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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I
ENVIRONMENTAL SERVICES DIVISION 60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173-3185
March 6 1990
Mr Jim Makris Chairman National Response Team Office of Emergency and Remedial Response EPA (WH-548-A) 401 M Street SW Washington DC 20460
Dear Mr Makris
Attached please find the On-Scene Coordinators report for the cleanup which involved a fund financed removal action conducted at the STAMINA MILL HAZARDOUS WASTE SITE in North Smithfield Rhode Island which occurred during the period of July 12 through November 11 1988
This report is being sent to you in accordance with CFR 30040 and 30069 of the National Oil and Hazardous Substance contingency plan which statesthe OSC shall submit to the RRT a complete report on the response operation and the actions taken The OSC shall at the same time send a copy of the report to the NRT for review This shall be accomplished within 30 days after the report has been received
Should you have any questions in regard to this report please contact me at (617) 860-4308 shy
Sincerely
aul R Groulx Federal On-Scene Coordinator Response and Prevention Section
Enclosure On-Scene Coordinators Report
cc Leonard B Wallace IV RRT Coordinator BSD Lexington MA David Lopez EPA Emergency Response Division Washington DC Rose Toscano EPA RPM Boston MA Joseph Polselli State of RI DEM Providence RI Raymond Church Town Administrator Slatterville RI Steve Novick EPA Enforcement and P T-edness Section
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ON-SCENE COORDINATORS REPORT
STAMINA MILLS SITE FORESTDALE PROVIDENCE COUNTY RHODE ISLAND
REGION I
AUGUST 9-12 1988 NOVEMBER 16 1988
Emergency Planning amp Response Branch Environmental Service Division
United States Environmental Protection Agency60 Westviev Street Lexington MA 02173
(617) 860-4300
Prepared By
Paul Groulx On-Scene Coordinator US Environmental Protection AgencyEmergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Date
TABLE OF CONTENTS
I INTRODUCTION
A Removal Action Summary 1 B Site History and Background 1 C Participating Organizations and
Personnel 4
II SITE ACTIVITIES
A Chronological Summary 5 B Effectiveness of Removal Action
and Recommendations 8 C EPA-Committed Resources 9 D Problems Encountered 10
III SUPPORTIVE DOCUMENTATION
A Work Plan 10 B Health and Safety 10 C Community Relations 11 D Enforcement 12 E Pollution Reports (POLREPS) 12
ii
LIST OF FIGURES
1 General Location Map Stamina Mills Site Forestdale Rhode Island
2 Site Map Stamina Mills Site (Site 27) Forestdale Providence County RI 3
1 v
iii
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
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(D 0)
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O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
Sshy
ON-SCENE COORDINATORS REPORT
STAMINA MILLS SITE FORESTDALE PROVIDENCE COUNTY RHODE ISLAND
REGION I
AUGUST 9-12 1988 NOVEMBER 16 1988
Emergency Planning amp Response Branch Environmental Service Division
United States Environmental Protection Agency60 Westviev Street Lexington MA 02173
(617) 860-4300
Prepared By
Paul Groulx On-Scene Coordinator US Environmental Protection AgencyEmergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Date
TABLE OF CONTENTS
I INTRODUCTION
A Removal Action Summary 1 B Site History and Background 1 C Participating Organizations and
Personnel 4
II SITE ACTIVITIES
A Chronological Summary 5 B Effectiveness of Removal Action
and Recommendations 8 C EPA-Committed Resources 9 D Problems Encountered 10
III SUPPORTIVE DOCUMENTATION
A Work Plan 10 B Health and Safety 10 C Community Relations 11 D Enforcement 12 E Pollution Reports (POLREPS) 12
ii
LIST OF FIGURES
1 General Location Map Stamina Mills Site Forestdale Rhode Island
2 Site Map Stamina Mills Site (Site 27) Forestdale Providence County RI 3
1 v
iii
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
Prepared By
Paul Groulx On-Scene Coordinator US Environmental Protection AgencyEmergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Date
TABLE OF CONTENTS
I INTRODUCTION
A Removal Action Summary 1 B Site History and Background 1 C Participating Organizations and
Personnel 4
II SITE ACTIVITIES
A Chronological Summary 5 B Effectiveness of Removal Action
and Recommendations 8 C EPA-Committed Resources 9 D Problems Encountered 10
III SUPPORTIVE DOCUMENTATION
A Work Plan 10 B Health and Safety 10 C Community Relations 11 D Enforcement 12 E Pollution Reports (POLREPS) 12
ii
LIST OF FIGURES
1 General Location Map Stamina Mills Site Forestdale Rhode Island
2 Site Map Stamina Mills Site (Site 27) Forestdale Providence County RI 3
1 v
iii
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
TABLE OF CONTENTS
I INTRODUCTION
A Removal Action Summary 1 B Site History and Background 1 C Participating Organizations and
Personnel 4
II SITE ACTIVITIES
A Chronological Summary 5 B Effectiveness of Removal Action
and Recommendations 8 C EPA-Committed Resources 9 D Problems Encountered 10
III SUPPORTIVE DOCUMENTATION
A Work Plan 10 B Health and Safety 10 C Community Relations 11 D Enforcement 12 E Pollution Reports (POLREPS) 12
ii
LIST OF FIGURES
1 General Location Map Stamina Mills Site Forestdale Rhode Island
2 Site Map Stamina Mills Site (Site 27) Forestdale Providence County RI 3
1 v
iii
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
LIST OF FIGURES
1 General Location Map Stamina Mills Site Forestdale Rhode Island
2 Site Map Stamina Mills Site (Site 27) Forestdale Providence County RI 3
1 v
iii
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
Z BACKGROUND i
A Removal Action Summary
Operating under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) of 1980 as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986 (Pub L99-499) for a Removal Action Section 30065 of the National Contingency Plan EPA Region I Emergency Planning amp Response Branch utilized the Zone I Emergency Response Cleanup Services (ERCS) contractor OK Materials to abate the threat of continuing environmental contamination posed by two old deteriorated underground storage tanks at the Stamina Mills Site in Forestdale Rhode Island Site work was performed from Tuesday August 9 1988 through Friday August 12 1988 and on Wednesday November 16 1988 The removal action resulted in the disposal (recycling andor incineration) of all tank contents (oil water and sludge layers) the excavation and disposal of a 10000 gallon steel tank and the decontamination and closure of a 7500 gallon concrete tank The total cost for this action was $7212900 (estimated)
B Site History and Background
The Forestdale section of Rhode Island (Figure 1) was the site of a trichloroethylene (TCE) spill at the Stamina Mills Textile Company in 1969 In 1977 a fire destroyed the mill during which an additional 600-700 gallons of TCE may have been released At various times between 1969 and 1974 still bottoms derived from the mills solvent recovery system apparently were landfilled on-site As a result of these releases drinking water wells in the Forestdale area were contaminated with TCE and the site was placed on the National Priorities List (NPL) in September 1983 In 1984 the Agency learned that many families were continuing to use their contaminated wells and in November 1984 a removal action was begun to extend the existing municipal water supply to the affected area
During subsequent remedial investigations two abandoned deteriorated and potentially leaking underground storage tanks containing hazardous substances were located (Figure 2) The contents of these tanks were sampled and analyzed for PCBs and volatile organic compounds No PCBs were detected in the samples However volatile organics found in the underground tanks included toluene in one tank and ethylbenzene and xylene in both tanks
Although area residents are now being supplied with municipal water as a result of the removal action in 1984-1985 the presence of hazardous substances in the abandoned underground storage tanks represented a continued threat of introducing -mdashial -ontaminants to the groundwatsr andKsurface waiter -1
the Foiestdale area The tanks were situated 3list above a shallow groundwater table within fifty feet of the Branch River
1
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
BLACKSTONE MASS N4200mdashW713075
ite Location
v V N V v - - - laquo
Scale 1 =
FIGURE 1 General Location Map
DRAWN DATE PCS raquoStamina Mills Site Giustra 08268B 1529 Forestdale Rhode Island APPROVED DATE TOO bull
01-8807-14
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
enCM
O o
o CO2 o
O 00 00I
_Q)
CD o
cj o
(D 0)
c (D
(Drtfgt 00 o
L
CO Q_
CNJ 2-o deg
CO en CD
O U 00 00 LJshy
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
Immediate removal of the contents of these tanks was therefore necessary to ensure elimination of a source of continued contamination at the site and into the environment Additionally catastrophic failure resulting in rapid discharge from these old and deteriorated tanks could have significantly impacted future costs of site remediation The site is currently the subject of a remedial investigationfeasibility study (RIFS) to determine long-term remedial action under Superfund
On July 12 1988 an Action Memorandum requesting a waiver of the statutory one year time limit and additional funding to continue removal actions undertaken in 1984-1985 at Stamina Mills to mitigate the threat to the environment posed by the potentially leaking underground storage tanks was approved by EPA Regional Administrator Michael Deland The Action Memorandum called for the removal of the tank contents and any contaminated soil surrounding the tanks consistent with future remedial actions at the site The EPA Region I Emergency Planning amp Response Branch proceeded with removal activities under the direction of On-Scene Coordinator (OSC) Paul Groulx to ensure appropriate project completion
On July 14 1988 ERGS Delivery Order No 7445-01-017 was submitted to the prime contractor followed by meetings at the site on July 21 and July 29 1988 regarding the scope of the tank removal activities Jet Line Services Inc of Providence Rhode Island was subcontracted by OK Materials ERCS prime contractor to perform the actual tanksoil removal activities which began on August 9 1988 Liquid tank contents (approximately 11000 gallons) were taken to the Jet Line facility in Stoughton Massachusetts for recycling Approximately 1400 gallons of contaminated sludge material from the tanks were placed in 55-gallon drums for incineration at an off-site facility (ThermalKEM Rock Hill South Carolina) One underground storage tank a 10000 gallon steel tank was excavated decontaminated and removed from the site for disposal at the State Line Scrap facility in North Attleboro Massachusetts The second tank a 7500 concrete vault was decontaminated destroyed and backfilled on-site Work to secure the site was completed on August 12 1988 On November 16 1988 removal activities were completed when the drums containing sludge material were transported off the site
C Participating Organizations and Personnel
US Environmental Protection Agency Emergency Planning amp Response Branch Lexington MA
Paul Groulx On-Scene Coordinator Waste Management Division Boston MA
Rose Toscano Remedial Project Manager
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
US EPA Technical Assistance Team Roy F Weston Inc Burlington MA
Dennis P Glustra
RI Department of Environmental Management (RI DEM) Division of Air and Hazardous Materials Providence RI
Joseph Polselli EngineerPeter Sullivan Inspector
Prime Contractor OK Materials Company Findlay OH
Paul Street Supervisor II Jim Seliga Project Control Technician (PCT)
Subcontractors Jet Line Services Inc Providence RI
Walter Royley Contract Representative Ron Ciafarani Contract RepresentativeMark Bowen Foreman Greg MacDougall Equipment Operator Dave Gervais Equipment Operator Tom McLoughlin Laborer John Moore Laborer John Ross Laborer Greg Ciafarani Laborer PK Moore Laborer Charles Berry Equipment Operator
Grover Enterprises Raynham MA Marc Pollard Equipment Operator Ray Raggiani Equipment Operator
II SITE ACTIVITIES
A Chronological Summary
The following is a chronological summary of the events pertaining to the Stamina Mills underground storage tank removal action conducted in Forestdale Rhode Island
July 12 1988
An Action Memorandum requesting additional funding to continue removal activities at the Stamina Mills site was approved by EPA Regional Administrator Michael Deland
July 14 1988
ERCs Delivery Order No 7445-01-017 was submitted to the prime contractor OK Materials Company with a $150000 ceiling
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
July 21 1988
A meeting was held at the site between US EPA TAT RI DEM and OH Materials regarding the scope and scheduling of tank removal activities
July 26 1988
Additional samples of tank contents were obtained by the TAT and submitted to Rhode Island Analytical Warwick Rhode Island for total metal and flash point analyses Previous analyses on the tank contents included volatile organic and PCS parameters performed by the New England Regional Laboratory Lexington Massachusetts
July 29 1988
A meeting was held at the site between the TAT and Jet Line Services Inc the ERGS subcontractor chose to perform tank removal activities On-site utilities previously set up by GHR Engineering Associates Inc Lakeville Massachusetts (an EPA remedial contractor) were transferred to OH Materials for the duration of the removal action
August 4 1988
A Work Plan and Safety Plan were prepared by the TAT which outlined EPAs approval and procedures to be followed during the removal action
August 8 1988
OH Materials personnel (supervisor PCT) were mobilized to Rhode Island to manage the removal action under the direction of the EPA OSC
August 9 1988
Removal activities commenced ERGS subcontractor personnel and equipment from Grover Enterprises Raynham Massachusetts and Jet Line Services arrived at the site to begin work All liquid material from the underground concrete tank was pumped into a Jet Line vacuum trailer Excavation by Grover Enterprises around the underground steel tank revealed the top and sides of the tank An additional vacuum truck was brought on site to remove the contents of the steel tank Approximately 7400 gallons of liquid material were removed from both tanks manifested (MAC 427252 MAC 427253) and taken off the site to the Jet Line facility in Stoughton Massachusetts for reclamation andor treatment
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
August 10 1988
Jet Line personnel continued to pump liquid material from the bottom of the steel tank while sludge material from the bottom of the concrete tank was removed and placed in 55-gallon drums for disposal
August ll 1988
All remaining liquid and sludge material from the steel and concrete tanks was removed by the Jet Line crew The inside of both tanks were then cleaned The steel tank was pulled from the ground and placed in a stabilized area on site Closure of the steel tank was approved by Peter Sullivan of the RI DEM and the former tank location was backfilled and covered
Approximately 3300 gallons of liquid material which had been pumped into a Jet Line vacuum trailer were taken offsite for disposal in Stoughton Massachusetts (MAC 427254) A total of 26 drums of sludge material were staged on site to await disposal by incineration Composite samples of the sludge material from six drums were collected for future disposal analyses
August 12 1988
The excavated steel tank was further cleaned and taken off site for disposal at State Line Scrap in North Attleboro Massachusetts The inside of the concrete tank was inspected by OSC Paul Groulx and Jet Line Foreman Mark Bowen before being demolished in place (using a CAT 225 excavator) The former concrete tank area was then backfilled and both excavation areas regraded All contractor personnel and equipment were demobilized and the site secured Arrangements for the disposal of the 26 drums (containing sludge materials from the tanks) remained to be finalized by OK Materials
August 17 1988
All site utilities (office trailer telephone electric port-ashyjohn) were disconnected andor taken off site
September 30 1988
Composite samples of sludge material from the tanks were submitted to OH Materials for disposal analyses
October 24 1988
Sludge material was accepted for disposal by the ThermalKEM facility located in Rock Hill South Carolina
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
November 16 1988
The ERCS contractor was reactivated by the EPA OSC to complete removal actions at the site after disposal arrangements had finally been coordinated The 26 drums stored on the site were loaded onto a SJ Transportation Company trailer and transported to the ThermalKEM facility for disposal by incineration The removal action was thus completed and the site resecured
B Effectiveness of Removal Action and Recommendations
Initially to develop an appropriate scope of work and schedule the removal action the EPA OSC met with OH Materials and State of Rhode Island Department of Environmental Management representatives at the Stamina Mills Site Prior to the removal action limited information had been provided regarding the two underground storage tanks Tanks contents had been analyzed for PCBs volatile organics total metals and flash point but no information was found regarding actual tank construction or sizes
Jet Line Services also inspected the site prior to conducting removal activities Based on past experience Jet Line was able to develop a preliminary scope of work from the limited information available Although no significant problems were expected regarding the tank removals it was realized that certain contingencies could arise in the field which would complicate the removal action
Once work commenced no problems were encountered that altered the effectiveness of the removal action The successful completion of the removal action was aided by the information uncovered with respect to the individual tanks as the excavations were completed tank contents removed and tanks entered for inspection One tank was determined to be a 10000 gallon steel tank and the other a 7500 gallon concrete tank
In accordance with EPAs ban on land disposal all sludge material from the bottoms of the tanks was drummed for incineration at an off-site facility Circumstances at the time of the removal also made it possible for the steel tank to be taken off site for disposal Originally the excavated tanks were to be left on site after decontamination at a location designated by the OSC The condition of the steel tank which was inspected after being excavated indicated that the removal had been effective in eliminating a release of the tank contents into the environment Although no release had occurred the deteriorated state of the tank suggested that leakage was imminent if the tank had remained in the ground The concrete underground storage tank was found to be a solid reinforced structure with walls and flooring to be in good condition A
8
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
I1
I
i
1
J
J
portion of the ceiling of the tank had collapsed exposing the ground above Since the complete excavation of this tank was not
practical the tank was left in place The ceiling was collapsed entirely and the north wall destroyed to prevent collection of
water andor permit drainage prior to backfilling the tank area
In neither case was any contaminated soil found surrounding the underground storage tanks which required removal Additionally the manner in which both tanks were closed was approved by the State of Rhode Island Department of Environmental Management as well as the N Smithfield Fire Department Overall the removal action proved successful by working closely with the RI DEM and utilizing an experienced tank removal subcontractor such as Jet
Line Services Inc
C EPA Committed Resources
Resources committed to the Stamina Mills Site via additional funding requested in the Action Memorandum signed on July 12 1988 were as follows
1) Extramural Costs
Remove contents of two underground tanks $3000000 Analyze and incinerate waste liquid 8000000 Removedispose of contaminated soil if necessary 4000000 ERGS contingency (15) 2500000 TAT costs 2500000
Subtotal $20000000 Plus 15 Contingency 3000000
$23000000
2) Intramural Costs
Direct $1000000 Indirect 2000000
Subtotal $3000000
Total Project Cost $26000000 Plus 15 Contingency 4000000
TOTAL PROJECT INCREASE $30000000
3) Estimated Costs to Date
Removal Action - August 9-12 1988 November 16 1988
ERCS Costs $4892900 TAT Costs 1260000 EPA Obligation 1060000
Total Expended sect 7212900 Balance $22787100
9
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
D Problems Encountered
During removal activities no significant problems were encountered which affected the scheduling and completion of the work Cost tracking and the submission of accurate 1900-55 forms by OH Materials however did develop into problem areas Final ERGS costs presented in this report are estimated since no cost documentation has been provided to the EPA regarding the removal action since August 11 1988 including costs for subsequent site work await bills and drum disposal costs Additionally the costs which have been submitted were found by the EPA to be inaccurate and in excess of applicable contractor rates in some instances The performance of the prime contractor in this capacity has therefore been deemed unsatisfactory as indicated by the EPA OSC to OH Materials Inc under separate cover
III SUPPORTIVE DOCUMENTATION
A Work Plan
A Work Plan was prepared for the Stamina Mills Removal Action which outlined the US EPAs approach to the tank removals provided a statement of work listed the personnel involved and contained health and safety requirements The work plan was approved by the OSC prior to the commencement of work
In general the tank removal was recommended to follow the procedures outlined in the API Bulletin 1604 for the removal of used underground storage tanks (provided as an attachment to the work plan) The work plan however was subject to change as site conditions necessitated or if more efficient cost effective on-site methods were developed and approved by the OSC The project approach also required close tracking of ERCS contractor and subcontractor personnel materials and equipment costs
Health and safety standards were generally outlined and it was required of all field personnel to thoroughly review and understand each component of the detailed safety plan provided as an attachment to the work plan (see following section)
B Health and Safety
A Safety Plan was prepared for the tank removal activities at the Stamina Mills Site during August 9-12 1988 This safety plan was distributed to all appropriate personnel prior to the commencement of work The safety plan was also available for review by personnel entering the site during the removal action in order to understand and comply with its content
j
10
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
The purpose of this plan was to assign responsibilities to EPA and contractor personnel relative to safety and site security establish personnel safety and protection standards site
mandatory safety operating procedures relative to physical and chemical hazards encountered on the site distinguish various
zones of contamination establish decontamination procedures and i provide contingencies which may arise during the course of this
immediate removal action in accordance with 40 CFR 300-38 the National Contingency Plan (NCP) and OSHA proposed final standard 1910120 (Hazardous Waste Operations and Emergency Response)
Safety concerns at the Stamina Mills Site were directed towards the contact and inhalation hazard posed by the tank contents
i contaminated with volatile organics Specific concerns were also addressed towards working in confined spaces during cleaning and sludge removal of the tanks Secondary concerns involved the presence of Trichloroethylene (TCE) which is known to exist in the groundwater beneath the site However since the tanks were situated above the groundwater table and previous air monitoring at the site did not detect the presence of volatile organics in the ambient air TCE was not considered a major threat during this removal action
i Zones of contamination were therefore established directly around both tanks openings Entry to these zones were restricted to Jet Line Service personnel All contamination reduction and
j decontamination occurred within these areas Personal protective gear within these zones were typically dictated by the on-going activity and previous Jet Line experience consistent with the
j site safety plan
Routine safety requirements to be followed by all other personnel involved in the removal action outside of the contamination zones dictated that at a minimum the standard work uniform should consist of leather high-top steel-toed work boots slacks longsleeve shirts and cotton protective gloves During work with heavy equipment all personnel were required to maintain a safe distance and wear hard hats Upon leaving the tank areas during breaks or at the end of the day personal recommendations included brushing off any loose particles from clothing and immediately washing hands and face or showering
Finally it should be noted that heat stress did not pose a problem during the removal action despite high daily
1 temperatures Routine break periods shade breezes and a large supply of drinking water reduced the chances of heat stress
1 occurring This and other safety concerns were discussed with the Jet Line Foreman on a daily basis
C Community Relations
fcfc Apprcp-1 commur mdash-Morlt were maintained on the loc-1 state and federal levels during the tank removal activities at
11
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
the Stamina Mills Site North Smithfield Fire Marshall Tom Dybala was contacted prior to the removal action to serve as Emergency Coordinator as outlined in the site safety plan The North Smithfield Fire Department was represented on the site during each day of the removal by either Fire Marshall Dybala or Fire Chief Ed Canvoyver The excavated locations of the former underground storage tanks within the North Smithfield area are typically required to be inspected by the fire department prior to closure Frank Church Town Administrator was also informed of the removal prior to the commencement of work and was routinely on the site to receive status reports and witness the progress of work Additionally pollution reports (POLREPs) were distributed to the town administrators office and fire department as they were generated Public coverage was also provided by a local newspaper on the day of the steel tank excavation and removal
Personnel from the RI DEM were also routinely on the site to check the status of the tank removals Joe Polselli Division of Air and Hazardous Materials served as the state representative for the site and has been involved with remedial activities as well as this removal action Final inspection and permission for tank closure was provided by Peter Sullivan of the RI DEM
The EPA Remedial Project Manager Rose Toscanp was kept informed of progress at the site on a regular basis by the EPA OSC During the on-going remedial activities the Stamina Mills Site has generated a great deal of public awareness Formal community relations have been the responsibility of the Remedial Office which has held periodic meetings between concerned groups and the EPA as well as issuing press releases through public affairs
D Enforcement Strategy
Efforts conducted thus far have failed to result in responsible party assumption of cleanup liability and the OSC determined that removal of the contents of these tanks must take place as expeditiously as possible The State of Rhode Island was presently constrained and unable to undertake the removal activity Additionally no remedial actions were planned to deal with the underground storage tanks In light of the above facts the EPA Emergency Planning amp Response Branch performed the removal action described in this report This removal action subject to cost recovery has been entirely consistent with any future remedial activities which may take place at the Stamina Mills Site
E Pollution Reports (POLREPS 1
During the continuation of removal activities at the Stamina Mills Site involving the underground storage tanks 4 POLREPs
bull - ^ner^ted documenting the current -site situation actimdash
12
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
taken to date future plans and cost information These POLREPs were distributed to the National Response Center and appropriate US EPA personnel as well as state and local officials involved in the removal action As such pollution reports are a concise way of presenting site information during response activities under the NCP The Stamina Mills case was officially closed on January 18 1989
13
