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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 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

  • 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.

  • 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.

  • 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.

  • 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.

  • 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

  • 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

  • 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.

  • 0

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    FEET

    CONTOUR INTERVAL

    LOCATION

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    Montpelier, VT 05602

    Date:Drawn by:TheJohnson

    Company

    100 State Street, Suite 600

    Project:Scale:

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    = 20 FT

    Woodsville, NH-VT, 1988

    Figure 1. Site Location MapAdams Paper CompanyWells River, Vermont

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    SITE

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    1:24,000 3-2202-28

  • 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.

  • 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.

  • 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.

  • 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).

  • 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.

  • 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).

  • 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

  • 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

  • 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).

  • 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.

  • 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).

  • 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

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • APPENDIX 1

    ENVIRONMENTAL PROFESSIONAL RESUMES Provided upon Request

  • APPENDIX 2

    ENVIRONMENTAL QUESTIONNAIRE

  • APPENDIX 3

    PHOTOGRAPHIC PLATES

  • 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

  • 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.

  • 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

  • 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.

  • Plate 9: Interior transformer / electric supply bank in First Basement of former mill building.

    Plate 10: Pulp slurry bulk waste in Sub-Basement

  • APPENDIX 4

    USER QUESTIONNAIRE

  • 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)

  • 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

  • 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

  • ii Weston & Sampson

    5.0 CONCLUSIONS AND RECOMMENDATIONS ............................................................21

    6.0 LIMITATIONS..................................................................................................................23

    7.0 COMMON ACRONYMS .................................................................................................24

    8.0 REFERENCES ..................................................................................................................25

  • 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)

  • 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

  • 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

  • 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.

  • 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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    2.0 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.”

  • 4 Weston & Sampson

    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

  • 5 Weston & Sampson

    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.

  • 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)