4+1 SDMS DocID 553187

REMOVAL PROGRAM PRELIMINARY ASSESSMENT

SITE INVESTIGATION FOR

ATLAS TACK FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Emergency Planning and Response Branch

60 Westview Street Lexington MA 02173

CONTRACT NO 68-WO-0036

TAT-01-N-01005

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

I Preliminary AssessmentSite Investigation Forms

II Attachments

Appendix A - Site Location Map (Figure 1)

Appendix B - Site Diagram (Figure 2)

Appendix C - Health and Safety Plan

Appendix D - Site Sampling QAQC Plan

Appendix E - Chain of Custody Record

Appendix F - Photodocumentation Log

St EPA REGION I 1 OF 3 REMOVAL PRELIMINARY ASSESSMENT

SITE NAME AND LOCATION SITE NAME fl^fl^ CLC K

STREETROUTE NO OR LOCATION IDENTIFIER lt g g gt J g O ^ V f ^ ^ F c L i r h f t lrgt

COUNTY fcriZ+ol STATE yY)A ^ATTACHED USGS MAP OF LOCATION

SITE STATUS I ^NPL bull NON-NPL Q RCRA Q TSCA bull ACTIVE Q ABANDON

bull OTHER

SITE ID C lt-f

REFERRAL bull CITIZEN bull CITYTOWN bull STATE bull PREREMEDIAL bull RCRA

NAME OF REFERRING PARTY J O ~ P S

ADDRESS PHONE ( )

CONTACTS IDENTIFIED

A h f o m ) d P e r r y - S Y ^ Cnramp^akp f PHONE ( )

B 3~- Ann f g - u j ^ V C ^ A L - fMalt^ l a c K lt6y PHONE (kz-oafc^-VS

c^aMJa P f ^ innmorvs - E P f t - l o m h fTlA-SP PHONE (bt7gtpoundamp3 - 5 ^ ^ Sec Aon Cjiiepound

D PHONE L

SOURCE OF INFORMATION

bull VERBAL

ffi RFPDBT Preliminary ^Sve Qssessnierti- fienor^ (Jv^henTl97^

bull OTHER

POTENTIAL RESPONSIBLE PARTIES OWNER ADDRESS

PHONE ( ) A) m

OPERATOR X - A ^ g l O fl^e ^^ p t e ^ SDRESS

PHONE (tof) V E ^ 1

SOURCE fig^fe

REMOVAL PROGRAM PRELIMINARY ASSESSMENT

SITE INVESTIGATION FOR

ATLAS TACK FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Emergency Planning and Response Branch

60 Westview Street Lexington MA 02173

CONTRACT NO 68-WO-0036

TAT-01-N-01005

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

I Preliminary AssessmentSite Investigation Forms

II Attachments

Appendix A - Site Location Map (Figure 1)

Appendix B - Site Diagram (Figure 2)

Appendix C - Health and Safety Plan

Appendix D - Site Sampling QAQC Plan

Appendix E - Chain of Custody Record

Appendix F - Photodocumentation Log

St EPA REGION I 1 OF 3 REMOVAL PRELIMINARY ASSESSMENT

SITE NAME AND LOCATION SITE NAME fl^fl^ CLC K

STREETROUTE NO OR LOCATION IDENTIFIER lt g g gt J g O ^ V f ^ ^ F c L i r h f t lrgt

COUNTY fcriZ+ol STATE yY)A ^ATTACHED USGS MAP OF LOCATION

SITE STATUS I ^NPL bull NON-NPL Q RCRA Q TSCA bull ACTIVE Q ABANDON

bull OTHER

SITE ID C lt-f

REFERRAL bull CITIZEN bull CITYTOWN bull STATE bull PREREMEDIAL bull RCRA

NAME OF REFERRING PARTY J O ~ P S

ADDRESS PHONE ( )

CONTACTS IDENTIFIED

A h f o m ) d P e r r y - S Y ^ Cnramp^akp f PHONE ( )

B 3~- Ann f g - u j ^ V C ^ A L - fMalt^ l a c K lt6y PHONE (kz-oafc^-VS

c^aMJa P f ^ innmorvs - E P f t - l o m h fTlA-SP PHONE (bt7gtpoundamp3 - 5 ^ ^ Sec Aon Cjiiepound

D PHONE L

SOURCE OF INFORMATION

bull VERBAL

ffi RFPDBT Preliminary ^Sve Qssessnierti- fienor^ (Jv^henTl97^

bull OTHER

POTENTIAL RESPONSIBLE PARTIES OWNER ADDRESS

PHONE ( ) A) m

OPERATOR X - A ^ g l O fl^e ^^ p t e ^ SDRESS

PHONE (tof) V E ^ 1

SOURCE fig^fe

TABLE OF CONTENTS

I Preliminary AssessmentSite Investigation Forms

II Attachments

Appendix A - Site Location Map (Figure 1)

Appendix B - Site Diagram (Figure 2)

Appendix C - Health and Safety Plan

Appendix D - Site Sampling QAQC Plan

Appendix E - Chain of Custody Record

Appendix F - Photodocumentation Log

St EPA REGION I 1 OF 3 REMOVAL PRELIMINARY ASSESSMENT

SITE NAME AND LOCATION SITE NAME fl^fl^ CLC K

STREETROUTE NO OR LOCATION IDENTIFIER lt g g gt J g O ^ V f ^ ^ F c L i r h f t lrgt

COUNTY fcriZ+ol STATE yY)A ^ATTACHED USGS MAP OF LOCATION

SITE STATUS I ^NPL bull NON-NPL Q RCRA Q TSCA bull ACTIVE Q ABANDON

bull OTHER

SITE ID C lt-f

REFERRAL bull CITIZEN bull CITYTOWN bull STATE bull PREREMEDIAL bull RCRA

NAME OF REFERRING PARTY J O ~ P S

ADDRESS PHONE ( )

CONTACTS IDENTIFIED

A h f o m ) d P e r r y - S Y ^ Cnramp^akp f PHONE ( )

B 3~- Ann f g - u j ^ V C ^ A L - fMalt^ l a c K lt6y PHONE (kz-oafc^-VS

c^aMJa P f ^ innmorvs - E P f t - l o m h fTlA-SP PHONE (bt7gtpoundamp3 - 5 ^ ^ Sec Aon Cjiiepound

D PHONE L

SOURCE OF INFORMATION

bull VERBAL

ffi RFPDBT Preliminary ^Sve Qssessnierti- fienor^ (Jv^henTl97^

bull OTHER

POTENTIAL RESPONSIBLE PARTIES OWNER ADDRESS

PHONE ( ) A) m

OPERATOR X - A ^ g l O fl^e ^^ p t e ^ SDRESS

PHONE (tof) V E ^ 1

SOURCE fig^fe

St EPA REGION I 1 OF 3 REMOVAL PRELIMINARY ASSESSMENT

SITE NAME AND LOCATION SITE NAME fl^fl^ CLC K

STREETROUTE NO OR LOCATION IDENTIFIER lt g g gt J g O ^ V f ^ ^ F c L i r h f t lrgt

COUNTY fcriZ+ol STATE yY)A ^ATTACHED USGS MAP OF LOCATION

SITE STATUS I ^NPL bull NON-NPL Q RCRA Q TSCA bull ACTIVE Q ABANDON

bull OTHER

SITE ID C lt-f

REFERRAL bull CITIZEN bull CITYTOWN bull STATE bull PREREMEDIAL bull RCRA

NAME OF REFERRING PARTY J O ~ P S

ADDRESS PHONE ( )

CONTACTS IDENTIFIED

A h f o m ) d P e r r y - S Y ^ Cnramp^akp f PHONE ( )

B 3~- Ann f g - u j ^ V C ^ A L - fMalt^ l a c K lt6y PHONE (kz-oafc^-VS

c^aMJa P f ^ innmorvs - E P f t - l o m h fTlA-SP PHONE (bt7gtpoundamp3 - 5 ^ ^ Sec Aon Cjiiepound

D PHONE L

SOURCE OF INFORMATION

bull VERBAL

ffi RFPDBT Preliminary ^Sve Qssessnierti- fienor^ (Jv^henTl97^

bull OTHER

POTENTIAL RESPONSIBLE PARTIES OWNER ADDRESS

PHONE ( ) A) m

OPERATOR X - A ^ g l O fl^e ^^ p t e ^ SDRESS

PHONE (tof) V E ^ 1

SOURCE fig^fe

EPA REGION I 2 OF 3 REMOVAL PRELIMINARY ASSESSMENT

SITE ACCESS DATE

^ OBTAINED bull VERBAL AUTHORIZING PERSON Ceurouj 6 k

bull NOT OBTAINED bull WRITTEN PHONE (Gn)

PHYSICAL SITE CHARACTERIZATION BACKGROUND INFORMATION (INCLUDE SITE DESCRIPTION TOPOGRAPHY AND PRIOR USES)

T h J^flxne prfrper^hj rs heeded on^hhe edge n-P^hdaJj marsh nd ja r fgtaexd$o ined tobull gt bull ^ bull - 6 i x7 7A n i - bull W o i n d c o n s - n f o n e bull bull ^J r J - - - mdash bdquo bull bdquo w y

a g e shy

hut Jd)siClti j samppoundraJ ^rmalkr~ bnamptfng find ar ire a adhere ltx )cujrgto^ p CP s rout )jj e v t^faol ixbullgt vch a H -Cor aaci^fipL f ra i aaf-)frn nCrheaictJ

oPxsrhnnland ^icferriW dwellings ffrhc^n UnK ppnee ^arTconds YtQgtemr DESCRIPTION OF SUBSTANCES POSSIBLY PRESENT KNOWN OR ALLEGED f^QOGn CKrea

T n j mft- TjlTft r epo r t ed lPCs 3 fneicJs c^cnde^ P f fXs A ) n lt7d g r e a s e

ma nu CcxctixrincK a n a chemicaJ rJ-eci intra ( J O C L S ^ uoenp d a m p e d n ^j-e W ^ o ^ bej-tx)eer I ^ ^ O s V-o 37pound-

EXISTING ANALYTICAL DATA IDENTIFY SOURCE DATE AND METHODOLOGY

bull REAL-TIME MONITORING DATA

SAMPLING DATA _

trease _

) onr^3lt n (V rv e TYinAlt i^r-li rlrnd c Ui n n oia n f- 3 ~7 3i

POTENTIAL THREAT 3i

DESCRIPTION OF POTENTIAL HAZARDS TO ENVIRONMENT ANDOR POPULATION - IDENTIFY ANY OF THE CRITERIA

^OR A REMOVAL ACTION (FROM NCP) THAT MAY BE MET BY THE SITE CHI Sec f)Orraquo FlCO-QlC amptMail fkken

)-poi-(gtn-Lgtai Exposure neltxChj humanS p-mems -hodchain Pr^iifoac-sJcv-i ecf ESSE bV^Yt^pofeniial ro Mamma-tiers o f d r m k i f Y j lord^rSupflieJecrJZijitPm lgtVraquo)t^gtlftfewx^a -poflttgtntHLl exposure gtp neafhj hurhajil anirmts Qgtcd chain f^rnm hcampc-sJoui renjamitw^ mn^minampych )bull ndctxtnSjT-CLnkSjCH-herTtfcasye co n^ixin-ersT^Cd- pnSltLl-eltsgtcd- of rp leas

1

S t EPA REGION I 3 of 3 REMOVAL PRELIMINARY ASSESSMENT

PRIOR RESPONSE ACTIVITIES

13^ PRP STATE pound3 FEDERAL bull OTHER

BRIEF DESCRIPTIONXnmdash^S3 fTlB- IbfrP ^c^rnpkd CfhU^AIt vxiornci- a 0lta^^ ciix ^ J l t f c andn n c T ^ n ) rU~rxJ-H-kpV-AP1 Q^ok^ry ^ r ^ o tyAfe^idampnhal KniI Q ^ M r - s Sr^W foV^S

( fr-tfP) m^fti lied a WW (AgtP) and r iler^cL^m^pd^^ I fXnO Kludge ^ a m ^ k ^ n W p r r ^ W f Q^lalt l^re

CO rpQ rC^HOn t Cn n plusmna nnlna ^T-S mPCo poundgt7(lnrl f-n poundP ion r hr~gtr

j gt ~ A ^ r ^ ^ Co^^r-^Pcy prp^gtra_r ( c ^ y Cpi

^ ^ p r e l i m i n a r y ^ r n - c a ^ f ^ m p ^

PRIORITY FOR SITE INVESTIGATION LEHIGH bull MEDIUM O LOW bull NONE

COMMENTS A J ~ P U ^ T f - e ^ D p p P ^ ^ H

REPORT GENERATION INITIATOR OF REPORT f l T j 0^ nO(X(^t ^LfoxuQ

DATE OF PREPARATION I j L)Cj Q

PH0NEAFFIUATIONT^U R ^e^pTechn W Assitfarr^ TeqM [ bull ( ^BM-MZO

1 OF 3 St EPA REGION I REMOVAL SITE INVESTIGATION

INSPECTION INFQflHATIBN ADDRESS ^ 3 k c L ^ X O f S tSITE NAME fr^Oc T f l t j C K

STATE TOWN COUNTY ftrfStp)

DATE OF INSPECTION I amp~ TIME OF INSPECTION ] O ~1Q A t T l

WEATHER CONDITIONS S l A D P u j 3 0 C p

SITE STATUS AT TIME OF INSPECTION COMMENTSfHan uPkri-^nnO) OjDem^inns ceased bull ACTIVE

INACTIVE consistisivj ma^rras exiXttr blti ldn^

AGENCIES PERFORMING INSPECTION

NAMES PROGRAM Sgte poundlltx) (J rd

EPA Amij Jpan Luster

NAMES FIRM

Z3pound no hcpound_

NAMES PROGRAM

bull STATE

NAMES ORGANIZATION

bull OTHER

BOOK

PAGE VERBAL CHECK AT DESK

CURRENT OWNER BASED ON DEED STATUS

CURRENT OWNER BASED ON FIELD INTERVIEW

PHYSICAL SITE CHARACTERISTICS QUANTITIESEXTENT PROVIDE SITE SCHEMATIC - SEE ATTACHMENT 1

QUANTITIESEXTENT poundjj-PILES

j pgtN- t^ndampr- ^loorOBTAINED SOIL bull CYLINDERS

bull SHEENS bull DRUMS

bull STRESSED VEGETATION) AJ R~bull LAGOONS AJ )n J-S^ABOVE U knouon qixc^nU^tu |D LANDFILL

QjTANKSH p rt ia-i e ( e -s i de nceogt raquo P J m POPULATI PTLPOPULATION WITHIN LD BELOW o us jcccdtonZ poundS VICINITY OF SITE

fvi^n tutu i^rmk STASBESTOS 9- suspected )cm+icABrw11-5

regOTHER ^ r t - vender -P loor JD OTHER

2 OF 3 REMOVAL SI GATION

PHYSICAL SITE OBSERVATIONS OMMENTS-^ building conzrsted poundgtP ecrtcCtU P bcrs jbYcKocite )kj and LOCO den inner uoalh ^hebrte piles fix^codj metal ^

smltx = f cnnjat igtrz c - ^ r ) X S u pec fco hestos campnhxm i no r f

CONTAINMENT OF MATERIALS bull T h r o u g h o u t gtAe hu t Jdrrta pSatiny mcLKte ^Y pnsh)y m n i t L i n j CLjanrtio n x x s h c c d - e d t^nr l p r A r s ) ni-ecjrr^f - lt 7cgt

cden -Floor Klta-rofe RECEPTORS

PRIVATE tprO0$-e(xs^ 1-cuon uoelk

^ j f GROUND WATERDRINKING WATER SOURCE MUNICIPAL u^Vhin ^ ry^rles

bull UNRESTRICTED ACCESS TO SITE ^

ST POPULATION IN PROXIMITY TO SITE ^ m e r o ^ s f^^tdonce-^ aigthltn IOO Ij^TAshy12 SENSITIVE ECOSYSTEM amp U - ^ T ^ X c d ^ ftlt3-Cj UJ gt f rgt ^ 7TI

11 OTHER FIELD SAMPLING AND ANALYSIS

FIELD INSTRUMENTATION ANALYTICAL PARAMETER

bull SOIL AJ j Q A 2 bull GROUNDWATER 7 t

Agt - A i SURFACE WATER

Rgjd hlAJO5 AIR SAMPLING JoacKj found TV

i_ TANKS A A - ^

A Z 7bull DRUMS

5Ts STRUCTURES AJ bull VATS

bull LAGOONS f 7 ^ ted 5 cujCKnde shy

J SPILLAGE

AJRUNOFF

g^PILES ^ Peons 1-y+aland n rhampntxbk

v- WS AJ 1^

1 OF 3 St EPA REGION I REMOVAL SITE INVESTIGATION

INSPECTION INFQflHATIBN ADDRESS ^ 3 k c L ^ X O f S tSITE NAME fr^Oc T f l t j C K

STATE TOWN COUNTY ftrfStp)

DATE OF INSPECTION I amp~ TIME OF INSPECTION ] O ~1Q A t T l

WEATHER CONDITIONS S l A D P u j 3 0 C p

SITE STATUS AT TIME OF INSPECTION COMMENTSfHan uPkri-^nnO) OjDem^inns ceased bull ACTIVE

INACTIVE consistisivj ma^rras exiXttr blti ldn^

AGENCIES PERFORMING INSPECTION

NAMES PROGRAM Sgte poundlltx) (J rd

EPA Amij Jpan Luster

NAMES FIRM

Z3pound no hcpound_

NAMES PROGRAM

bull STATE

NAMES ORGANIZATION

bull OTHER

BOOK

PAGE VERBAL CHECK AT DESK

CURRENT OWNER BASED ON DEED STATUS

CURRENT OWNER BASED ON FIELD INTERVIEW

PHYSICAL SITE CHARACTERISTICS QUANTITIESEXTENT PROVIDE SITE SCHEMATIC - SEE ATTACHMENT 1

QUANTITIESEXTENT poundjj-PILES

j pgtN- t^ndampr- ^loorOBTAINED SOIL bull CYLINDERS

bull SHEENS bull DRUMS

bull STRESSED VEGETATION) AJ R~bull LAGOONS AJ )n J-S^ABOVE U knouon qixc^nU^tu |D LANDFILL

QjTANKSH p rt ia-i e ( e -s i de nceogt raquo P J m POPULATI PTLPOPULATION WITHIN LD BELOW o us jcccdtonZ poundS VICINITY OF SITE

fvi^n tutu i^rmk STASBESTOS 9- suspected )cm+icABrw11-5

regOTHER ^ r t - vender -P loor JD OTHER

2 OF 3 REMOVAL SI GATION

PHYSICAL SITE OBSERVATIONS OMMENTS-^ building conzrsted poundgtP ecrtcCtU P bcrs jbYcKocite )kj and LOCO den inner uoalh ^hebrte piles fix^codj metal ^

smltx = f cnnjat igtrz c - ^ r ) X S u pec fco hestos campnhxm i no r f

CONTAINMENT OF MATERIALS bull T h r o u g h o u t gtAe hu t Jdrrta pSatiny mcLKte ^Y pnsh)y m n i t L i n j CLjanrtio n x x s h c c d - e d t^nr l p r A r s ) ni-ecjrr^f - lt 7cgt

cden -Floor Klta-rofe RECEPTORS

PRIVATE tprO0$-e(xs^ 1-cuon uoelk

^ j f GROUND WATERDRINKING WATER SOURCE MUNICIPAL u^Vhin ^ ry^rles

bull UNRESTRICTED ACCESS TO SITE ^

ST POPULATION IN PROXIMITY TO SITE ^ m e r o ^ s f^^tdonce-^ aigthltn IOO Ij^TAshy12 SENSITIVE ECOSYSTEM amp U - ^ T ^ X c d ^ ftlt3-Cj UJ gt f rgt ^ 7TI

11 OTHER FIELD SAMPLING AND ANALYSIS

FIELD INSTRUMENTATION ANALYTICAL PARAMETER

bull SOIL AJ j Q A 2 bull GROUNDWATER 7 t

Agt - A i SURFACE WATER

Rgjd hlAJO5 AIR SAMPLING JoacKj found TV

i_ TANKS A A - ^

A Z 7bull DRUMS

5Ts STRUCTURES AJ bull VATS

bull LAGOONS f 7 ^ ted 5 cujCKnde shy

J SPILLAGE

AJRUNOFF

g^PILES ^ Peons 1-y+aland n rhampntxbk

v- WS AJ 1^

2 OF 3 REMOVAL SI GATION

PHYSICAL SITE OBSERVATIONS OMMENTS-^ building conzrsted poundgtP ecrtcCtU P bcrs jbYcKocite )kj and LOCO den inner uoalh ^hebrte piles fix^codj metal ^

smltx = f cnnjat igtrz c - ^ r ) X S u pec fco hestos campnhxm i no r f

CONTAINMENT OF MATERIALS bull T h r o u g h o u t gtAe hu t Jdrrta pSatiny mcLKte ^Y pnsh)y m n i t L i n j CLjanrtio n x x s h c c d - e d t^nr l p r A r s ) ni-ecjrr^f - lt 7cgt

cden -Floor Klta-rofe RECEPTORS

PRIVATE tprO0$-e(xs^ 1-cuon uoelk

^ j f GROUND WATERDRINKING WATER SOURCE MUNICIPAL u^Vhin ^ ry^rles

bull UNRESTRICTED ACCESS TO SITE ^

ST POPULATION IN PROXIMITY TO SITE ^ m e r o ^ s f^^tdonce-^ aigthltn IOO Ij^TAshy12 SENSITIVE ECOSYSTEM amp U - ^ T ^ X c d ^ ftlt3-Cj UJ gt f rgt ^ 7TI

11 OTHER FIELD SAMPLING AND ANALYSIS

FIELD INSTRUMENTATION ANALYTICAL PARAMETER

bull SOIL AJ j Q A 2 bull GROUNDWATER 7 t

Agt - A i SURFACE WATER

Rgjd hlAJO5 AIR SAMPLING JoacKj found TV

i_ TANKS A A - ^

A Z 7bull DRUMS

5Ts STRUCTURES AJ bull VATS

bull LAGOONS f 7 ^ ted 5 cujCKnde shy

J SPILLAGE

AJRUNOFF

g^PILES ^ Peons 1-y+aland n rhampntxbk

v- WS AJ 1^

EPA REGION I of 3 REMOVAL SITE INVESTIGATION

ANALYTICAL RESULTS

SEE ATTACHED REPORT(S) p r c f c m iVicvO S ampSpoundsSmlaquo-)T- Q e p c r h ( -c r Fcwuc

FIELD QUALITY CONTROL PROCEDURES

^ ^ S O P FOLLOWED bull DEVIATION FROM SOP

COMMENTS ^ U ^ n

FURTHER ANALYSIS ANALYTICAL PARAMETER MEDIA LABORATORY

bull VOA bull AIR g f NERL

r- bull S A S

bull PCB bull WATER C L Pbull ^ bull SOW bull PESTICIDE DT SOIL bull NON-CLP LAB

plidlEr METALS -CdjCr f k ^ b ^ SOURCE

g f CYANIDE ~ 7 t f U ) fl-mDct-bk bull SEDIMENT

bull SEMI VOA

bull TOXICITY

bull DIOXIN

I^ASBESTOS

bull OTHER

ADDITIONAL PROCEDURES FOR SITE DETERMINATION bull BIOLOGICAL EVALUATION

U ATSDR

SITE DETERMINATION LISLISTT -- LUSE NCP CRITERIA CLOSUUSE MEMO j

rvPpound 7so claquor cch^ncx rhasf- mltxu be ffrpoundT

f e ^ t s n-C ^ o - m p K nhfQcrPOl d u r i n g V-Vx mdash i 1mdash n ^ mdash y _ s is i v - gt )mdash ^ _ ^mdash^ i j =mdashraquomdash bull v o mdash

f-t porr pep ocuTcxUonshy

APPENDIX A

Site Location Map (Figure 1)

APPENDIX B

Site Diagram (Figure 2)

1 I i I I I j f 1 I I i f i I I f 1 i J I 1 I I I 1 1 1 1 1 I i f i

NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

ATLAS TACK BUILDING LAGOON

ltc WELDING 5 SHOP

DRIVEWAY

BOILER MARSHLAND ROOM BUILDING

LEGEND

FENCE

STREET HURRICANE

BARRIER shy] RESIDENCES

NOT TO SCALE

FIGURE 2 REGION I TECHNICAL ASSISTANCE TEAM

SITE DIAGRAM DATE ATLAS TACK

SHAW 1 9 2 1 6 0 9

FAIRHAVEN MA DATE TDD

1 9 2 0 1 - 9 1 1 0 - 1 7 B

APPENDIX C

Health and Safety Plan

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX A

Site Location Map (Figure 1)

APPENDIX B

Site Diagram (Figure 2)

1 I i I I I j f 1 I I i f i I I f 1 i J I 1 I I I 1 1 1 1 1 I i f i

NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

ATLAS TACK BUILDING LAGOON

ltc WELDING 5 SHOP

DRIVEWAY

BOILER MARSHLAND ROOM BUILDING

LEGEND

FENCE

STREET HURRICANE

BARRIER shy] RESIDENCES

NOT TO SCALE

FIGURE 2 REGION I TECHNICAL ASSISTANCE TEAM

SITE DIAGRAM DATE ATLAS TACK

SHAW 1 9 2 1 6 0 9

FAIRHAVEN MA DATE TDD

1 9 2 0 1 - 9 1 1 0 - 1 7 B

APPENDIX C

Health and Safety Plan

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX B

Site Diagram (Figure 2)

1 I i I I I j f 1 I I i f i I I f 1 i J I 1 I I I 1 1 1 1 1 I i f i

NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

ATLAS TACK BUILDING LAGOON

ltc WELDING 5 SHOP

DRIVEWAY

BOILER MARSHLAND ROOM BUILDING

LEGEND

FENCE

STREET HURRICANE

BARRIER shy] RESIDENCES

NOT TO SCALE

FIGURE 2 REGION I TECHNICAL ASSISTANCE TEAM

SITE DIAGRAM DATE ATLAS TACK

SHAW 1 9 2 1 6 0 9

FAIRHAVEN MA DATE TDD

1 9 2 0 1 - 9 1 1 0 - 1 7 B

APPENDIX C

Health and Safety Plan

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

1 I i I I I j f 1 I I i f i I I f 1 i J I 1 I I I 1 1 1 1 1 I i f i

NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

ATLAS TACK BUILDING LAGOON

ltc WELDING 5 SHOP

DRIVEWAY

BOILER MARSHLAND ROOM BUILDING

LEGEND

FENCE

STREET HURRICANE

BARRIER shy] RESIDENCES

NOT TO SCALE

FIGURE 2 REGION I TECHNICAL ASSISTANCE TEAM

SITE DIAGRAM DATE ATLAS TACK

SHAW 1 9 2 1 6 0 9

FAIRHAVEN MA DATE TDD

1 9 2 0 1 - 9 1 1 0 - 1 7 B

APPENDIX C

Health and Safety Plan

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX C

Health and Safety Plan

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

WESTON MAJOR PROGRAMS DIVISION HEALTH AND SAFETY PLAN

EMERGENCY RESPONSE SITE INVESTIGATION

TnnNnOJ-q 110-17 H amp Site Name fit T o e K Site Address Street No ^ n P f -^t-ngt

City R i C b C k ^ Q _ CountyState ftr-i-TVf-o rrraquo I ^ T N J J ADH-

Site Contact Phone No

Directions to fijtefAtLMmVEVwregcl tn amp+au XCron hmT fh ks to

School Ayena-gt TbrK ltJO lt toot ^ fcocks HistoricalCurrent Site Information

fhAnuGxcHLrtrr nnltj r Ion ^ n a C r i P mfco^K Ury T l ^ r r ^ m e c i ^ r r a n ftnlfnpcf toftnpn laquo gt h r r ) S ^fgt^L^ M q rnrxfxxl cwlthtoJ3sLrr

Von ffTKn^^pd T ^ P gt Qgtggt- g r o u n d mater-p ^fgt) ^ O l ^ r ^

Incident Type ( ) Air Release ( )SpiUshy( _ _ shy

() HW Site - -gltPi- ltsAg tvampArraquopound _

Location Class ( ) Industrial ( ) Commercial ( ) UrbanResidential ( ) Rural

USEPA rnntact) J Shi^~ Date of Initial Site Activities H j j j l l Original HASP Yes Modification Number Lead TkT-Dont hhC Site Health amp Safety Coordinator QwAmdash

Response ActivitiesDuration (fill in as applicable)

Emergency Response ( ) Perimeter Recon ( ) Site Entry ( ) Visual Documentation ( ) Multi-media Sampling ( ) Decontamination

Assessment (jQ Perimeter Recon Site Entry

( Visual Documentation (y) Multi-media Sampling fyQ Decontamination

1

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Physical Safety Hazards to Personnel

(7^ Heat 6Q Cold ( ) Precipitation ( ) Confined Space J f t Terrain ( k WalkingWorking Surfaces ( ) Fire amp Explosion ( ) Oxygen Deficiency f ) Underground Utilities ( ) Overhead Utilities ( ) Heavy Equipment ( ) Unknowns in Drums Tanks Containers Ponds Lagoons Impoundments ( ) Rivers Streams ( ) Pressurized Containers Systems ( ) Noise ( ) niuminadon ( ) Nonionizing Radiation ( ) Ionizing Radiation

Biological Hazards to Personnel

( ) InfectiousMedicalHospital Waste ( ) Non-domesticated Animals ( ) Insects ( ) Poisonous PlantsVegetation ( ) Raw Sewage

Training Requirements

C$ 40 Hour General Site Worker Course with three days supervised experience ( ) 24 Hour Course for limited specific tasks with one day supervised experience ( ) 24 Hour Course for Level D Site with one day supervised experience ty 8 Hour Annual Refresher Health and Safety Training

8 Hour ManagementSupervisor Training in addition to basic training course ( ) Site Specific Health and Safety Training

( ) Pre-entry training for emergency response skilled support personnel

Medical Surveillance Requirements Baseline initial physical examination with physician certification Annual medical examination with physician certification

( ) Site Specific medical monitoring protocol (Radiation Pesticide PCB Metals) ( ) Asbestos Worker medical protocol ( ) Exempt from medical surveillance (Y) Examination required in event of chemical exposure or trauma

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

P Chemical Hazards to Personnel

Cheaical Contaminant Cheaical Contaminant Cheaical Contaainant Cheaical Contaminant Physical Parameters

Ccvjrrgtiurr

o I M 4 3 A ppn -fcH^-mg3 PEL a ^ p p m J ^ i w j a r PEL

Exposure 4T5^-PPI i i^mg3 PEL jtgfr ppn J 2 pound TO3 TLV ppa pound laquo9laquo TLV

Limits ppa _3J_ mgB3 TIV ppm i O ^ mgn3 TLV ppn mgH3 IDLH bullrf7poundpoundgt ppn bullBaf IDLH ppa mglaquof IDLH

IDLH Level ppn mg3 IDLH

Liquid Solid iquid Solid Liquid Solid Liquid Solid

Physical Form Color Color GM _Gas Color Gas Color CM _SalLiqCraquow Color co Airless Co hrfess colorless

Odor trade ^ 3 1

net- corntou^ht^ Q Degrees(bor c Oegreaa F or C Degrees F or C Degrees F or C Flash Point X UEL X LEL X UEL X X LEL i n X UEL 3 X LEL X LEL UELFlammable

l imits

no imHg I l t O naHg Vapor Press 01 mmHg mVHg V T i V Air laquo 1 Air 1Vapor Oens Air raquo 1 Air bull 1 ZS3I

Water - 1 Water 1 Water laquo 1 Water raquo 1

Specific Gravi ty

Solubility 3 ^

Incompatible Materials

Inh Abs Inh Inh Abs Inh Abs Route of Abs Con Ing Con Con Exposure Con Ing Ing Ing

p tlaquoirgt ede m a d u s f ilaquow degree nau n o - - h e a d Qraquo - t f five j v^mT l iver Kdneij f f g h r c h e s t Subs f W Symptoms of hepcctcneCjCLl i j e y e

Acute Exposure aches nlaquou dic-rr ltfl0S) i r r 1011 freibullKvnrtrade e^e - r Tinea

tf-p- -skxxf toctsgti F i rs t Aid Treatment breca-h - c^rY re5^3

firer^-O-rt bull f ^ p

Q eV eV Ion Potential eV eV

Probe 1mdashPip g 9 Probe ^PID M 7 Probe ^ PID w n Probe PID w Instruments H

FID CGI RAD ^ FID U-CGI RAD ^ gtID U^CGI laquo RAO FID CGI _ RAD For Detection Det Tube Ph Det Tube Ph Det Tube Ph Det Tube Ph

Other Other Other

3

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

C h e m i c a l Hazards to Personnel

Chemical Contaminant Cheaical Contaminant Chemical Contaminant Chemical Contaminant Parameters

Physical

Pu gte s and cJcsr

~gt JUS ppn ^ O S M W P PEL pom j pound _ mgm3 PEL -ht+e-ve i l^pmgn 3 PEL I Q O ppn j ^ m g a 3 PEL Exposure ppng^mgm3 TLV t pom 3 _ mgm3 TLV -7laquoTlt7 ppn O M mgm3 TLV Limits tOO pom -1 Omga3 TLV ppn mgm5 IDLH ppn aQ mgm3 IDLH ltk7tfQ pom mgm3 IDLH IDLH Level 1 c 00 ppn mgm3 IDLH

1 Solid Liquid

Solid -Liquid V Solid Liquid Solid ^ Liquid Physical Form Gas _ Color

Gas _ Color Gas Color Gas Color SolLiq6as

Color Co lcrbsltgt I ogtrorroJtltc

Odor odor (tfCAJ lt)o^) bullit hot- combust bAe

M Degrees (T)or C Degrees t or C [W O Degrees(poundor C Degrees F or C Flash Point y S X UEL 2Q~X LEL X UEL X LEL |

X UEL I X LEL X~ UEL X LEL Ft amiable l imits

O mmHg 3 ( i l l mmHg Vapor Press 9-pound mmHg

Air raquo 1 Air bull 1 Vapor Dens

3 1 shyWater laquo 1 am

0 Water raquo 1 (lt Water bull 1 filG water = 1 Specif ic Gravity

Solubil i ty

ox di zers en pspv-olf 1

Incompatible Zixch (xz nt Tnxtes Materials

a r i d c u r r r f s o t - f r S 1Inh Abs Inh Abs Inh Abs Route of V Inh Abs Con Ing Con Ing Exposure i ^ - Con Ing Con Ing

g shyf a n ( r c c c r c^ec^tf heoeii

Symptoms of Acute Exposure of p u p Sf n e r v o u s

S K i V raquo i r r H - L M i T O

S K ^ r T S C C - ^ UCV^- ^ i p - Sorti7laquoJ- u--ltxfe First Aid Treatment breech-- ltxr nssp

eV eV eV Ion Potential eV to

Probe PID w JOQ- Probe PID M Instruments ^ PID M Q3 Probe PID w Probe

FID CGI _ RAD FID imdash-CGI RAD FID u CGI RAD FID _ CGI _ RAD For Detection Det Tube Ph Ph Det Tube Ph Det Tube Ph Det Tube Other 3Other Other Other

a

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Physical Parameters

Physical Fom SolLiqGas-Color

Flash Point Flammable limits

Vapor Press Vapor Oens

Specific Gravity

Solubility

Incompatible Materials

Route of Exposure

Symptoms of Acute Exposure

First Aid Treatment

Ion Potential

Instruments For Oetection

Chemical Hazards to Personnel

Cheaical ContaainantCheaical Contaainant

Qhrcf^) um fn fa) C h r o m t u m j ct i bulloujf

ppa JX P E L

pea I D mgm3 TLV ppa mgB 10LH

Hot C O r T l D ^ ^ 1

Degrees F or CDegrees f or C T UEL X LEL _X UEL X LELr UEL X LEL

mmHgimHgj J l h mmHg A i r = 1Air = 1bull J j r V Air = 1

Water = 1l ^ V Water = 1fa I Water = 1

ChcnncCfeci r u b b e r

Inh Abs Inh Abs Inh Abs

Con Ing Con Ing Con Ing

Si^t^f- rx-laquofal Taste 9(r^ gteurons derm

breach- o~c fe f7- brerx-t^-or- (esp bullgtbdquo oca J W m ed-( rf-n

eV Or eV eV

PID w Probe PID w Probe PID w Probe RAO FID CGI RAD FID CGI RADE10 CGCGIIFID bullmdash-Pet Tube PhDet Tube Ph -- Det Tube Ph Det Tube Other f Other gt-J-Other

Cheaical Contaainant

^ amHg -gt Air laquo 1

Water bull 1ML

0 t-^ecccabuJgtbi

Inh Abs Con Ing

eV

PID w Probe FID CGI RAD Det Tube Ph

bullOther f ) ir~

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Site Control Measures

Site Map with work zones

Decontamination Procedures

( ) Wet Decontamination shy(j^Dry Decontamination

using

A i f

3 E

Description of Site Specific Decontamination gtPlan gt M _ C A J L A-n to ^ K K W J rVopo r

A i ^ f t ^ c J o

fl^ r

Adequacy of decontamination detennined by vjiSutxP r k)S^rvy o-A-i -gt-v

4

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Personal Protective Equipment

INNER GLOVE TYPE OF APR TASK TO BE ANTICIPATED TYPE OF

OUTER GLOVE CARTRIDGE OR CHEMICAL PERFORMEDAIR LEVEL OF PROTECTIVE BOOT COVER CANISTER

MONITORING PROTECTION COVERALL REQUIRED

w

C3)

copyowS

Frequency and Types of Air Monitoring (^ontinuous ( ) Routine - ( ) Periodic shy

DIRECT COMBUSTIBLE READING GASOXYGEN INSTRUMENTS METER

(1)

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL pound 20LEL pound195 Si 23 0 - LEAVE

RADIATION PHOTOIONIZATION SURVEY METERPROBE (2)

3X BACKGRND shyCAUTION 1 MRHR-LEAVE

TECTORPROBE

UNKNOWNS 0-5 UNITSC 5-500 B

FLAME CHEM IONIZATION DETECTOR DETECTOR TUBE (5)

UNKNOWNS PELTLV 0-5 UNITSC COMPARE 5-500 B WPF

5

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Personal Protective Equipment

TASK TO BE ANTICIPATED TYPE OF INNER GLOVE TYPE OF APR PERFORMEDAIR LEVEL OF CHEMICAL OUTER GLOVE CARTRIDGE OR MONITORING PROTECTION PROTECTIVE BOOT COVER CANISTER REQUIRED COVERALL

v0_ rv j ^

Frequency and Types of Air Monitoring (^ Continuous ( ) Routine ( ) Periodic shy

DIRECT COMBUSTIBLE RADIATION PHOTOIONIZATION FLAME CHEM

READING GASOXYGEN SURVEY DETECTORPROBE IONIZATION DETECTOR1

INSTRUMENTS METER METERPROBE DETECTOR TUBE (5)

(1) t2) (4)

i

ID NUMBER

CAL DATE

TAT MEMBER

ACTION LEVEL ^ 20 LEL 3X BACKGRND shy UNKNOWNS UNKNOWNS PELTLV pound195 23 CAUTION 0-5 UNITS C 0-5 UNITSC COMPARE 0 shy LEAVE 1 MRHR-LEAVE 5-500 B 5-500 B WPF

m

5

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Emergency Phone Numbers

Emergency Contact

S T shy shy AV lt Hospital 10 i

Location

l-o^e jgtr

Phone Number Notified

mbulance

Police r h rraquo igtltc n

Fire Dept Pew r hjxplusmneuron

Chemical Trauma Capability ()4 Yes ( ) No If no closest backup

Directions to Hospital (attach map) - Route verified by - i A J T V ^ laquo 1 ^ mdash V ^ - | gt i

Phone

- | - r

Date

v

T T

Additional Emergency Phone Contacts

Contact Phone Number

WESTON 24 hr Hotline 215-524-1925 215-524-1926

WESTON Medical Emergency Service 513-421-3063

Chen tree 800424-9300

ATSDR 404-639-0615

ATF (explosives information) 800-424-9555

National Response Center

National Poison Control Center

800424-8802

800-942-5969

o Date Jy 3c7 _ HASP prepared by C L ^ C ^ lt pound L

Pre-ResponseEntry Approval by - ~ Date lplusmn_JUlL Date Verbal ApprovalModification to Original HASP by

6

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Physical Description of Site and Response Activities

Size of Site ih AcSgt Terrain -Flout Weather 5^ny ltjvJgtZ Distance to Nearest Residence ampco Schoolooc Hospital z

Public Building Tec f Other Evacuation ( ) Yes (^No Bv Whom Nearest Waterway ampu i^Js amplt~^ Distance from Site inn

Condition Observed Potential None Comments Observations

Surface Water Contamination

Ground Water Contamination

Drinking Water Contamination

Air Release

bullfSoil Contamination

Stressed Vegetation

VDead Animal Species

Actions Taken On-Site Perimeter Monitoring (t^Yes ( ) No Site Entry by TAT ( ) Yes (lt-)-fo

Tasks Conducted Level of ProtectionSpecific PPE Used

poundgt - sh-tel fa kcofc Co tfa~^ tdeg S^1- W S

in CO ttue-cdJU

7

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Physical Description of Site and Response Activities

Size of SiteJ^^LL^L Terrain VloJr Weather SUYl 30CF Distance to Nearest Residence 500 1 School 1006 1 Hospital CL r

Public Bunding poundC01 Other Evacuation ( ) Yes poundgt^No By Whom Nearest Waterway __ Distance from Site

Potential CommentsObservations Condition Observed None

Surface Water Contamination co-nc odtri hhcJ-GcnftxrnnoJ-icf)

Ground Water Contamination

Drinking Water Contamination

Air Release

Soil Contamination 21 Stressed Vegetation

Dead Animal Species Y

Actions Taken On-Site Perimeter Monitoring T ) Yes ( ) No Site Entry by TAT (^Yes ( ) No

Tasks Conducted Level of ProtectionSpecific PPE Used

t ^ IO j n -Trlt c^aj^

I

tut

7

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Air Monitoring Summary Log Date 6 I9f Data Collected bv amp j^^cA^e

Data to be summarized by a Range of readingsie- Low to High andor Average by location

PIDProbe FIDOVA Detector TuStationLocation CGIO Meter Radiation Meter

SummaryComments WcVM^

8

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Air Monitoring Summary Log DateJ__2^j J lt Data Collected by ^CLVJ I l-Xnn D PiC tgt

Data to be summarized by a Range of readingsie- Low to High andor Average by location

StationLocation CGIO Meter Radiation Meter PIDProbe FIDOVA Detector Tube

OcOO A) fir

I COT)

00^

QOf

_ SummaryComments Agtn rltn tf-i^fn nlAn4 m r K ^ Q - T ^ n ^

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

gt

Hazardous Waste Site and Environmental Sampling Activities

Off Site ( ) Yes () No On Site ( ) Yes (^fNo

Describe types of samples and methods used to obtain samples _

Was Laboratory notified of Potential Hazard Level Of Samples ( ) Yes ( ) No

Note- The nature of the work assignment may require the use of the following proceduresprograms which will included as Attachments to this HASP as applicable Emergency Response Plan Confined Space Entry Procedures Spill Containment Program ^

Disclaimer This Health and Safety Plan (HASP) was prepared for work to be conducted under the Technical Assistance Team (TAT) Contract 68-WO-0036for Zone I Use of this HASP by WESTON and its subcontrac is intended to fulfill the OSHA requirements found in 29 CFR 1910120 Items not specifically covered in thff HASP are included by reference to 29 CFR 1910 and 1926 m

The signatures below indicate that the individuals have read and understood this Health and Safety Plan

AFFILIATION DATE PRINTED NAME SIGNATURE

hU9tvivTW JAM Irhi

bullJ

Date Final Submission of HASP by

Post Response Review by

Post Response Approval by

TAT HSO Review by

COMMENTSFOLLOWUP

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

ERECTIONS TO THE HOSPITAL REGION I TECHNICAL ASS STANCE TEAM

ATLAS TACK SITE -AIRHAVEN CT 1570

PCS bullDATE DRAWN

B DONOHOE 1 2 9 1 bull -gtC-M ni-i PLEASANT ST TO RIGHT ONTO WASHINGTON ST bull ^ ^ ^ O ^ l f S T O N AVE (RT 6) TO LEFT ONTO

T TO RIGHT ONTO ALLEN ST ST LUKE HOSPITAL GHT

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX D

Site Sampling QAQC Plan

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

ATLAS TACK SAMPLING QUALITY ASSURANCE

QUALITY CONTROL PLAN FAIRHAVEN MASSACHUSETTS

Prepared For

US Environmental Protection Agency Region I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-W0-0036

TAT-01-N-00992

TDD NO 01-9110-17B

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

January 1992

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

TABLE OF CONTENTS

PAGE

10 Background 1

20 Objectives 4

30 Quality Assurance Levels 4

40 Approach and Sampling Methodologies 5

41 Sludge Sampling 5

50 Project Organization and Responsibilities 5

60 Quality Assurance Requirements 7

70 Deliverables 7

80 Data Validation 7

90 References 9

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

LIST OF FIGURES

FIGURE 1 - Site Location Map

FIGURE 2 - Site Diagram

FIGURE 3 - Sample Location Diagram

iii

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

LIST OF TABLES

PAGE

TABLE 1 shy Sampling Summary Analytical Methods amp QAQC Samples 8

iv

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

10 Background

Atlas Tack Corporation is a 13-acre facility located at 83 Pleasant Street in Fairhaven Massachusetts (Figure 1 - Site Location Map) and was involved in the manufacture of rivets tacks eyelets and similar products (approximately 24000 different items) since 1895 The site is bounded to the south and east by marsh and to the north and west by residential dwellings (Figure 2 - Site Diagram) From the early 1940s to 1978 it maintained a 100 ft x 100 ft unlined acid-neutralizing lagoon on site for disposal of waste liquids and sludge containing heavy metals cyanide and volatile organic compounds associated with such manufacturing processes as annealing pickling plating enameling and cleaning

Atlas Tack Corporation had been discharging waste water under NPDES permit number MA 0002704 Prior to this on June 4 1974 the NPDES permit was issued with the requirement that Atlas Tack Corporation cease discharging into Buzzards Bay and instead tie into the Fairhaven sewage treatment system The Town of Fairhaven opposed this connection and on February 23 1976 proposed a connection with the Fairhaven Sewage Treatment Plant (STP) outfall By August 10 1976 compliance with the NPDES permit had not been met and an Administrative Order was issued requiring Atlas Tack Corporation to submit an engineering report in their proposed connection to the Fairhaven STP outfall along with their application for a re-issuance of their permit Compliance had still not been reached by June 22 1978 and therefore on that date an Agreement for Judgment against Atlas Tack Corporation to eliminate discharges to Buzzards Bay was issued in Suffolk Superior Court At that time discharges to the lagoon by Atlas Tack Corporation were reportedly terminated thus effecting compliance with their discharge permit

Atlas Tack Corporation was cited as a point source of pollution for direct discharge to Buzzards Bay in the Massachusetts Department of Environmental Quality Engineering (DEQE) Water Quality Management Plan 1976 and a Water Quality Area Management Plan prepared by the Southeast Regional Planning and Economic Development District February 1978 Both reports recommended a tie-in to the Fairhaven STP which was effected in 1978 The 1978 Area Management Plan also recommended further study of the lagoon to monitor the potential migration of contaminants to Pope Beach During the period 1981-1985 the MA DEQE issued Notices of Violation of Hazardous Waste Regulations against Atlas Tack for its failurerefusal to remove lagoon contents in response to community concern about possible adverse health effects which may result from any exposure to disposed materials

On January 14 1983 Goldberg-Zoino Associates (GZA) under contract to Atlas Tack Corporation to explore feasible options for lagoon closure installed an observation well approximately twenty feet from the southeast corner of the lagoon Groundwater lagoon sludge and soil samples were collected and volatile organic compounds (VOCs) cyanides and heavy metals were identified The general levels of contaminants found in the groundwater directly adjacent to and presumably downgradient from the lagoon indicated that the contaminants found in the sediments were being leached into the groundwater

During the period of March 1983 to November 1985 GZA continued to serve as consultant to Atlas Tack and hired Clean Harbors Corporation Braintree MA to remove the lagoon contents in cooperation with Cecos Treatment Corporation Bristol Connecticut and Jetline

1

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

2

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

I 1 1 1 I 1 I 1 I 1 I 1 I 1 f 1 I 1 I I 1 I 1 I 1 I 1 I 1 I 1 I 1 I 1 I i

ft NEW YORK NEW HAVEN amp HARTFORD RAILROAD

LOADING LOADING DOCK DOCK

IU ATLAS TACK BUILDING Ui

DRIVEWAY

BOILER ROOM BUILDING

LEGEND bull

FENCE STREET

RESIDENCES

NOT TO SCALE

FIGURE 2

LAGOON

z ^ GATE

ltsgt

WELDING SHOP

lt 2

MARSHLAND

y HURRICANE

BARRIER

REGION I TECHNICAL ASSISTANCE TEAM SITE DIAGRAM

DATE ATLAS TACK 1 6 0 9 SHAW 192

FAIRHAVEN MA APPROVED DATE TDD o

1 9 2 0 1 - 9 1 1 0 - 1 7 B

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Services Stoughton MA GZA inventoried samples and removed all RCRA waste within the buildings and pumped the contents of four large underground tanks All this work was conducted under the guidance of the MA DEQE who followed a workplan generated by their contractor Wehran Engineering Methuen MA

The US Environmental Protection Agency (EPA) tasked their Field Investigation Team contractor NUS Corporation (NUSFIT) to conduct a site inspection on April 26 1984 during which time lagoon sludge surface water soil sediment and groundwater samples were collected Sample analysis included cyanide inorganics and VOCs Five VOCs were identified in samples collected from the site with toluene detected at a concentration of 3089 ppm in the marsh sediment south of the lagoon The highest concentration of cyanide (37200 ppm) was found in the lagoon sludge collected along the north side of the lagoon Fifteen inorganic substances were identified among all samples These compounds are consistent with those utilized in Atlas Tacks manufacturing processes

In 1985 the lagoon was removed from the site In February 1989 the Roy F Weston Inc Region I Technical Assistance Team (TAT) conducted a preliminary site assessment No further involvement by TAT beyond preliminary assessmentreconnaissance was recommended since the MA DEQE assumed all further responsibility for the case in cooperation with the EPA Region I Remedial Branch

On July 30 1990 the Roy F Weston Environmental Services Assistance Team (ESAT) at the request of the EPA conducted an ecological assessment of the site which involved the collection of soil and sediment samples The detection of metals at levels up to 9000 ppm during preliminary analyses suggested that the area may pose a threat to the local population via direct contact

20 Objectives

The objective of the sampling survey is to obtain sufficient analytical data from a representative number of samples which can be used to determine whether further actions at the site by the US EPA Region I Emergency Planning and Response Branch (EPRB) are necessary

30 Quality Assurance Levels

The quality assurance (QA) levels for the on-site screening activities will be QA1 These activities include the use of the following instrumentationtest equipment

HNU Systems Inc Photoionization Detector (HNU PID)

Mine Safety Appliances Model 260 Combustible Gas IndicatorOxygen Alarm

Victoreen Radiation Meter (Model 490)

The QA level for the samples analyzed at the laboratory will be a modified QA2 The QA levels are described in OSWER Directive 93604-01 (April 1990-Interim Final) Quality

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

AssuranceQuality Control Guidance for Removal Activities Sampling QAQCPlan and Data Validation Procedures It is anticipated that QA1 and QA2 will satisfy most data quality requirements for the Removal Program

See Section 60 for quality assurance requirements

40 Approach and Sampling Methodologies

The sampling survey will be conducted on or about November 25 1991 Samples have been identified using an internal classification of low mid and high-level concentrations which refers to the anticipated level of potential contamination This classification system was instituted by EPRB and the US EPA New England Regional Laboratory (NERL) in May 1991 The classification system and relative sampling protocols used to develop this sampling plan are described in a Roy F Weston draft inter-office memorandum dated June 6 1991 which has been submitted for comment to EPRB and NERL Sludge samples will be collected for but are not limited to analyses for mid-level metals and total and amenable cyanide

41 Sludge Samples

Up to five (5) sampling locations will be selected by Site Investigator Mary Ellen Stanton (Figure 3 - Sampling Location Diagram) Sludge samples will be collected at each location for each of the 4 parameters as listed in Section 40 Disposable plastic spoons will be used for the samples collected for metals and total and amenable cyanide analyses Metals samples will each be contained in one 4-ounce glass jar which will be half full and preserved on ice and cyanide samples will each be contained in one 8-ounce glass jar and will be preserved on ice

The samples will be screened in the field prior to sample collection if practical to determine the location and quantity of samples to be collected The samples will be containerized preserved and analyzed in accordance with Table 1 US EPA chain of custody procedures will be utilized for all sampling activities Samples will be disposed of by the laboratory performing the analyses All contaminated sampling materials will be disposed of by NERL

50 Project Organization and Responsibilities

US EPA EPRB

Amy Jean Lussier On-Scene Coordinator

Mary Ellen Stanton Site Investigator

Roy F Weston TAT Members

Brian Donohoe Sample collection and documentation

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

ft ATLAS TACK BUILDING

I

SAMPLE 0 0 5 (GRAY DUST) SAMPLE 004

(SOIL)

SAMPLE 003 (WOOD)

5 o o

SAMPLE 0 0 2 SAMPLE 0 0 1 z (SOIL) (SOIL)

ON

SAMPLE 0 0 6 ENTRANCE SAMPLE 007 (ASBESTOS)

(ASBESTOS)

DRIVEWAY

NOT TO SCALE

FIGURE 3 REGION I TECHNICAL ASSISTANCE TEAM

SAMPLE LOCATION DIAGRAM DATE ATLAS TACK 1609 SHAW 192

FAIRHAVEN MA DATE TDD a

192 0 1 91 10-17B

i i E i i i i i i i i i i i i i i i 1 1 i i i i i i i i i i i i i i i i i i

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

Margaret Shaw Quality Control Monitor

The quality control monitor shall record quality assurance checks and any problems or corrective actions taken associated with the sampling and sampling plan The quality control monitor shall also be responsible for completeness and accuracy of the chain of custody record

60 Quality Assurance Requirements

The analyses will be performed at NERL The samples designated as high-level will be analyzed to indicate the presence or absence of contamination above a threshold value High-level QA protocols will include semi-quantitation of high levels of target specific compounds based on a known standard The samples designated as mid-level will be analyzed to determine definitive identification and quantitation of contaminates Mid-level QA protocols will include a laboratory blank matrix spike and multiple standards Samples designated as low-level are usually drinking water samples or samples collected for enforcement purpose Low-level QA protocols will include a laboratory blank matrix spike and matrix spike duplicate and multiple standards

70 Deliverables

A report documenting all project activities will be generated by TAT Based on visual observation and exact sampling locations selected in the field a site diagram and sample location map will be prepared and included in the final sampling QAQC plan Any modifications to the practices in the original sampling QAQC plan will be documented in this report when it is finalized in order to reflect what was actually done in the field

80 Data Validation

A data quality review of the sample analyses will be conducted by TAT andor NERL personnel The data will be evaluated according to OSWER Directive 93604-01 (April 1990 - Interim Final)

QA level 1 data will be evaluated for calibration and detection limits

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

TABLE 1

SAMPLING SUMMARY ANALYTICAL METHODS AND QAQC SAMPLES

MATRIX ^SAMPLES ANALYTICAL PARAMETER VOLUME CONTAINER PRESERVATIVE METHOD TRIP BLANKS

Sludge Metals-mid Cyanide-total

Cyanide-amenable

2-oz 8-oz 8-oz

4-oz glass 8-oz glass 8-oz glass

ice ice ice

NA NA NA

NA NA NA

CO

I I I I I I I I I I I I I I I I I I 1 1 1 1 1 1 I I I I 1 1 1 1 1 1 1 1 1 1

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

90 References

US Environmental Protection Agency OSWER Directive 93604-01 (April 1990 - Interim Final) Quality AssuranceQuality Control Guidance for Removal Activities Sampling QAQC Plan and Data Validation Procedures

Roy F Weston Inc Technical Assistance Team Region I Draft Inter-Office Memorandum on Sampling Protocols June 6 1991

Roy F Weston Inc Technical Assistance Team Region I Preliminary Site Assessment for Atlas Tack Site Fairhaven Massachusetts February 1989

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX E

Chain of Custody Record

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

REGION 1ENVIRONMENTAL PROTECTION AGENCY

JFK Federal Bui ld ing Rm 2 2 0 3 Office of Enforcement

Boston Massachusetts 0 2 2 0 3 CHAIN OF CUSTODY RECORD PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF

REMARKS CONshy

TAINERS

STA NO DATE TIME STATION LOCATION

Ool COS

i shy 1 Jo^ -

0pound3 m no

2r Aye pound1 2r

0^5 3--fro 2- 2r

Relinquished

^1Relinquished

by (Signature)

kirfaLfr^Mu by (Signature)

)ate Time

053shyDate Time

Received by (Signature)

Received by (Signature)

bull A

Relinquished

Relinquished

by (Signature)

by (Signature)

Date Time

Date Time

Received by (Signature)

Received by (Signature)

Relinquished by (Signature) Date Time Received f or Ll (Signature^

sap

Distribution Original Accompanies Shipment Copy to CoortJInatbr^ield Files

7 gap W

i I QO

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

I i i i I i i i I i i i i i 1 I I I I I 1 1 1 1 I I I I I i i t i i i ENVIRONMENTAL PROTECTION AGENCY REGION 1

Office of Enforcement CHAIN OF CUSTODY RECORD

JFK Federal Bui ld ing Rm 2 2 0 3 Boston Massachusetts 0 2 2 0 3

PROJ NO PROJECT NAME

NO

SAMPLERS (Signature) OF REMARKS

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

3_ y 3 f-v f)cor

Received by (Signature) Relinquished by (Signature) Date Time Relinquished by (Signature) Date Time Received by (Signature) f

Date Time Received by (Signature) Relinquished by (Signature)Relinquishecfby (Signature) Date Time Received by (Signature)

Relinquished by (Signature) Date Time Received for Laboratory by Date Time Remarks (Signature)

1044 Distribution Original Accompanies Shipment Copy to Coordinator Field Files

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

APPENDIX F

Photodocumentation Log

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 001 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 1 DATE 010892 TIME 1429 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 2 0OA FILM ROLL 08829 0

SCENE Sample s t a t i o n 002 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 3 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 4 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 003 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 5 DATE 010892 TIME 1431 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 004 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 7 DATE 010892 TIME 1432 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe

CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 005 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 8 DATE 010892 TIME 1432 SKY CONDITION cl e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

PHOTOGRAPHY LOG SHEET

SCENE Sample s t a t i o n 007 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 11 DATE 010892 TIME 1441 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA M i n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

SCENE Sample s t a t i o n 006 SITE NAME A t l a s Tack LOCATION Fairhaven MA FRAME NUMBER 14 DATE 010892 TIME 1442 SKY CONDITION c l e a r PHOTO BY Shaw WITNESSES Donohoe CAMERA Mi n o l t a SETTING auto FILM TYPE 200A FILM ROLL 088290

NEGATIVES

NEGATIVES