presence of the compoundin the blank.

()aquatecENVIRONMENTAL SERVICES

75 GreenMountain Drive, So. Budins:«>n, VT05401TEL. 8021658-1074

ANALYTICAL REPORT

Aquatec Lab No.: 56391ETR No.: 7030Sample Receiveti On: 6 March 1986Sample Identification: RG-l, Tank

Pesticides and/or PCB's in ug/l

aldrin 1 U a-BHe 1 Udieldrin 1 U lrBHC 1 Uchlordane 1 U d-llHC 1 U4,4 1-DDr 1 U g-BHC (lindane) 1 U4,4 1-OOE 1 u methoxychlor 20 U4,4 1-ODO 1 u toxaphene 20 Ua-enc1osulEan 1 U PCB-1242 20 Ub-endosulfan 1 U PCB-1254 20 uendosulfan sulfate 1 U PCB-1221 20 Uendrin 1 U PCB-1232 20 uendr-i.n aldehyde 1 U PCB-1248 20 uendrin ketone 1 U PCB-1260 20 uheptachlor 1 U PcB-1016 20 uheptachlor ep?xide 1 U

Key to the letters used to.qualify the results of the analysis:

U - The compound was analyzed forbut not detected. The numberis the detection lLmit for thecanpound.

NOB - Quantitation is not possibledue to the relative concentra­tion of the compound in theblank.

C - The result has been correctedfor the presence of the oam­pound in the blan1<.

()aquatecENVIRONMENTAL SERVICES

75 Gr«n Mountain DroY<'. So. Burlington, VT05401TEL. 8OU658-IOH

AN ALYTICAL REP~0RT.The Rutlarrl Group

Date: 3 10 86Project No: 85019ETR No: 7030Sample(s) Received On: 3/6/86Page 2 of 3

Standard analyses were performed in accordance with Methods for Analysis of Water and Wastes, EPA-600/4/79-020,Test Methods for Evaluating Solid Waste, SW~846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mgll unless otherwise noted.

Parameter 5K,Ql SK,Q2The FollCMing Fesultare in rrq/l

Aluminum 300 60Antim::my <1 <1Arsenic <5 <5Beryllium <5 <5Cadmium <0.1 <0.1Chrcmium 0.5 <0.1CObalt <0.1 <0.1COpper 300 2Iron 34 30Lead 3 6I-Ercury <5 <5l"blyb:lenurn <5 <5Nickel 1 0.1Selenium <5 <5Silver <0.5 <0.5Tin 500 9Titanium 3 <0.5

meLab No. , Sample Description

5639l. Water sample collected 3/6/86 from tank No. l.

56392. Water sample collected 3/6/86 fran pit inside.

Suhmi".d By rt2 (J1(J.f)m !l1kIZu ~Aqua tee Inc.

The Rutland Group

()aquatecENVIRONMENTAL SERVICES

75 Green Mountain Drive, 50. Burlington, VT05401TEL. 8021658-1074

Date: 3/10/86Project No: 85019ETR No: 7030

Sample(s) Received On: 3/6/86Page 1 of 3

Standard analyses weN performed in accordance with Methods for Analysis of Water and W"",tes, EPA-600j4!79-020,Test Methods for Evaluating Solid Waste, SW-846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mg/l unless otherwise noted.

Parameter 5<'00 5<'00The Following Fesultsare in rrg/Kg

Altuninum 50,000 49,000AntiIrony <10 <10Arsenic <5 <5Beryllium <5 <5Cadmium 2 2Chromium 10 13Cobalt 32 33Copper 21 19Iron >20 >40Lead 7 7Mercury <5 <5M:llylxlenum <5 <5Nickel 14 15selenium <5 <5Silver <5 <5Tin <5 <5Titanium 500 600Zmc 4:/ 4.Lab No. , Sample Description

56389. SOil sample oollected 3/6/86 fran oil cbange site.

56390. SOil sample oollected 3/6/86 from buried drum area.

Aquatcc Inc.

()aquatecENVIRONMENTAL SERVICES

75 GreenMountain Dnve,So. Burlington, VT 05401TEl... 8021658-1074

AN AL YTICAL' RE"P'ORT.Date: 3/10/86

The Rutland Group Project No: B5019ETRNo: 7030Sample(a) Received On: 3/6/86Page 3 of 3

Standard analyses were perCormed in accordance with Methods for Analysis of Water and Wastes, EPA-600/4!79-020,Test Methods for Evaluating Solid WlllIte, SW_846, or Standard Methods for the Examination of Water and Wastewater.

All results are in mg/l unless otherwise noted.

Parameter 56389 56390 56391 56392

The Following Result,;are in ITB/Kg Unless 1- "tedChloride <5 <5Cyanide 0.07 0.09Fluoride <5 <5Hexavalent Chromium <0.5 0.62pH (std. units) 6.8 7.2Sulfate <25 <25

The Following jesul.taare in nq/l \IDless N: !ted

Chloride 540 <20Cyanide <0.10 0.010Fluoride 1500 <20Hexavalent Chrc:roium. o.n 0.007pH (std. units) 1.4 6.7Sulfate 7000 <100

Lab No. • Sample Description

56389. Soil sample collected 3/6/86 frcm oil change site.

56390. Soil sample collected 3/6/86 from buried drum area.

56391. Water sarrple collected 3/6/86 fran tank No. 1

56392. Water sample collected 3/6/86 fran pit inside.

Submitted Dy: k!/~vn (l~(/j1?1JAqua tee Inc.

·

MEMORANDUM

TO: Mintzer Bros. Lumber - LUdlow file, Environmental Release

FROM: stan Corneille, Environmental Release Management

RE: Drums during site Work in Ludlow

DATE: March 7, 1986

The Technical services Group received notice 3/5/86 that anindividual, Dave Gilman, who operates equipment for Dave WisellExcavation, developed a body rash after uncovering 2 to 3 55-gal­lon drums on a site in Ludlow. wisell Excavation is a subcon­tractor to the Rutland Group who is the contractor for MintzerBros., owner of the property.

Mr. Gilman reported that he uncovered some drums Friday2/28/86 while bulldozing snow in preparation for stumping andsite grading. He pushed these drums into a pile with stumps,cobbles, snow, and soil. He returned to work on Monday 3/3/86and had a headache most of the day. He spent some time on theground greasing and changing oil in his machine. That night hedeveloped a rash with blisters on his back, sides, underside offorearms, and back of legs. Reported to a supervisor with theRutland Group who told him to go to the hospital. He went to theemergency room at Rutland Hospital 3/4/86 and was examined byDoctor Hartman, who gave him cream and pills and made an appoint­ment with a specialist, Doctor McIntyre.

Site work has stopped until an investigation into the causeof Mr. Gilman's problems can be determined. Mr. Gilman saidsomething was in the drums and he thinks some clear liquid mayhave been seeping out. He also reported that he heard someworkers from the Rutland Group complain about headaches, dizzi­ness and upset stomach from working in the building.

The Rutland Group is renovating a building and will con­struct additional buildings on the site for a retail outlet storefor Mintzer Bros. Lumber who owns the site. The originalbuilding housed T A Electronics, an electroplating industry. T Aplated copper, nickel, zinc, tin, and some mercury, presumably onelectronic parts. They used chemicals including acids and sol­vents? Discharge of wastewater after precipitation of metals and

pH adjustment was to the Ludlow Sewage Treatment Plant. The firmwent bankrupt after approximately one year in 1980 - 81. Subse­quently a fire gutted the building with the inventory inside.The building reverted to the bank and sat idle and boarded untilabout 1984 - 85 when the property changed hands. New EnglandMarine Contractors was hired by the bank to clean the building ofall chemicals. This job was successfully completed beforerenovation commenced.

John Amadon and the writer were on the site 3/6/86 to con­duct a preliminary investigation. The rutland Group had con­tracted the services of Aquatec to conduct some sampling. A­quatec was on-site when we arrived. A singe drum was exposed onthe pile of stumps, soil, rocks, etc. The drum was empty, andcollapsed and had a methylene chloride label on it. A tank(fiberglass with concrete tiles and manhole covering it) was un­covered off of the northeast corner of the building. It was fullof liquid and may represent a pump station where treatedwastewater from T A was pumped to the sewer treatment plant.

HNU probing inside and outside the building showed noreadings anywhere. Dave Gilman dropped by after his visit to thespecialist in Rutland. He showed us where he discovered thedrums and where he laid on the ground to change dozer oil. Thedrums were not in the area where he changed the oil. Samples(soil) were collected by Aquatec in the area where drums werediscovered. Ground surface was scratched 6 - 8 inches with abackhoe to obtain a sample. Aquatec will provide fast turnaround for these samples.

The Rutland Group will handle the investigation for theowner. Brad Thomas, Project Manager, and Rod Andrews, JobSuperintendent, were informed that a site monitoring and cleanupplan may have to be developed which would delay project comple­tion. Aquatec test reSUlts are first cut and will determine ourcourse of action in the future.

Winslow LaDue of the Health Department called 3/7/86 fcr abriefing on the problem. He informed me that a municipal well,located across the road (Route 103) from the sewer plant waswithin the zone of influence of the site. The well is rated at354 GPM and is used intermittently, i.e., when popUlation shiftsfrom 2,700 to 24,000 people. The well was not approved by theDepartment of Health. They advised the Town not to construct thewell. The Health Department will sample for VOC's today.

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Dep""""'''l oj \\I"t"1 nnw",,,,"Env"",,,,,,,r,!,,1 BoardDivision of EI,vi,oo''''"nl,,1 f:n'li,werio9Oivi~io" of Emllfonmenwl t'uuecuonNatural Besources Conservanon Coun~il

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Mr. Nicholas DeGiglioTA Electronics Company,49 Pearl S't ree t 'Springfield, VT 05156

Gentlemen:

Inc.

RE: Discharge to NunLc i pa L Sewer System

[nclosed is your copy of tIle above r£'ferencedpermit which llBS been signed by tIle Secretary of theAgency of EnVironmental Conservation.

!'lease read tIle entire permit C1lYcflll!y :ll}l]familiarize yourself with all ies terms and condiciuns.Your attention is particularly directed to those conditionsWllich may require written responses by ccr(~in dates. Pleasecheck to see tllat all pages are included in your permit.

If you have any questions concerning YOllr"perlnit,please contact us at once.

Very truly yours,

!J/I~lll;;-(LL.~L~Willard II. FarnhamEnvironmental EngineerPermits Section

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PERMIT FOR DISCHMtGE TO MUNICIPAL SEWER SYSTEM

Permit No. J ..0360

File No. 14-10-015

In compliance with the provisions of the Vermont Water Pollution ControlAct, as amended, (10 V.S.A., Chapter 47 § 1251 et.·~j the "Act:'),

T A Electronics Company, Inc.

is authorized to discharge from a facility located at~t<d /'OC<)

..3f: :F.Lgfichi, Vermont

to the municipal sewe r system of

Lud Low Municipal Sewage Treatment Plant

in accordance with discharge limitations, monitoring requirements and otherconditions set forth in Parts I, II, and III hereof.

This permit shall become effective on June 1, 1980

This permit'and the authorization to discharge shall expire at midnight,

Hay 31, 1985

1,Signed this ~ day of +!

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t. .,;7/'/7~/II&. '/.-A;fLLL~

CA~c~t~.~n"g""C::'-'o rruuis s i one rD4Partment of Water Resources

Form WR-80

A. DISC;-;.ARGE: LIEITA! ION~ AND 1'10NITORING REQU mS2'1E:'\T j

.. ~

During ehc period beginningfollowing discharges (seri81

June 1,nu:nbers

1980shown) are

and .i.astinp;authori.zed:

t h r o uuh Hay 31, 1985 the

.",-

E1ectra1ess Plating Line Rinse

(:Heasure~ent Sample

Da ily Avg Daily Ha x Da ily Avg Daily Ha x Frequency Type

Flow_m3/Day (MGD) (.00035) (.0005 ) Continuous Daily Hax , & Avg.Lead 0.1 mg!l 1 x Monthly CompositeCopper 0.1 mg!l 1 x Monthly CompositeNickel 0.5 rug!l 1 x Monthly CompositeTin 0.1 rug!l 1 x Bi-annually CompositeNang an esc 0.1 mg!l 1 x Bi-annually CompositeHe r cu ry No detectable concentrations above background levels* 1 x Nonthly Composite

Samples taken in compliance with the monitoring requirements ~pecified above shall be taken

at the fallo~inr- loca~ion(~): At Sampling pit prior to discharge into Municipal System. *Raw Water

Supply before addition of process chemicals and efflue~t samples shall be tested for Mercurymonthly. This requirement may be deleted after 6 months at the discression of the department.

Reca rcnlat tonby chci<1ical

Re qu t r eccntsHan i r o r i ng

in the effluent.the W2S t e stream

(Sp e c Lf v )Other Unit::;LimitationsDischarge

(lbs/day)

s t anda r d units nor greater than 8.5 standard units

kg/day

Such d i s c he r g e s shall be limit_cd and non i cc r ed by the p e r-m i t t c e as s p ec i f Le d below:

Dischar~e Characteristics

The pH shall not be less than 6and shall be monitored

~oee: The regenerant for the ion-exchange unit shall not be disposed ofa f the r e gcneran t is accep table provided regene r3"J t receives t reatmen t inprecipitation, settling and ion-exchange.

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w,owo-:o

..PART I

Page 2 of 10

permi t No. 3-0360

I. ~;CllEllULl:. OF CtHtPLIANCE

1. TIl£> p r i mi ttee sha l.l achieve complaince with the effluent limitationss pcc Lf ted for discharges in accordance with the following echedul e-

An effluent sampling pit and flow meter shall be installedprio~to commencement of discharge.

2. No later t han 14 c c Lendar days following a date identified in theabove schedule of compliance, the permitt~e shall submit either areport of progress or, in the case of specific actions beingrequired by identified dates, a written notice of compliance ornoncompliance. In the latter case, ,the notice shall include' thecause of noncompliance, any remedial actions taken, and theprobability of meeting the next scheduled requirement.

'.,;

PART I

Page 3 of 10

Permit No. 3~0360

C. l1ONITOll.ING AND REPORTING

1. ~eprescntative Sampling

Sampl es and measurements taken as required herein shall berepresentative of the volume and nature of the monitoreddischarge.

1. Reporting

}10nitoring results shall be reported on accepteble forms submittedto the following address:

State of VermontAgency of Environmental Cons ervatronDepartment of Water ResourcesState Office BuildingMontpelier, Vermont 05602

'Itic s ..- reports shall be submitted on the 10th day of the month fo,110\~ing thesampling perio~..!..

The initial report is due on ~J~,~,1~y~1~O~,C_l~9~8~00_ ~ ___

3. Def t nt t t one

Implementation Schedule - An abatement program consisting of:

a. A plan of intended design, construction, and operation ofnew or modified facilities to pretreat the discharge; and

b. A timetable setting forth the dates by which all discharge'smust be in compliance with the limitations of this permit.The schedule shall include (if appropriate) interim and finaldates to accomplish:

(1) Completion of preliminary plans and engineering report(2) Completion of final plans(3) Contract award(4) Commencement of conatruction(5) Ccmp l e t'Lon of construction end conmencement of operation(6) Attainment of ,operational level

Composite Sample - A sample consisting of a minimum of grabsamples collected at regular intervals over 8 normal operating dayand combined proportional to flow, or a sample continuouslycollected proportional to flow over 8 normsl operating day.

. '... '.'"* " , ..

PART I

Page 4 of 10

Permit No. 3-0360

(;'rah Sample ~ An i nd Lv Iduu I snmp le co l l ec r ed tn a period of Ics ethan 1~ minutes.

4. Te~t Procedures

Test procedures for the analysis of pollutants shall conform toregulations published pureusnt to Section 304 (g) .of the Federal Waterpollution Control Act, under which such procedures may be required.Guidelines establishing these test procedures have been publishedin the Federal Register as Vol. 38 No. 199, Part II, dated October16, 1973,

'). Recording of Results

For each measurement or sample taken pursuant to the requirements01 this permit, the permittee shall record the following inforn~tion:

· '.

,PART I

Page 5 of 10

Permit No. 3-0360

,1, The exact place, date, and time of sampling;

b. 'Iue dates the analyses were performed;

c. The person(s) who performed the analyses;

d. The analytical techniques or methods used;

e. The results of all required analyses; and,

f. Weather conditions, plant operating condition, and any unusualor abnormal condition ahall also be noted.

6. Additional Monitoring by Permittee

1£ the permittee monitors any pollutant at the location(s) designatedherein more frequently than required by thia permit, using approvedanalytical methods as specified above, the results of such monitoringshall be included in the monitoring reports outlined above. Suchincreased frequency shall also be indicated.

7. Records Retention

All records and information resulting from the monitoring activitiesr eq uLred by this permit including all records of analyses performedand calibration and maintenance of instrumentation and recordingsfrom continuous nmnitoring instrumentation shall be retained for aminimum of three (3) years, or longer if requested by the Secretary.

•

PART II

page 6 of 10

Permit No. 3-0360

l. Change in Discharge

All discharges authorized herein shall be consistent with the t e rmsnod conditions of this permit. The discharge of any pollutanti dent i f Led in this permit more frequently than or at a level inexcess of that authorized shall constitute a v Lol a t Ion of the permit.Any anticipated facility expansion, production increar-es, or processmodifications which will result in new, different, or increaseddischarges of pollutants must be reported by submiaoions of a newpermit application or, if such changes will not violate the dischargelimitations specified in this permit. by notice to the permit issuinge.ut ho r t t y of such changes. Following such notice, the pe rmt t may bemod i f i ed to specify and limit any pollutants not previously limited •

.!. Ncuc ompLt ance Notification

If, for any r c a son , the permittee does not comply with or will beunable to comply with any daily maximum limitation specified in thispe rm i t , the permittee shall provide the Secretary with the followinginformation, in writing, within five (5) days of becoming aware ofscc h condition:

u . A description of the discharge and cause of noncompliance; and

h. Tbe period of noncompliance, including exact dateS and times;or, if not· corrected, the anticipated time the noncomplianceis expected to continue, and steps being t~ken to reducr-,eliminate and prevent recurrence of the noncomplying discharge.

'\. facilities Ope r a t Ion

The permittee shall at all times Uk~intaill. in good working order andoperate as efficiently as pOSSible all pretreatment or controlfacilities or systems installed or used by the permittee to achievecompliance with the t e rms and conditions of this permit.

~. Adverse Impact

The permittee Shall take all reasonable steps to minimize anyadverse impact to the municipal treatment f aci Lf t y end/or t.onaVigable waters resulting from noncompliance with any limitationsspecified in thiS permit, including such accelerated or ~dditional

monitoring as necessary to determine the nature and impact of thenoncomplying discharge.

,

'A'-"

PART II

Page 7 of 10

Permit No, 3-0360

') lIypatis LnK

Any diversion [rom or bypass of pretreatment facilities necessary tomaintain compliance with the termS and conditions of thia permit isprohibited except where unavoidable to prevent loss of Ufe ors.eve r e property damage , The permt t t'ee ehe l I p.romptly notify the~ecretary in writin~ of each such diversion or bypass.

6. R~moved SubstanceH

Solids, sludges, filter backwash, or other pollutants removed in thecourse of pretreatment or control of wastewaters shall be disposedof (1) in a manner such as to prevent any pollutant from suchmar er La l s from entering navigable waters, and (2) in a manner andlocation acceptable to the Agency.

7. Powe r Failures

In order to maintain compliance with the d i echc rg.a l:l.mitations andprohibitions of thiS permit, the permittee ahall either:

a. In accordance with the Schedule of Compliance contained inPart I,. provide an alternative power eourc e sufficient tooperate the pretreatment facilities;

or, if Such a l t e.rna t Ive power source is not in existence, and, nodate for its implementation appears in part I,

b. Halt, .red uc e or otherwise cont r o I production endyo r alldischarges upon the reduction, 10s8, or Ea I l ure of theprimary source of .pover to the pretreatment facilities.

E. RESPONS IBILITIES

1. Right of Entry

The permittee shall allow the head of the State 'later pollutioncontrol agency and/or his authorized r ep resentat tves , upon thepresentation of credentials:

a. To enter upon thepermittee's'premises vhere a discharge islocated or in which any records are required to be kept underthe termS and conditiouB of this permit; and

b. At reasonable times to have access to and copy any recordsrequired to be kept under the terms and conditions of thispermit; to inBp~ct any monitoring equipment or monitoring methodrequired in this permit; and to sample any discharge ofpollutants.

Page

, .

PART 11

8 of 10

Permit No. 3-0360

2. Transfer of Ownership or Control

In th~ event of any change in control or ownership of facilities fromwhich the autho r i z e d discharges emanate, the permittee shall notifythe succeeding owner or controller of the existence of this purmf.tby letter, a copy of which shall be forwarded to the Secretary.

J. Avail~bility of Reports

Except for data determined to be confidential under Section 1259 (c)of the Act, all reports prepared in accordance with the terms ofthis permit shall be available for public inspection at the officesof the State wat e r pollution control agency. As r equt r ed by theAct, discharge data shall not be considered confidential. Knowinglymaking any false statement on any such report may result in theimposition of criminal penalties 8S provided for in Section 1275 (b)of the Act.

4. Permit Modification

After noti<::e and opportunity for a hearing) this permit may hemodified, suspended, or revoked in whole or in part during its termfor cause including, but not limited to, the followine:

8, Violation of any terms or conditions of this pe rmt t ;

b. Obtaining -tb t s permit by misrepresentation. or failure todisclose fully all relevant facts; or

c. A change in any condition that requires eLther a t empor s ry orpermanent reduction or elimination of the authorized discharge.

5. Tox i c pollutants

Notwithstanding Part II, B-4 above, if a toxic effluent standard orprohibition (including any schedule of compliance specified in sucheffluent standard ortprohtb Lt Lon) is established under SectLon 307 (8)of the Federal Water Pollution Control Act for 8 toxic pollutantwhich is present in the discharge and such standard or prohibitionis more stringent than any limitation for such pollutant in thispermit, this permit shall be revised or modified in accordance withthe toxic effluent standard or prohibition and the permittee sonotified.

PART II

Page 9 of 10

Permit No, 3-0360

(" Civil and Crtrnt na l Liability

Exccp t ns provided in penni t coud Lt Ions on "Bypassing" (Part II,A4S) and "Power Failures" (Part II, A-7), nothing in this permitshall be tcons t rued to relieve the permittee from civil or criminalpenalties for noncompliance.

7. Uil and Hazardous Substance Liability

Not h i n g in this permit shall be construed to preclude the institutionof any legal ac t i on or relieve the p ermi t r e e from any responsibilities,liabilities, or penalties to which the permittee is or may be subjectunder Section 1281 of the Act.

8. nt a t e and Local La... ." Regulations. Ordinances, etc.

Nothing in this per nit shall be construed to preclude the institutionof any legal action or relieve the permittee f rom any r espous Lbt Lt r t ee ,liabilities, or penalties established pursuant to any applicableState of Local IRw or regulation. etc., under authority preserved bySection 510 of the Federal Water Po11utionControl Act.

rJ. Property Rights

Issuance of tht s permit does not convey any property. rights' ineither real or personal property. or any exclusive privileges, nordoes it authorize any injury to private property or any invasionof personal rights •. nor any infringement of Federal, State or locall avs , or regulations.

10. Severability

The prov Ls Lons of this permit are severable, and if any prov i s tonof this permit, or the application of any provision of this permitto any- circumstance, ~s held invalid, the application of eucfprovision to other circumstances. llnd the remainder of thiS permit,shall not be affected thereby.

11. Authority

This permit is issued under authority of Section 1259 of the Actwhich requires a permit for discharge into a publicly owned treatment

, .-PART II

Page 10 o[ 10

Permit N-). 3-0360

vc rks ,my W,lS('" which interferes with, pH:>S'~S t hro ugb withoutr r ca tucnt , o r is otherwise incompatible with such works or wouldhave a substantial adverse effect on such works,

PART III

OTHER ltEQU IREMENTS