phase i environmental site assessment update adams paper ...as of the date of this report, the site...
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Phase I Environmental Site Assessment Update
Adams Paper Company 15 Mill Street (Route 302)
Wells River, Vermont VTDEC Site #VT2007-3651
July 30, 2008
Prepared for:
Vermont Department of Environmental Conservation Waste Management Division
103 South Main Street/ West Building Waterbury, Vermont 05671-0404
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont i July 2008
EXECUTIVE SUMMARY
The Johnson Company, Inc. of Montpelier, Vermont (JCO) was retained by the Vermont Department of Environmental Conservation (VTDEC) on behalf of Gene Eastman of Green Mountain Monogram (prospective purchaser, the User) to conduct an update of a Phase I Environmental Site Assessment (ESA) of the Adams Paper Company site located at 15 Mill Street in Wells River, Vermont. The report being updated is a Phase I ESA that was generated by Weston and Sampson Engineers, Inc. in September 2007. Since the previous ESA was performed more than 180 days prior to the anticipated closing date on the property, portions of the Phase I ESA require updating under ASTM 1527-05 and All Appropriate Inquiries (AAI) protocol. This ESA Update was performed in general accordance with the American Society for Testing and Materials' Standard Practice for Environmental Site Assessments (E 1527-05). This ESA Update included determining the Site's regulatory status, contacting appropriate personnel regarding past and present uses of the Site, researching the existence of any liens associated with environmental cleanup, investigating the potential for past releases of petroleum products and/or hazardous materials on the Site using federal state and local records, and conducting a site reconnaissance to visually inspect accessible portions of the Site to ascertain the presence of recognized environmental conditions in the form of past, present or potential release(s) of hazardous materials or petroleum products. As of the date of this report, the Site is listed as Active Hazardous Waste Site # VT2007-3651 by the VTDEC due to the presence of PCBs, dioxins, VOCS and metals in soil, which are likely also present in groundwater and associated building debris. The Site was not listed on the Federal National Priority List (NPL) as a Superfund Site. The Site was not listed as a hazardous waste site on the federal Comprehensive Environmental Response Compensation and Liability Information System (CERCLIS). Neither the VTDEC nor the United States Coast Guard National Response Center databases have any record of spills of hazardous materials occurring on the Site. The Site is not listed as a generator of hazardous substances, nor were any adjacent properties identified as generators. The Site is not a VTDEC permitted underground storage tank (UST) facility. A site reconnaissance was conducted by The Johnson Company on July 8, 2007. The Site reconnaissance included an inspection of the interior and exterior portions of the both buildings on the property. Evidence of spills, staining and releases of petroleum products and/or hazardous materials were observed. Additionally, a considerable quantity of building and associated industrial debris exists throughout the majority of the building, some of which is suspected to contain hazardous materials or is coated with dust that may also contain regulated contaminants. This Phase I ESA Update, performed in general conformance with the scope and limitations of ASTM E 1527-05 in compliance with 40 CFR Part 312, Standards and Practices for All Appropriate Inquiries, of the Adams Paper Company at 15 Mill Street in Wells River, Vermont has revealed evidence of recognized environmental conditions (RECs) associated with the Site.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont ii July 2008
Based on the findings of this Phase I ESA Update and the previous investigatory efforts at the Site, The Johnson Company recommends a Corrective Action Feasibility Investigation (CAFI) and Corrective Action Plan (CAP) be developed in accordance with the VTDEC guidelines to address the following RECs at the Site:
• The soil is impacted approximately 50-feet south of the former mill building presumably from a release associated with the former 14,400-gallon UST previously located in this area. The tank was reportedly removed in the late 1980s and remains on the property near the southeast corner of the building. It is suspected that the groundwater has also been impacted by this release. Recommendation: Excavation of the contaminated soil has proven impractical, the Site is serviced by a municipal water source, and the relatively low concentrations of VOCs in the soil present a minimal risk of impacting indoor air quality. Therefore, it is recommended that a notice to the land records be filed in the Newbury Town Land Records identifying this REC. Additionally, the tank should be emptied, cleaned, and disposed of in accordance with Vermont UST Closure Guidelines.
• The 1,000-gallon UST remaining on the property along the southern exterior wall of the former mill building may pose further risk of impacting the soil and groundwater at the Site. Recommendation: If it is determined by the property owner that this 1,000-gallon UST is no longer in use, the tank should be decommissioned because the VTDEC UST Program requires that abandoned USTs be closed in accordance with State UST Closure Guidelines.
• Five inactive transformers, three of which have been proven to contain PCBs, remain
outside the southwest corner of the former mill building. PCBs were also detected in soil and concrete below the platform that holds these transformers. A second concrete pad with cut wires mounted on the warehouse building immediately above was noted approximately 15-feet to the northwest of the exterior transformer bank. It is possible this pad may have a previously housed a transformer. No indication of staining or stressed vegetation was observed.
Recommendation: All out of service, PCB-containing transformers must be removed from the property in accordance with Toxic Substances Control Act (TSCA) regulations. Additionally, it appears that the PCB impacted soil and concrete beneath these transformers requires further delineation in accordance with TSCA regulations. These results will be used to determine the appropriate remedial actions.
• Debris that may contain hazardous material was observed in both the former mill building and the warehouse. This material included approximately 14 drums and several cans and buckets of possibly hazardous liquids. Other surfaces and materials inside and around the building may be contaminated with dioxins or PCBs.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont iii July 2008
Recommendation: A qualified environmental contractor should inventory the materials in the drums and containers in both the former mill building and the warehouse and dispose of this material in accordance with State guidelines. Additional sampling inside the building is recommended to determine the distribution and levels of suspected contaminants, with particular attention paid to dioxins and PCBs. The results will be used to determine potential remedial actions.
• Indoor air quality inside the former mill building may be impacted by residual dioxin contamination.
Recommendation: Indoor air monitoring should be performed to determine the impact, if any, on the indoor air quality within the former mill building.
• The Oil and Lubricant Storage Room located west of the Machine Room on the first basement of the former mill building contained approximately five 55-gallon drums and several buckets with dark stains. A thick, viscous material which appeared to be a petroleum product of some sort had coated the majority of the floor. Previous wipe sampling of the floor has indicated that this oily substance contains residual PCBs.
Recommendation: Following the removal and disposal of the contents in the Oil and Lubricant Storage Room, a qualified environmental contractor should clean all surfaces of the room... Additional sampling for PCBs may be required in advance of cleaning to determine solvent disposal requirements. If cleaning proves impractical, demolition and disposal of this storage room may be an option.
• Sediment sampling during previous investigations have indicated detectable levels of metals, dioxins, furans, and PCBs in several of the seven floor/sink drains noted throughout the former mill building. These drains lead directly to the Wells River without treatment and pose a risk to surface water should future releases take place in the building.
Recommendation: Prior to any clean-up effort a qualified environmental contractor should remove and properly dispose of all sediment from the seven drains identified in the former mill building. Additionally, these seven drains, which presumably lead directly to the Wells River, should be decommissioned so this pathway is eliminated.
• During the 2008 Supplemental Investigation, PCBs were detected using wipe samples on the surface of the interior transformer area / electrical bank and wood floor. PCBs were also detected in the concrete pad below the transformer by analyzing samples of the pulverized concrete. The oil-filled switches mentioned in the 2007 Weston and Sampson report were noted immediately to the north of the interior electrical bank along the wall, and may contain residual PCB oil.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont iv July 2008
Recommendation: All surfaces associated with the interior transformer including the switches along the wall, and the wood and concrete floor should be sampled and analyzed for PCBs using a bulk sampling method. Additionally, JCO recommends the interior transformer and the associated equipment be taken offsite and disposed of properly.
• Previous laboratory analysis of the white pulpy material caked onto walls, pipes and equipment at various locations in the first and sub-basements in the former mill building has detected dioxins and furans in the material. These data should be used in determining the appropriate management method for this bulk waste.
Recommendation: JCO recommends the pulp slurry waste be removed and disposed of off site in accordance with VTDEC regulations prior to commencement of the building renovations. Additional wipe sampling of other surfaces or equipment in these basements should be conducted for dioxins and PCBs.
• Considering the buildings age, it is likely that lead paint and asbestos containing material remain at the Site.
Recommendation: JCO recommends both lead paint analysis and an asbestos inspection be performed at the Site prior to commencement of future building renovations or demolition.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont v July 2008
TABLE OF CONTENTS
1.0 INTRODUCTION.................................................................................................................. 1 2.0 SITE DESCRIPTION............................................................................................................ 3 3.0 SITE HISTORY AND REVIEW OF EXISTING INFORMATION................................ 3
3.1 Historical Review............................................................................................................ 3 3.1.1 Land Records .............................................................................................................. 3 3.1.2 Environmental Questionnaire ..................................................................................... 3
3.2 Interviews........................................................................................................................ 3 3.2.1 Current Owner/Occupant ............................................................................................ 3 3.2.2 Occupant ..................................................................................................................... 4 3.2.3 State/Local Officials ................................................................................................... 4 3.2.4 Neighboring or Nearby Property Owner/Occupant .................................................... 4
3.3 Prior Investigations ......................................................................................................... 4 3.4 USER RESPONSIBILITIES .......................................................................................... 5
4.0 REGULATORY STATUS .................................................................................................... 5 4.1 Environmental Liens....................................................................................................... 5 4.2 Federal Regulatory Files ................................................................................................. 6
4.2.1 Federal National Priority List (NPL) .......................................................................... 6 4.2.2 Comprehensive Environmental Response, Compensation and Liability Information
System (CERCLIS) List ............................................................................................. 6 4.2.3 Federal Resource Conservation and Recovery ACT (RCRA) Generators ................. 6 4.2.4 RCRA Treatment, Storage and Disposal (TSD) Facilities ......................................... 7 4.2.5 Federal Institutional Control/Engineering Registries ................................................. 7 4.2.6 Federal Emergency Response Notification (ERNS) List............................................ 7
4.3 State/Tribal Regulatory Files .......................................................................................... 7 4.3.1 Hazardous Sites List ................................................................................................... 7 4.3.2 Underground Storage Tank List.................................................................................. 9 4.3.3 Spills List .................................................................................................................... 9 4.3.4 Landfills ...................................................................................................................... 9 4.3.5 Institutional Controls/Engineering Controls Registries .............................................. 9 4.3.6 Voluntary Cleanup Sites ............................................................................................. 9 4.3.7 Brownfield Sites.......................................................................................................... 9
4.4 Local Regulatory Files.................................................................................................... 9 4.4.1 Fire Department .......................................................................................................... 9 4.4.2 Local/Regional Health Officer.................................................................................. 10 4.4.3 Local Electric Utility Company (Polychlorinated biphenyls) .................................. 10
4.5 Non-AAI/ASTM Scope Considerations ....................................................................... 11 4.5.1 Asbestos and Lead Paint Issues ................................................................................ 11
5.0 SITE RECONNAISSANCE................................................................................................ 11 5.1.1 Former 14,400-gallon No. 6 Fuel Oil Underground Storage Tank........................... 12 5.1.2 Existing 1,000-gallon No. 2 Fuel Oil........................................................................ 12 5.1.3 Exterior Transformer Banks ..................................................................................... 12 5.1.4 Riverbed Sediments .................................................................................................. 13
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont vi July 2008
5.2 INTERIOR OBSERVATIONS .................................................................................... 13 5.2.1 Hazardous Materials ................................................................................................. 13 5.2.2 Oil & Lubricant Storage Room................................................................................. 14 5.2.3 Floor Drains .............................................................................................................. 14 5.2.4 Interior Transformer / Electric Supply Bank ............................................................ 14 5.2.5 Pulp Slurry Bulk Waste ............................................................................................ 15
6.0 CONCLUSION AND RECOMMENDATIONS............................................................... 15 7.0 DATA GAPS/LIMITATIONS............................................................................................ 19
7.1 DATA GAPS ................................................................................................................ 19 7.2 LIMITATIONS............................................................................................................. 19
8.0 REFERENCES CITED....................................................................................................... 20 LIST OF FIGURES Figure 1 Site Location Map......................................................................................................2 LIST OF APPENDICES Appendix 1 Environmental Professional Resumes Appendix 2 Environmental Questionnaire Appendix 3 Photographic Plates Appendix 4 User Questionnaire Appendix 5 Weston & Sampson Phase I ESA, September 2007 Appendix 6 Strategic Environmental, LLC. Supplemental Environmental
Investigation, April 4, 2008 Appendix 7 Figures and Tables from Previous Reports
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 1 July 2008
1.0 INTRODUCTION
The Johnson Company, Inc. of Montpelier, Vermont was retained by the Vermont
Department of Environmental Conservation (VTDEC) on behalf of Gene Eastman of Green
Mountain Monogram (prospective purchaser, the User) to conduct an update of a September
2007 Weston and Sampson Engineers, Inc. (W&S) Phase I Environmental Site Assessment
(ESA) of the Adams Paper Company site located at 15 Mill Street in Wells River, Vermont (the
Site). The Adams Paper Company is an active VTDEC hazardous site with ID number VT2007-
3651. The location of the Site is depicted in Figure 1.
Based on information provided by the VTDEC, it is the understanding of JCO that this
investigation may support the redevelopment and reuse of the Site for commercial purposes.
The purpose of the ESA Update was to identify recognized environmental conditions
associated with the Site that indicate the presence or likely presence of hazardous substances or
petroleum products under conditions that indicate an existing release, past release, or a material
threat of a release associated with the property. This ESA Update included contacting
appropriate personnel regarding current and past uses of the Site, reviewing existing information
made available and/or that was reasonably ascertainable regarding current and past usage of the
property, determining the Site’s regulatory status, investigating the potential for past releases of
petroleum products and/or hazardous substances on the Site, and conducting a reconnaissance to
visually inspect the accessible portions of the Site.
This ESA was performed by personnel from JCO who meet the definition of
Environmental Professional as defined in 40 CFR Part 312, in general conformance within the
scope and limitations of ASTM E 1527-05 and in compliance with 40 CFR Part 312, Standards
and Practices for All Appropriate Inquiries. Credentials of the Environmental Professionals from
JCO involved with the conduct of this ESA are included as Appendix 1.
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LOCATION
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Montpelier, VT 05602
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100 State Street, Suite 600
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Figure 1. Site Location MapAdams Paper CompanyWells River, Vermont
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 3 July 2008
2.0 SITE DESCRIPTION
The Site is located on the northern side of Mill Street (Route 302) approximately 1,000 feet northwest of the Wells River town center, and is situated atop the steep southern bank of the Wells River. The Adams Paper Company property comprises 1.6 acres of land. The land surrounding the property is largely forested with mixed vegetation, including tall grasses, surrounding the two main buildings on the property. A mixed use, residential and commercial building is located less than ¼ -mile to the east of the Site. The Site and host vicinity are depicted on the W&S Figure 2 in Appendix 7.
The Wells River flows from west to east past the Site and joins the Connecticut River
approximately 1,800 feet down-stream.
3.0 SITE HISTORY AND REVIEW OF EXISTING INFORMATION
3.1 HISTORICAL REVIEW
3.1.1 Land Records Ms. Susan Underwood of the Newbury Town Clerk’s Office indicated that the Site is
currently owned by Fernand Fournier and no land transactions have taken place with respect to
the property since September 2007 (date of original W&S Phase I ESA).
3.1.2 Environmental Questionnaire The Johnson Company’s standard environmental questionnaire was completed by the
prospective purchaser, Mr. Gene Eastman, and was received via fax by JCO on July, 10, 2008.
The completed questionnaire is included in Appendix 1.
3.2 INTERVIEWS
3.2.1 Current Owner/Occupant Mr. Fernand Fournier, the current owner, was contacted on July 9, 2008 regarding the
Site. Mr. Fournier indicated the nothing has changed at the Site since the previous Phase I ESA
was performed.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 4 July 2008
3.2.2 Occupant Mr. Glenn O’Connor was interviewed as part of this ESA. Mr. O’Connor is an Enel
North America, Inc. employee who performs daily maintenance of the hydroelectric equipment
associated with the Site. Mr. O’Connor provided access to portions of the property associated
with the hydroelectric power generation which actively takes place at the Site. Mr. O’Connor
identified some lubricating oil he uses to maintain the equipment and some small leaks in the
system that have caused rust to form, resulting in a small amount of pooled, orange water. Mr.
O’Connor was unaware of any additional recognized environmental conditions associated with
the Site, beyond what had been addressed in the previous Phase I ESA.
3.2.3 State/Local Officials Patricia Coppolino of the VTDEC is the Site Manager for the Adams Paper Company
site. Ms. Coppolino provided several documents to JCO for review, including previous Phase I
and Phase II ESAs, and letters from the VTDEC requesting further investigatory work and
corrective action.
Attempts to contact the Wells River Fire Chief, Jeff Morin, requesting any emergency
response information for the Site were not successful.
The Wells River Health Officer Renee Schulze was contacted regarding emergency
response information for the Site (see Section 4.4.2).
3.2.4 Neighboring or Nearby Property Owner/Occupant Neighboring property owners were not contacted for the purposes of this ESA Update
because the current owner and occupants were interviewed.
3.3 PRIOR INVESTIGATIONS Several environmental investigations have taken place at the Site prior to The Johnson
Company’s involvement. JCO has reviewed the following three reports associated with the
previous investigatory work performed at the Site:
a. W&S Phase I ESA Report dated September 2007.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 5 July 2008
b. Strategic Environmental, LLC (SEL) Limited Phase II ESA dated May 2, 2007
c. SEL Supplemental Environmental Investigation dated April 4, 2008.
3.4 USER RESPONSIBILITIES In order to qualify for one of the Landowner Liability Protections (LLP) offered by the
Small Business Liability Relief and Brownfields Revitalization Act of 2001, the user must provide the following information (if available) to the environmental professional:
1. Environmental cleanup liens that are filed or recorded against the Site;
2. Activity and land use limitations that are in place on the Site or that have been filed or recorded in a registry;
3. Specialized knowledge or experience of the person seeking to qualify for the LLPs;
4. Relationship of the purchase price to the fair market value of the property if it were not contaminated;
5. Commonly known or reasonably ascertainable information about the property;
6. The degree of obviousness of the presence or likely presence of contamination at the property and the ability to detect the contamination by appropriate investigation.
All of the information listed above was addressed by Mr. Gene Eastman, the prospective
purchaser, of Green Mountain Monogram and provided to The Johnson Company. A copy of a completed User Questionnaire pertaining to the Site has been included with this report as Appendix 4.
4.0 REGULATORY STATUS
4.1 ENVIRONMENTAL LIENS The September 2007 W&S Phase I ESA makes no mention of any environmental cleanup
liens associated with the property. Additionally, Ms. Coppolino of the VTDEC indicated that the
neither the Vermont Agency of Natural Resources nor the United States Environmental
Protection Agency (EPA) has placed a lien on the property. The Town Clerk of Newbury, Ms.
Susan Underwood was contacted regarding the environmental lien status of the property but was
unable to provide any information associated with liens via telephone.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 6 July 2008
4.2 FEDERAL REGULATORY FILES
4.2.1 Federal National Priority List (NPL) According to the EPA’s website, as of April 11, 2008 the Site is not listed on the National
Priority List (NPL) as an active site (EPA, 2008a). Also no properties within a 1-mile search
radius of the Site appear on the Final NPL list.
4.2.1.1 Delisted NPL Sites Neither the Site nor any other properties within the 0.5 mile search radius are
delisted NPL sites (EPA, 2008b).
4.2.2 Comprehensive Environmental Response, Compensation and Liability Information System (CERCLIS) List
As of February 1, 2008, the Site does not appear on the CERCLIS list. No other
CERCLIS sites are located within a 0.5 mile search radius of the Site (EPA, 2008a).
4.2.2.1 No Further Remedial Action Planned (NFRAP) Site List Neither the Site nor any sites within a 0.5 mile search radius are listed as
CERCLIS sites with a no further remedial action planned (NFRAP) status (EPA, 2008a).
4.2.3 Federal Resource Conservation and Recovery ACT (RCRA) Generators The Site is not included on the June, 2006 RCRIS list, nor are any adjoining properties
(EPA, 2006). Two conditionally exempt, small quantity, active RCRA Generators (Bradford Oil
VTR000514273, and VT Agency of Transportation VTD982762528) were identified to be on
US Route 302 in Newbury, although their exact addresses were not provided, thus making their
relative distance to the Site uncertain.
4.3.3.1 RCRA Corrective Action Sites (CORRACTS) List The Site is not on the list of RCRA Corrective Action sites for New England (last
update June 5, 2008), nor is any property within a one-mile search radius of the Site
(EPA, 2008c).
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 7 July 2008
4.2.4 RCRA Treatment, Storage and Disposal (TSD) Facilities There are no non-CORRACTS transportation and disposal (TSD) facilities listed within a
0.5 mile search radius of the Site (EPA, 2006).
4.2.5 Federal Institutional Control/Engineering Registries As of the date of this report, the EPA is still developing the Institutional Controls
Tracking System; as such, the system had not yet been implemented (EPA, 2007).
4.2.6 Federal Emergency Response Notification (ERNS) List According to the July 9, 2008 ERNS list, there have been no spills or releases of
hazardous materials or petroleum products specifically reported at the Site (NRC, 2008).
However, the ERNS report did indicate an August 1993 release of an unknown liquid into the
Wells River from a business located on Route 302. The incident report references H Q Taylor as
a possible responsible party.
4.3 STATE/TRIBAL REGULATORY FILES
4.3.1 Hazardous Sites List The Adams Paper Company is listed on the Vermont Active Hazardous Sites list as Site #
2007-3651 (ANR, 2008a and ANR, 2008b).
The VTDEC determined the Site to be an Active Hazardous Site in their June 5, 2007
letter, following a limited Phase II ESA performed by SEL, which identified petroleum-related
VOCs, PCBs, metals, and dioxin in soils and sediments associated with the Site. Following the
limited Phase II ESA, SEL generated a report dated April 4, 2008 entitled “Supplemental
Environmental Investigation,” which was intended to address the data gaps remaining at the Site
identified in the June 5, 2007 VTDEC letter. In response to the Supplemental Environmental
Investigation the VTDEC issued a letter dated May 14, 2008 to Mr. Gene Eastman identifying
the corrective action plan requirements remaining at the Site associated with the following
recognized environmental conditions:
a. Residual soil contamination associated with the former 14,400-gallon No. 6 fuel
oil UST.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 8 July 2008
b. Hazardous material throughout the building which include drummed liquids,
equipment likely containing hazardous substances, possible asbestos-containing
material, lead based paint, residual paper pulp, contaminated building materials
(concrete floors walls and wooden floor boards), and deposited contaminated
dust.
c. Residual PCB-containing oil and grease on walls and the floor of the Oil and
Lubricant Storage Room.
d. Contaminated sediment remaining in all floor drains to be removed and disposed
of.
e. The PCB-containing exterior surface and the wood and concrete surfaces below
the inactive transformer bank mounted in the first basement inside the building.
f. The PCB-containing soils beneath the two inactive transformers mounted on the
western exterior wall of the former Mill Building.
g. Dioxin-containing residual pulp slurry in the white water return chest (sub-
basement level), on the west wall of the machine room (first basement level), the
machine pit trench, the parts room floor drain, and likely other piping associated
with the facility’s former operations.
Two additional Active Hazardous Sites are located within a 1 mile radius of the Site:
Jiffy Mart (#951808) and WE Jock Oil Co. (#972180). Both of these sites are impacted with
petroleum contamination in soil and groundwater and are considered to be low priority according
to the VTDEC database. Since they are both greater than 0.5 mile from the Site and presumably
hydraulically down gradient, it is unlikely that their presence would have significant
environmental impact on subsurface conditions at the Site.
Additionally, two State of Vermont Closed Hazardous Sites (Baldwin Block Housing #
20012945 and HO Taylor Chevrolet #890368) were listed on the Vermont GIS Hazardous Waste
Locator within a 1 mile radius of the Site and likely pose no risk of impacting the Adams Paper
Company property (ANR, 2008a; ANR, 2005a).
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 9 July 2008
4.3.2 Underground Storage Tank List According to the VTDEC’s files, there are no currently permitted underground storage
tanks (USTs) at the Site (ANR, 2007b; ANR, 2005b). However, during the July 8, 2008 site reconnaissance four tanks (a 14,400-gallon AST, a 1,000-gallon UST, and two 4,000 gallon ASTs) were identified. These storage tanks and former contents are described in greater detail in the September 2007 Phase I ESA which was generated by W&S (see Appendix 5).
4.3.3 Spills List The Vermont ANR’s spills database does not list any spills having been reported at the
Site (ANR, 2008c).
4.3.4 Landfills There are no certified active landfills within a 0.5 mile search radius of the Site (ANR,
2005c). According to the EPA Envirofacts TRI database an inactive landfill, Longmoore
Landfill, was formerly located on US Route 302 in Newbury; however, no further information
regarding this landfill was available (EPA, 2008a).
4.3.5 Institutional Controls/Engineering Controls Registries According to the ANR’s Environmental Interest Locator, there are no Land Use
Restrictions applied to this Site (ANR, 2008a).
4.3.6 Voluntary Cleanup Sites Vermont does not maintain separate records of voluntary cleanup sites beyond active and
closed hazardous sites and Brownfield sites.
4.3.7 Brownfield Sites This Site is enrolled in the Vermont Brownfield program (# 2007-3651). No other
Brownfield sites are located within a ½ mile search radius of the Site (ANR, 2008d).
4.4 LOCAL REGULATORY FILES
4.4.1 Fire Department An attempt to contact Chief Jeffery Morin of the Wells River branch of the Newbury
Volunteer Fire Department was unsuccessful. Mr. Morin did not return the phone call placed to
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 10 July 2008
the barracks requesting comment regarding hazardous material or petroleum release incidents at
the Site (Muller, 2008a).
4.4.2 Local/Regional Health Officer In a phone message received on July 9, 2008, Ms. Renee Schulze (the Town of Newbury
Health Officer) indicated that she had not responded to and was not aware of any incidents at the
Site related to the release of hazardous material (Muller, 2008b).
4.4.3 Local Electric Utility Company (Polychlorinated biphenyls) The July 8, 2008 site reconnaissance visit confirmed the presence of the 12 transformers
at the Site identified in the W&S September 2007 ESA. Of the 12 transformers, 11 are outside
the former mill building and six of the 11 appear to currently be functioning. Of the six
functioning transformers, three (mounted on GMP Pole# 99/01) are located immediately to the
south of the former mill building and are presumably associated with the power source entering
the building from the grid. The other three functioning transformers (partially mounted on GMP
Pole# 100/01) are located at the southeast corner of the mill building and are presumably
associated with the functioning power generation from hydroelectric power equipment in the
building. Both sets of the functioning transformers appeared in good condition with no
indications of leakage. Mr. Steven Blood of Green Mountain Power (GMP) was contacted on
July 14, 2008 and confirmed that the three transformers mounted on Pole# 99/01 were installed
in 1985 and are free of PCBs. Mr. Blood also indicated that the bank of three mounted to Pole #
100/01 were customer owned and therefore GMP does not maintain records of them. Mr. Blood
indicated that Pole # 100/01 was installed in 1983 (Muller, 2008c).
The five transformers that appeared to be off line were located outside the southwest
corner of the mill building. Previous investigation by SEL indicated the presence of oil
containing PCBs at concentrations above 50 parts per million (ppm) in three of these
transformers. No information regarding the interior transformer / electric supply bank was
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 11 July 2008
available from the Green Mountain Power representative. Observations of the interior
transformer are documented in Section 5.2.3.
4.5 NON-AAI/ASTM SCOPE CONSIDERATIONS
4.5.1 Asbestos and Lead Paint Issues Although testing for both asbestos containing materials (ACM) and lead paint was not
part of the scope of this ESA Update or previous ESAs, it is likely based on the age of the
building that both ACM and lead paint were used in the building. In 2003, as part of the W&S
ESA, Op-Tech Environmental Services identified and removed 160 linear feet of ACM from the
warehouse building. This action was likely the result of the illegal asbestos disposal activities
that allegedly took place at the Site between 1999 and 2001, as described in the 2007 W&S
report.
5.0 SITE RECONNAISSANCE
A Site walkover was conducted on July 8, 2008 by Kurt Muller of The Johnson
Company, Inc., and Ms. Patricia Coppolino of the VTDEC. Conditions on this day were clear
and humid with a temperature of approximately 85 degrees Fahrenheit. Site conditions are
documented in the photo plates included as Appendix 3 of this report. The Site reconnaissance
included an inspection of the former mill building, the storage warehouse and limited inspection
of the grounds,
5.1 EXTERIOR OBSERVATIONS
The reconnaissance of the Site’s exterior portions focused on the previously identified
recognized environmental conditions (RECs), but also included a limited inspection of the land
surrounding the buildings, and a visual inspection of the area adjacent to the hydroelectric dam
and downstream portions of the Wells River where sediment samples were previously collected.
The following RECs remain in the exterior portions of the Site (see Photographic Plates in
Appendix 3, and the W&S and SEL Tables and Figures in Appendix 7).
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 12 July 2008
5.1.1 Former 14,400-gallon No. 6 Fuel Oil Underground Storage Tank A large out-of-service UST, presumably the 14,400-gallon tank described in earlier
reports, was located against the southeast corner of the former mill building. The former UST,
although rusted, appeared in relatively good condition with only minor pitting and no obvious
holes. According to the previous reports prepared for the Site there was likely a release of
product associated with this former UST which has impacted the soil quality in the vicinity of the
tank grave. The extent of contamination and the degree of impact to soil could not be fully
ascertained due to the presence of a high voltage power line buried in the immediate vicinity of
the contaminated area. Although the extent of impacts to groundwater has not been assessed,
SEL reported that a sheen was present on the surface of the groundwater to the north and
northeast of the former tank location. No staining or noticeable areas showing stressed
vegetation was observed in the area of the former tank grave.
5.1.2 Existing 1,000-gallon No. 2 Fuel Oil The vent and fill pipe, presumably from the existing 1,000-gallon UST described in the
September 2007 W&S ESA was identified on the south side of the former mill building. No
odors were present in the vicinity of theses pipes, nor were stains or stressed vegetation
observed.
5.1.3 Exterior Transformer Banks Of the 11 transformers located outside the buildings, three have been confirmed to
contain PCBs at concentrations above 50 ppm according to the previous reports. The three
transformers of concern are situated among the five that appeared to be off line outside the
southwest corner of the mill building.
A concrete pad with cut wires mounted on the exterior wall of the northeast corner of the
warehouse storage building is located approximately 15-feet to the northwest of the bank of five
exterior transformers. It is possible this pad may have previously housed a transformer.
Although this separate pad was covered with approximately ½-inch of soil and vegetation, no
staining was observed.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 13 July 2008
The two additional banks of three pole mounted transformers described in Section 4.4.3
are reportedly free of PCBs and appeared to be in relatively good condition
5.1.4 Riverbed Sediments The area of riverbank and sediment sampled by SEL during the January 2007 Phase II
ESA is located immediately under the most easterly floor drain outlet pipe along mill building’s
northern exterior wall. The area is currently vegetated and would be extremely difficult to access
via heavy equipment, due to the steep bank above. Results from previous river bank and
sediment sampling efforts have indicated detections of dioxin and arsenic. These detections did
not exceed the limits recognized by the State of Vermont for dioxins, which have been adopted
from the State of New York references and the Wisconsin Department of Natural Resources
standards. Additionally, arsenic concentrations in the river bank and sediment samples did not
exceed the Region IX PRGs for industrial properties.
5.2 INTERIOR OBSERVATIONS Safely accessible areas in both buildings were briefly inspected as part of this Phase I
ESA Update, including the area deeded to Enel North America for hydroelectric power
generation. A large quantity of debris and equipment from the former facility operations remains
in both the mill building and warehouse, some of which appears to contain or be coated with
hazardous materials and/or petroleum products. Previous investigatory efforts at the Site have
identified the following areas of concern which were observed during the site walkover (see
Photographic Plates in Appendix 3, and Tables and Figures in Appendix 7).
5.2.1 Hazardous Materials Debris that may contain hazardous material was observed in both the former mill
building and the warehouse. These items included approximately 14 drums and several cans and
buckets of possibly hazardous liquids. These containers were inventoried in the September 2007
W&S Phase I ESA (see W&S Table 1 in Appendix 7).
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 14 July 2008
In addition to the containers containing hazardous materials the former use of PCB-
containing oils and the generation of dioxins and furans during industrial processes may have
resulted in the presence of these contaminants in or around the buildings.
5.2.2 Oil & Lubricant Storage Room This room is located west of the machine room on the first basement of the former mill
building. The room is separated by a wooden door that has a small screened opening. Inside the
storage room approximately five 55-gallon drums and several buckets were observed (see photos
in Appendix 3). A thick viscous material which appeared to be a petroleum product of some sort
had coated the majority of the floor. Mr. Muller did not enter the room to formally inventory the
containers and various products in this room. According to the previous reports a floor drain was
located in the northern portion of this room which presumably led to the Wells River, indicating
that the majority of these viscous materials that may have been spilled in this are in the past has
since been released. The exterior wall of this storage room is inaccessible due to the steep nature
of the escarpment leading down to the river.
5.2.3 Floor Drains Seven floor / sink drains were noted throughout the former mill building which include:
1) on in the Maintenance Room; 2) one in the Oil and Lubricant Storage Room; 3) one in the
Sub-Basement Storage Room; 4) one in the First Basement Pulp Room; 5) a collection sump in
the Sub-Basement Pulp Room; 6) one in the machine pit trench in the Sub-Basement Pulp Room;
and 7) one in the trench of the Machine Room. It is likely that all of these drains lead directly to
the Wells River without treatment. Several holes (approximately 4-inches in diameter) were
observed in the First Basement floor and were appropriately sized to have possibly contained a
drainage pipe.
5.2.4 Interior Transformer / Electric Supply Bank The interior transformer area / electrical bank appeared as described in the three previous
investigatory reports, including the presence of oil staining on both the wood and concrete floor
around the area and on the equipment itself. Additionally, the oil filled switches mentioned in the
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 15 July 2008
2007 W&S report were noted immediately to the north of the interior electrical bank along the
wall. The wall and shelf that supported these switches were stained as well.
5.2.5 Pulp Slurry Bulk Waste Several areas throughout both the First Basement and the Sub-Basement appeared to have
a white pulpy material caked onto walls, pipes and equipment at various locations including: 1)
the Whitewater Return Chest; 2) the floor drain in the Parts and Storage Area beneath the
Maintenance Room; 3) the walls of the Machine Room; 4) the interior walls of the trench in the
Machine Room; and 5) in the interior and on the exterior of piping throughout the former mill.
This pulp slurry has been confirmed to contain dioxins at elevated levels.
6.0 CONCLUSION AND RECOMMENDATIONS
JCO was retained by VTDEC to conduct an ESA Update of the Adams Paper Company
and the immediate surrounding land located at 15 Mill Street in Wells River, Vermont. The
purpose of the ESA Update was to perform a preliminary investigation to identify any changes in
the recognized environmental conditions identified in the September 2007 Phase I ESA for the
Site. This ESA Update, performed in general accordance with the American Society of Testing
and Materials (ASTM) Standard Practice for ESAs, ASTM E 1527-05, of the Adams Paper
Company in Wells River, Vermont, has revealed evidence of recognized environmental
conditions (RECs) associated with the Site. Based on the findings of this Phase I ESA Update
and the previous investigatory efforts at the Site, JCO recommends a Corrective Action
Feasibility Investigation (CAFI) and Corrective Action Plan (CAP) be developed in accordance
with the VTDEC guidelines to address the following RECs at the Site:
• The soil is impacted approximately 50-feet south of the former mill building presumably
from a release associated with the former 14,400-gallon UST previously located in this
area. The tank was reportedly removed in the late 1980s and remains on the property
near the southeast corner of the building. It is suspected that the groundwater has also
been impacted by this release.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 16 July 2008
Recommendation: Excavation of the contaminated soil has proven impractical, the Site
is serviced by a municipal water source, and the relatively low concentrations of VOCs in
the soil present a minimal risk of impacting indoor air quality. Therefore, it is
recommended that a notice to the land records be filed in the Newbury Town Land
Records identifying this REC. Additionally, the tank should be emptied, cleaned, and
disposed of in accordance with Vermont UST Closure Guidelines.
• The 1,000-gallon UST remaining on the property along the southern exterior wall of the
former mill building may pose further risk of impacting the soil and groundwater at the
Site.
Recommendation: If it is determined by the property owner that this 1,000-gallon UST is
no longer in use, the tank should be decommissioned, because the VTDEC UST Program
requires that abandoned USTs be closed in accordance with State UST Closure
Guidelines.
• Five inactive transformers, three of which have been proven to contain PCBs, remain
outside the southwest corner of the former mill building. PCBs were also detected in soil
and concrete below the platform that holds these transformers. A second concrete pad
with cut wires mounted on the warehouse building immediately above was noted
approximately 15-feet to the northwest of the exterior transformer bank. It is possible
this pad may have a previously housed a transformer. No indication of staining or
stressed vegetation was observed.
Recommendation: All out of service, PCB-containing transformers must be removed
from the property in accordance with Toxic Substances Control Act (TSCA) regulations.
Additionally, it appears that the PCB impacted soil and concrete beneath these
transformers requires further delineation in accordance with TSCA regulations. These
results will be used to determine the appropriate remedial actions.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 17 July 2008
• Debris that may contain hazardous material was observed in both the former mill
building and the warehouse. This material included approximately 14 drums and several
cans and buckets of possibly hazardous liquids. Other surfaces and materials inside and
around the building may be contaminated with dioxins or PCBs.
Recommendation: A qualified environmental contractor should inventory the materials in
the drums and containers in both the former mill building and the warehouse and dispose
of this material in accordance with State guidelines. Additional sampling inside the
building is recommended to determine the distribution and levels of suspected
contaminants, with particular attention paid to dioxins and PCBs. The results will be
used to determine potential remedial actions.
• Indoor air quality inside the former mill building may be impacted by residual dioxin
contamination.
Recommendation: Indoor air monitoring should be performed to determine the impact, if
any, on the indoor air quality with in the former mill building.
• The Oil and Lubricant Storage Room located west of the Machine Room on the first
basement of the former mill building contained approximately five 55-gallon drums and
several buckets with dark stains. A thick, viscous material which appeared to be a
petroleum product of some sort had coated the majority of the floor. Previous wipe
sampling of the floor has indicated that this oily substance contains residual PCBs.
Recommendation: Following the removal and disposal of the contents in the Oil and
Lubricant Storage Room, a qualified environmental contractor should clean all surfaces
of the room... Additional sampling for PCBs may be required in advance of cleaning to
determine solvent disposal requirements. If cleaning proves impractical, demolition and
disposal of this storage room may be an option.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 18 July 2008
• Sediment sampling during previous investigations have indicated detectable levels of
metals, dioxins, furans, and PCBs in several of the seven floor/sink drains noted
throughout the former mill building. These drains lead directly to the Wells River
without treatment and pose a risk to surface water should future releases take place in the
building.
Recommendation: Prior to any clean-up effort a qualified environmental contractor
should remove and properly dispose of all sediment from the seven drains identified in
the former mill building. Additionally, these seven drains, which presumably lead
directly to the Wells River, should be decommissioned so this pathway is eliminated.
• During the 2008 Supplemental Investigation, PCBs were detected using wipe samples on
the surface of the interior transformer area / electrical bank and wood floor. PCBs were
also detected in the concrete pad below the transformer by analyzing samples of the
pulverized concrete. The oil-filled switches mentioned in the 2007 Weston and Sampson
report were noted immediately to the north of the interior electrical bank along the wall,
and may contain residual PCB oil.
Recommendation: All surfaces associated with the interior transformer including the
switches along the wall, and the wood and concrete floor should be sampled and
analyzed for PCBs using a bulk sampling method. Additionally, JCO recommends the
interior transformer and the associated equipment be taken offsite and disposed of
properly.
• Previous laboratory analysis of the white pulpy material caked onto walls, pipes and
equipment at various locations in the first and sub-basements in the former mill building
has detected dioxins and furans in the material. These data should be used in determining
the appropriate management method for this bulk waste.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 19 July 2008
Recommendation: JCO recommends the pulp slurry waste be removed and disposed of
off site in accordance with VTDEC regulations prior to commencement of the building
renovations. Additional wipe sampling of other surfaces or equipment in these
basements should be conducted for dioxins and PCBs.
• Considering the buildings age, it is likely that lead paint and asbestos containing material
remain at the Site.
Recommendation: JCO recommends both lead paint analysis and an asbestos inspection
be performed at the Site prior to commencement of future building renovations or
demolition.
7.0 DATA GAPS/LIMITATIONS 7.1 DATA GAPS
No data gaps have been identified with the following exception: due to time limitations,
the Town of Newbury Land Records were not searched for environmental liens. However,
because the VTDEC provided information on behalf of the State of Vermont and the EPA, this
data gap is not expected to significantly impact the findings of this investigation.
7.2 LIMITATIONS The conclusions of this ESA were arrived at based upon information obtained and made
available to JCO from the following sources: Weston and Sampson Engineers, Inc., Phase I ESA
Report (September 2007); Strategic Environmental, LLC, Limited Phase II ESA (May 2, 2007);
Strategic Environmental, LLC, Supplemental Environmental Investigation (April 4, 2008);
Newbury Office of the Town Clerk; the VTDEC; the Federal EPA; the Town of Newbury Health
Officer; Green Mountain Power Company and from information gathered during the Site
reconnaissance. This information has been intended for the sole use of VTDEC for specific
application to the Adams Paper Company in Wells River, Vermont. No other uses, expressed or
implied, are warranted. The design of the investigation was based on sound scientific techniques
and experience with similar investigations. Should additional information become available
pertaining to environmental concerns that may be associated with the Site, the information
should be made available to JCO so that we may re-evaluate our conclusions.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 20 July 2008
8.0 REFERENCES CITED
ANR, 2008a. maps.vermont.gov/imf/imf.jsp?site=ANR_NATRESViewer, “Environmental Interest Locator”, Vermont Agency of Natural Resources, Department of Environmental Conservation. April 2008.
ANR, 2008b. www.anr.state.vt.us/dec/wastediv/rcra/pubs/allVTGen.pdf, “All Vermont
Generators, (Active IDs Only)”, Vermont Agency of Natural Resources, Department of Environmental Conservation. April 24, 2008.
ANR, 2008c. Vermont Spills Database, Vermont Agency of Natural Resources, Department of
Environmental Conservation. April 15, 2008. ANR, 2008d. www.anr.state.vt.us/dec/wastediv/SMS/RCPP/pubs/Brownfield_Sites_List.pdf,
“Brownfields Sites List”, Department of Environmental Conservation, Vermont Agency of Natural Resources. June 27, 2008.
ANR, 2007a. www.anr.state.vt.us/dec/cf/acthazsite/search.cfm, “Vermont Active Hazardous
Sites List”, Vermont Agency of Natural Resources, Department of Environmental Conservation. October, 2007.
ANR, 2007b. www.anr.state.vt.us/dec/wastediv/ust/USTlist.htm, “Vermont Permitted
Underground Storage Tank List”, Vermont Agency of Natural Resources, Department of Environmental Conservation. 2007.
ANR, 2005a. Closed Hazardous Sites Database, Vermont Agency of Natural Resources,
Department of Environmental Conservation. March 30, 2005. ANR, 2005b. Vermont UST Databases (Registered and Pulled), Vermont Agency of Natural
Resources, Department of Environmental Conservation. March 30, 2005. ANR, 2005c. “Vermont Solid Waste Management Facilities”, Vermont Agency of Natural
Resources, Waste Management Division, Solid Waste Management Program. April 12, 2005.
EPA, 2006. www.epa.gov/enviro/html/rcris/rcris_query_java.html, RCRA Information System,
U.S. Environmental Protection Agency. June 8, 2006. EPA, 2007. www.epa.gov/oswer/onecleaupprogram/init2-IC.htm, Solid Waste and Emergency
Response, U.S. Environmental Protection Agency. July 12, 2007. EPA, 2008a. www.epa.gov/enviro/html/cerclis/cerclis_query.html, Office of Emergency
Remedial Response, U.S. Environmental Protection Agency. April 11, 2008.
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Phase I ESA Update The Johnson Company, Inc. Adams Paper Company – Wells River, Vermont 21 July 2008
EPA 2008b. www.epa.gov/superfund/sites/query/queryhtm/npldel.htm, “Deleted National Priorities List (NPL) Sites- by State”, U.S. Environmental Protection Agency. May 8, 2008
EPA, 2008c. www.epa.gov/ne/cleanup/rcra/, “Waste Site Cleanup and Reuse in New England”,
Region 1, U.S. Environmental Protection Agency. June 5, 2008. Muller, 2008a. Telephone message left for Chief Jeffery Morin, at the Wells River Branch of the
Newbury Volunteer Fire Department. July 9, 2008. Muller, 2008b. Telephone message left by Ms. Renee Schulze, Health Officer for the Town of
Newbury, Vermont. July 9, 2008. Muller, 2008c. Telephone conversation with Mr. Steven Blood, Regional Manager, Green
Mountain Power. July, 14, 2008. NRC, 2008. www.nrc.uscg.mil, National Response Center, United States Coast Guard. July 9,
2008. UNH, 2005. http://docs.unh.edu/nhtopos/nhtopos.htm, Government Documents Department,
University of New Hampshire. January 3, 2005.
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APPENDIX 1
ENVIRONMENTAL PROFESSIONAL RESUMES Provided upon Request
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APPENDIX 2
ENVIRONMENTAL QUESTIONNAIRE
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APPENDIX 3
PHOTOGRAPHIC PLATES
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PHOTOGRAPHIC PLATES
Plate 1: Former Adams Paper Company (mill building), facing east.
Plate 2: Former 14,400-gallon UST reportedly removed in the late 1980s
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Plate 3: Vent and fill pipe of existing 1,000-gallon No.2 Fuel Oil tank located south of the mill building
Plate 4: Three of the five inactive exterior transformers located near the southwest corner of the former mill building.
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Plate 5: Two of the five inactive exterior transformers southeast of the former mill building
Plate 6: Debris which appears to hazardous was evident in the former mill building and the warehouse
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Plate 7: Interior of Oil and Lubricant Storage Room, note viscous product on floor
Plate 8: Trench in Machine Room has one of seven known floor / sink drains at the Site which presumably empty directly into the Wells River without treatment.
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Plate 9: Interior transformer / electric supply bank in First Basement of former mill building.
Plate 10: Pulp slurry bulk waste in Sub-Basement
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APPENDIX 4
USER QUESTIONNAIRE
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APPENDIX 5
PHASE I ESA SEPTEMBER 2007
WESTON AND SAMPSON
(NOTE: CONCLUSIONS & RECOMMENDATIONS FROM STRATEGIC ENVIRONMENTAL’S JANUARY 2007 PHASE II ESA PRESENTED IN APPENDIX E OF THE ABOVE REPORT)
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P.O. Box 189 Waterbury, Vermont 05676
Tel: (802) 244-5051 Fax: (802) 244-8505
Report
Phase I Environmental Site Assessment
Adams Paper Mill 15 Mill Street (Route 302) Wells River, Vermont
Prepared For: Green Mountain Monogram PO Box 753 14 Creamery Street Wells River, VT 05081
September 2007 WSE No.2070432
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i Weston & Sampson
TABLE OF CONTENTS
Page TABLE OF CONTENTS................................................................................................................. i LIST OF FIGURES ....................................................................................................................... iii LIST OF TABLES......................................................................................................................... iii LIST OF APPENDICES................................................................................................................ iii EXECUTIVE SUMMARY .......................................................................................................ES-1
1.0 INTRODUCTION ...............................................................................................................1 1.1 Purpose............................................................................................................................ 1
2.0 SITE LOCATION AND DESCRIPTION...........................................................................2 2.1 Property Use and Historical Information........................................................................ 3 2.2 Observations During Site Visits ..................................................................................... 4
2.2.1 Mill Building – “Upper Floor” ............................................................................... 4 2.2.2 Mill Building – “Lower Floor” ............................................................................... 5 2.2.3 Mill Building – “Basement” ................................................................................... 6 2.2.4 Warehouse Building................................................................................................ 7 2.2.5 Outside .................................................................................................................... 7 2.2.6 Hydroelectric Power System................................................................................... 7
2.3 Storage Tanks.................................................................................................................. 8 2.4 Oil and Hazardous Substances........................................................................................ 8
2.4.1 Mill Building – Upper Floor (Lab Room) .............................................................. 9 2.4.2 Mill Building – Lower Floor (Chemical Room)..................................................... 9 2.4.3 Lead Based Paint..................................................................................................... 9 2.4.4 Asbestos .................................................................................................................. 9 2.4.5 Polychlorinated Biphenyls (PCBs) ....................................................................... 10 2.4.6 Other Miscellaneous Items ................................................................................... 11
3.0 REVIEW OF RECORDS ..................................................................................................12 3.1 Previous Environmental Reports .................................................................................. 12
3.1.1 Weston and Sampson Phase I ESA....................................................................... 12 3.1.2 Strategic Environmental Phase II.......................................................................... 13 3.1.3 Environmental Data Resources, Inc. (EDR) Report ............................................. 15
3.2 State Underground Storage Tank Program................................................................... 15 3.3 Town Records ............................................................................................................... 16 3.4 Environmental Permits and Compliance ...................................................................... 16
4.0 ENVIRONMENTAL CHARACTERISTICS ...................................................................18 4.1 Site Setting and Topography......................................................................................... 18 4.2 Groundwater Characteristics......................................................................................... 18 4.3 Surface Water Characteristics....................................................................................... 18 4.4 Soil and Bedrock Characteristics .................................................................................. 19 4.5 Potential Environmental Receptors............................................................................... 19
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ii Weston & Sampson
5.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................21
6.0 LIMITATIONS..................................................................................................................23
7.0 COMMON ACRONYMS .................................................................................................24
8.0 REFERENCES ..................................................................................................................25
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iii Weston & Sampson
LIST OF FIGURES Figure 1 Locus Map Figure 2 Site Plan
LIST OF TABLES Table 1 List of Oil and Hazardous Substances
LIST OF APPENDICES Appendix A Site Photographs Appendix B Transaction Screen Questionnaire Appendix C Historical Sanborn Fire Insurance Maps Appendix D VTSMS First Letter Appendix E Strategic Environmental Phase II ESA (Site Plan / Recommendation &
Conclusions / Boring Logs)
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ES-1 Weston & Sampson
EXECUTIVE SUMMARY
This document was prepared by Weston & Sampson Engineers, Inc. (Weston and Sampson) at
the request of the Green Mountain Monogram (GMM). A Phase I Environmental Site
Assessment (ESA) was performed for the Adams Paper Mill property located in Wells River,
Vermont.
Weston & Sampson researched the background, development and environmental regulatory
history of the Adams Paper Company (Site) located at 15 Mill Street in the town of Wells River,
Vermont. The background study included a review of municipal, state and federal records,
discussions with the Site owner and review of historical Sanborn maps. A Site reconnaissance
visit was conducted on August 8, 2007 to observe conditions at the Site and adjacent properties.
Interviews were also conducted with various sources to gather other relevant Site information.
The Site is assumed to be 1.6 acres in size and includes two (2) primary buildings: a Mill
Building and warehouse building. An active hydroelectric power plant is operated inside part of
the Mill Building and Enel North America, Inc. retains deeded rights to various portions of the
Site related to hydroelectric power generation. Water flows into the Mill Building through a
penstock from the Newbury Dam just up river.
The Site was used as a paper mill as early as 1860. Since then, there have been several owners
and changes made at the Site; however, the overall history indicates that it has remained a paper
mill. Manufacturing ceased in 1983, due to the inability to meet water quality standards. More
recently the mill has been used for dry operation involving packaging and distribution of paper.
There is very little current activity at the mill.
As a result of the previous millwork at the Site, there are artifacts remaining of machinery, old
parts, debris and various petroleum products and process chemicals. Associated with the mill
operation were many floor drains. Some of the drains appear related to internal processes and
some likely discharged to Wells River.
During Weston & Sampson’s Site reconnaissance, a number of hazardous substances were found
within the buildings, including numerous 55-gallon drums, buckets and cans containing products
such as oils, lubricants, paints, thinners, laboratory chemicals and other unlabeled items. Other
potential hazardous substances were identified including possible lead-based paint, suspect
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ES-2 Weston & Sampson
asbestos-containing materials, fluorescent light fixture ballasts, transformers, batteries, mercury-
containing thermostats and pigeon droppings.
An illegal asbestos removal and disposal activity took place at the Site between 1999 and 2000.
This activity triggered enforcement actions by the State of Vermont and EPA, which included
penalties and requirements for proper cleanup. As a result of the enforcement, an asbestos
abatement project was conducted in March 2001.
Weston and Sampson performed an earlier Phase I ESA at the Site in September 2003, on behalf
of the Two Rivers-Ottauquechee Regional Commission (TRORC), in association with a
Brownfields Assessment program. The Weston and Sampson 2003 report recommended a Phase
II ESA be performed based on several recognized environmental conditions (RECs) related to
the historical use of the property. The initial list of RECs included:
• assessment of subsurface soils in the vicinity of the two USTs • testing of stained soils under old transformers for PCBs • collection of riverbank soil and riverbed sediment samples for laboratory analysis
Continuing under the TRORC Brownfields program, a Quality Assurance Project Plan (QAPP)
was submitted and approved by the Vermont Department of Environmental Conservation
(VTDEC) Brownfields Response Program and U.S. Environmental Protection Agency (EPA). At
the request of the Site owner (Mr. Fernand Fournier), the Phase II ESA was not conducted and
Weston and Sampson had no further involvement with the project until the preparation of this
Phase I ESA.
Since our earlier report, there have been no significant changes at the property with the exception
of the following items:
• Sampling of transformers for polychlorinated biphenyls (PCBs) was conducted by
Transformer Services, Inc. of Manchester, New Hampshire. Samples of oil from three of
the five transformers were found to contain PCBs.
• A Limited Phase II Environmental Site Assessment (ESA) by Strategic Environmental
LLC (Strategic) of Baldwinsville, New York was conducted during January of 2007 with
a report dated May 2, 2007. The report was submitted to the State of Vermont Sites
Management Section (VTSMS) and the VTSMS responded with a letter dated June 5,
2007. A copy of this letter is included as Appendix D. The VTSMS has acknowledged
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ES-3 Weston & Sampson
that there has been an environmental release of hazardous materials at the Site. Pursuant
to Vermont Statute Title 10 V.S.A. Part V Chapter 159 §6617 (Person responsible for
release; notice to agency) it is recognized that the VTSMS has been notified and the letter
assumes that Mr. Fernand Fournier as Site owner is a potentially responsible party. With
this notification, Vermont Statute Title 10 V.S.A. Part V Chapter 159 §6615b (Corrective
action procedures) comes a responsibility to take action to mitigate the effects of the
release and the VTDEC has assigned the site a tracking number (SMS #2007-3651). The
VTSMS letter provides a summary of work done to date, a section detailing additional
comments/data gaps and requested follow-up actions (for further details see State “First
Letter” in Appendix D).
It is recommended that a supplemental Phase II ESA and preliminary risk assessment be
performed to address issues to the satisfaction of the VTSMS. It is also recommended that
any other sampling that was recommended in the Weston and Sampson QAPP be considered
as part of future assessment work.
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1 Weston & Sampson
1.0 INTRODUCTION
Weston & Sampson Engineers, Inc., (Weston and Sampson) was contracted by the Green
Mountain Monogram (GMM) to perform a Phase 1 Environmental Site Assessment (ESA) at the
Adams Paper Mill, in Wells River, Vermont (hereinafter referred to as “the Site”; see Figure 1 –
Site location Figure). All figures related to this report are provided as the first attachment –
Figures. The ESA included a review of local, state and federal regulatory agency databases,
completion of a Transaction Screen Questionnaire, correspondence with various officials, and a
Site visit.
1.1 Purpose This assessment utilized quality principles and practices toward the preparation of this report and
incorporated suggested methods in general accordance with the American Society of Testing
Materials (ASTM). The term “recognized environmental condition” (REC) is defined in ASTM
Standard Practice E 1527-05 as “the presence or likely presence of any hazardous substances
(i.e., as defined under CERCLA 42 U.S.C § 9601 (14)) or petroleum products on a property
under conditions that indicate an existing release, a past release, or a material threat of a release
of any hazardous substances or petroleum products into structures on the property or into the
ground, groundwater, or surface water of the property.” This report is subject to the Limitations
described in Section 6.0.
The ASTM definition does not include “de minimus” conditions, which generally do not present
a threat to human health or the environment and that generally would not be the subject to an
enforcement action if brought to the attention of the appropriate governmental agencies.
Therefore, de minimus conditions are not considered RECs.
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2 Weston & Sampson
2.0 SITE LOCATION AND DESCRIPTION
The Site is located at 15 Mill Street (Route 302) in Wells River, Orange County, Vermont,
approximately 0.25 miles west-northwest of downtown Wells River. Wells River abuts the Site
to the north and Mill Street to the south; see location depicted on Locus Map (Figure 1).
Surrounding properties to the east, 0.2 miles, is a commercial/residential building with a sign
“Collectibles, Housewares, Tools.” To the west, 0.2 miles, is a residential property.
The Site: Tax Map 50, Block 01, Lot 74, Parcel 253 Latitude / Longitude: 44° 09' 10" North / 72° 03' 07" West UTM Coordinates (meters) 4,892,855 North / 735,764 East (Zone 18)
Elevation: 430 feet +/- above sea level Owner: Mr. Fernand Fournier Size: 1.6 acres Zoning: Commercial
Utilities:
Water – municipal connection Sewer – municipal connection Electricity – overhead connection, hydroelectric power generation Heating Oil – 1,000 gallon UST
The mill complex consists of 2 main structures - the Mill Building and warehouse building. The
overall features and approximate square footage of the structures are indicated below and shown
on the Site Plan (Figure 2). Photographs obtained during our reconnaissance visits are provided
for reference in Appendix A. Municipal water and sewer service the Site. Electrical power is
available with an overhead service from the south side of Mill Street. A utility pole with three
(3) transformers is located between Mill Street and the Mill Building, offering both single and
three-phase power.
Structures: Approx.(sq.ft.)Mill Building 10,907warehouse building 8,880 - 2 bay garage 832 - shed 252Total 20,871
Source: Field Sketch, LMN, 08/30/00
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2.1 Property Use and Historical Information The Site is a former paper mill that is being evaluated for reuse. To aid in gathering information
related to Site activities a “Transaction Screen Questionnaire” was completed by the Site owner,
prospective purchaser, and Weston and Sampson. Copies of the questionnaires are included in
Appendix B.
There are two (2) main structures associated with the former mill. These structures include a
brick Mill Building and warehouse building. At the southwest corner of the warehouse building
there is an attached 2-bay garage and at the northwest corner there is an attached shed.
Manufacturing at the mill ceased in 1983 due to the inability to meet water quality standards.
More recently the mill has been used for dry operation involving packaging and distribution of
paper.
There is very little current activity at the mill. The second floor of the Mill is still used,
approximately once or twice a week for distribution of cardboard and paper products.
At the northwest corner of the Site there is the Newbury Dam on Wells River that is associated
with a hydroelectric plant in the Mill Building. Enel North America, Inc. (formerly CHI and
Newbury Hydroelectric) have deeded rights to parts of the Site related to hydropower as referred
to in the property deed dated April 4, 1983 (book 70, Pages 67-69). Enel also rents the garage
off the west side of the warehouse and uses it to store various tools and equipment.
Records available at the Newbury Town Hall (also serving Wells River) indicate the age of the
paper mill building to be 1860. Information from both deeds available in the Town Vault and
historical Sanborn Maps support the use of the Site as a paper mill since the 1800s. Mr.
Fournier, owner, has indicated that the warehouse building was constructed sometime around
1940.
Copies of Sanborn™ Fire Insurance maps were available for the years 1884, 1889, 1894, 1899,
1905, 1912, 1922 and 1938 (these maps are included in Appendix C). In 1884 the property was
identified as Deming, Learned Company (Paper Mill), until 1894 when the name is Adams Paper
Company (Paper Mill). Early maps identify several other buildings on the property that do not
presently exist. Some structures are identified as “lime” and “bleach.”
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The current dam is shown on the 1912 map in addition to the penstock, that carries water under
the warehouse building to the hydroelectric plant in the Mill Building. Maps prior to 1912 show
a flume and covered race with an older dam further down river. The most recent 1938 map
shows an area identified as a coal pile next to the boiler house, just south of Mill Building.
The historical Sanborn Maps between 1884 and 1938 show that various buildings have been
located on Site. Of particular interest, located south of the Mill Building, is the former boiler
house that produced steam for machinery in the mill and relied on coal and Bunker No. 6 oil.
The boiler house no longer exists and a 14,400-gallon underground storage tank (UST) located
next to the boiler house was removed circa 1985 to 1987. There is now a 1,000-gallon UST just
south of the Mill Building that stores No. 2 heating oil for three (3) oil-fired forced hot air (FHA)
furnaces.
2.2 Observations During Site Visits Weston & Sampson visited the Site on August 7, 2007 to access the buildings, make
observations of current conditions, walk the land surrounding the buildings and conduct a limited
off-Site area reconnaissance. The Mill Building has an upper floor; lower floor; and, basement.
Please refer to Site Plan (Figure 2) and Site Photographs (Appendix A). To summarize field
observations of potentially hazardous substances, please refer to Table 1 (List of Oil and
Hazardous Substances) for further details. This list is intended to offer a highlight of materials
observed and does not constitute an exhaustive audit.
2.2.1 Mill Building – “Upper Floor” The upper floor includes offices and a kitchen in the northwest corner, a 1-story open work area
in the western half and a 2-story open work area in the eastern half. This floor was used for
managing the mill operation, receiving of supplies, and packaging of finished product. Natural
light is obtained from windows and much of the flooring is wood with some areas covered with
metal sheeting for forklift use.
Along a portion of the northern wall on this floor, there are three (3) rooms that extend out of the
main structure. For this report they will be referred to as Supply Room 1, Supply Room 2 and
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Lab Room. Supply Room 1 and Lab Room were very cluttered and the ceilings in all three of
these rooms were in poor condition. An elevator is located between the upper and lower floors
and appears to be filled with debris. A few pieces of machinery related to paper packaging
equipment remain on the upper floor.
A mechanical room is located on the southern side of the upper floor and includes electrical
service panels, two (2) oil-fired FHA furnaces and a small electric hot water heater. The electric
panels include a 600 amp 3-phase disconnect, 200 amp 1-phase service panel, 400 amp QO Load
Center and various equipment disconnects. Another oil-fired FHA furnace was found in the
kitchen and a small electric hot water heater just outside the kitchen. It appears that area space
heaters were used in the past but do not appear operational at this time.
2.2.2 Mill Building – “Lower Floor” The lower floor is concrete and below grade on the southern side and exposed with windows on
the northern side towards Wells River. This floor was used for preparation of pulp, production
of the paper products, maintenance of the mill machinery and handling of liquids associated with
the manufacturing. A control room for the hydroelectric plant is on this level in a secured room
next to the southern side of the building.
The eastern half of the building floor where the paper machine was located is approximately 4
feet lower than the western half. This area housed the former Harper Fourdrinier paper machine
and round dryers. There are many floor drains on the eastern part of the building, some floor
drains appeared to be related to internal processing and some may have resulted in direct
discharge to Wells River. Though the paper machine and dryers have been removed, several
machines are still in place.
A centralized lubricating system (Centro-Matic) is located along the southern wall of the lower
floor in the Mill Building. A small diameter copper pipe attaches the system to an empty 33-gal
drum (labeled TE HVY MED SGI OF 4KB). Copper pipes leave the central lubricating system
and run along the Mill walls, the entire coarse and destination of the piping could not be
determined due to clutter.
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6 Weston & Sampson
An open top tank (approximately 4,000 gallon capacity) was observed at the northern side of the
building and was supported from the basement. This tank was reported to have contained
aluminum sulfate (alum) used for pulp preparation and has been drained, though there appeared
to be dry caked sludge at the bottom.
The western side of this floor appears to be a machine shop. Inside the room is a storage area
(Supply Room 3), a stairway down to the basement and a historical power supply/load center.
Located in an attached room off the northwestern corner of this floor is a locked room referred to
as “Chemical Storage Room” in this report. The interior of this room, viewed through a small
wire mesh screen in the door, appears to have several drums with an unknown liquid covering
the floor.
2.2.3 Mill Building – “Basement” The basement can be accessed from three (3) stairwells. Two (2) stairwells are near the northern
side of the building and the third is near the southern side and dedicated to the hydroelectric
plant. The basement associated with the mill was poorly lit and cluttered. The upper portion of
the eastern stairwell was compromised with pigeon droppings and partially broken lower
staircase. All observations were made using a flashlight and not all areas could be accessed due
to safety considerations.
The western part of the basement, under the machine room, was a storage area (Supply Room 4)