United States Environmental Protection Agency
Region I
POLLUTION REPORT

Subject: 

From approximately 1952 to 1977, the A.C. Lawrence Tannery (Tannery) facility, formerly located on the west bank of the Little Androscoggin River, used a metal trough to transport their waste to settling lagoons on the southeast bank of the Little Androscoggin River.

In the 1970’s, the South Paris Publicly Owned Treatment Works was constructed and began accepting waste from the Tannery.  In 1977, the lagoons ceased receiving wastes and a soil cap was placed over the sludge lagoons. The Tannery closed in 1985.

The land surrounding the Site is primarily wooded. A residential development is planned immediately south of the Site and currently the nearest residences are approximately 2000 feet northeast along Oxford Street. The land use on the west side of the river is industrial/commercial.  The Site is located over a mapped sand and gravel aquifer.

This inactive seven acre Site is referred to as lot 7 on the Town of Paris, Maine Property Map R2. The cause of the contamination is from a non-oil manufacturing source (Tannery).

It is bounded:

• to the north by Little Androscoggin River;
• to the south by a residential development;
• to the east by Oxford Street; and,
• to the west by a railroad right-of-way and the Little Androscoggin River.

Week of 12 March 2007

OSC McKeown, Weston START Leader (SL) Burton, Shaw Response Manager (RM) Lutsic, 2 equipment operators, and 1 laborer mobilized.  EPA chemist Clifford mobilized the Region I Mobile Laboratory. Activities for the week included the continued excavation and stockpiling of soil from Lagoon 1.  Load out activities continued through 14 March 2007.  

On 13 March 2007, Kevin McGillicuddy of the Town of Paris Assessors office provided information on properties previously owned by AC Lawrence on Oxford Street, off of Kilgore Road.  OSC McKeown and RM Lutsic drove to the property and noticed that there were two areas that were capped and fenced. MEDEP staff Brian Beneski confirmed that these areas were capped and were on the MEDEP list.

On 14 March 2007, Michael Parker of the MEDEP gave EPA permission to change the soil disposal sampling frequency from one per every 500 tons of stockpiled soil to one per every 2,000 tons. All disposal samples analyzed to date have passed TCLP VOC's, SVOC's and Metals.

On March 15, 2007 the Town of South Paris posted Oxford Street stating that trucks over 25,000 lbs were restricted until the spring freeze and thaw cycle has been completed. As a result, soil will be stockpiled until the road posting is removed.

1,063 tons of chromium-contaminated soil was shipped to the Juniper Ridge Landfill in Alton, ME at a cost of $44,377.

Number of Samples Collected: 8

Samples Analyzed on-site:    8

Samples Analyzed by NERL:     3

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Week of 19 March 2007

OSC McKeown, RM Lutsic, 2 equipment operators, and 1 laborer mobilized. SL Burton mobilized on 20 March 2007.  Activities for the week included snow removal and the continued excavation and stockpiling of chromium-contaminated soil from Lagoon 1.  To facilitate the excavation of Lagoon 1 the construction of a road continues in a northeasterly direction on the floor of Lagoon 1. This road is used for the end dump to load-out soil from the bottom of the lagoon.

Number of Samples Collected: 3

Samples Analyzed on-site:    0

Samples Analyzed by NERL:    0

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Week of 26 March 2007

OSC McKeown, SL Burton, RM Lutsic, 2 equipment operators, and 1 laborer mobilized.  Activities for the week included stockpile re-location and the continued excavation and stockpiling of chromium-contaminated soil from Lagoon 1.  The construction of road ramp on the floor of Lagoon 1 continued.  

On 26 March 2007, MEDEP representative Wayne Paradis delivered some additional aerial views and maps displaying previously capped AC Lawrence disposal sites off of Oxford Street and the Construction Record Report Final Closure AC Lawrence Disposal Site" dated August 1996.  This report details that waste from the Site was capped at the AC Lawrence Disposal Site under a MEDEP-approved plan.

Number of Samples Collected: 3

Samples Analyzed on-site:    0

Samples Analyzed by NERL:    6

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Week of 2 April 2007

OSC McKeown, SL Burton, RM Lutsic, 2 equipment operators, and 1 laborer mobilized. Activities for the week include stockpile re-location, snow removal, and the continued excavation and stockpiling of chromium-contaminated soil from Lagoon 1.  The construction of road ramp on the floor of Lagoon 1 continued as excavation of Lagoon 1 progressed.  The crew demobilized for the weekend.  

Number of Samples Collected: 5

Samples Analyzed on-site:    0

Samples Analyzed by NERL:    5

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Week of April 9

OSC McKeown, SL Burton, RM Lutsic, 2 equipment operators, and 1 laborer mobilized.  Additional personnel on-site this week include SHAW PE Larry Nesbitt, and EPA representative T. Hennessy.  OSC McKeown, RM Lutsic, and Larry Nesbitt visit the previously capped AC Lawrence disposal sites off of Kilgore Road on Oxford Street to assess the possibility of their use for disposal of the Lagoon waste on April 9 2007.  On April 10 2007 EPA representative arrived on-site.  On April 11 2007 OSC McKeown, and T. Hennessy visit the MEDEP to perform a site file search, and meet with MEDEP personnel to review disposal options for the site.  On 12 April 2007 SL Burton updated the Administrative Record at the Paris Public Library.   Additional activities for the week include stockpile re-location, and the completion of excavation and stockpiling of chromium-contaminated soil from Lagoon 1.  A narrow strip of Lagoon 1 remains to support the sheet pile.   Other site activities involved snow removal on April 13, 2007.  The spring storm deposited approximately 12 inches of snow.  The crew consolidated the snow from the site to control the water runoff after the snow melted.  The crew demobilized for the weekend.

Number of Samples Collected: 0

Samples Analyzed on-site:    0

Samples Analyzed by NERL:    0

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Week of April 16

OSC McKeown, SL Burton, RM Lutsic, 2 equipment operators, and 2 laborers mobilized.  Site activities for the week included the completion of stockpile re-location of from Lagoon 3, the start of Lagoon 3 excavation and stockpiling, the construction of a new load out truck turnaround, and the re-location of the connex box and the CRC.  On 15 and 16 April 2007 the New England area experienced torrential rains, and high winds.  The storm caused road erosion, closings and elevated river levels to the 100 year flood mark for the Little Androscoggin. Other site activities involved minor excavations to improve the drainage of standing water from the soil stockpile areas.  The crew demobilized for the weekend.

Number of Samples Collected: 5

Samples Analyzed on-site:    0

Samples Analyzed by NERL:    5

Samples Analyzed by SHAW
procured laboratory for
disposal purposes:           0

Excavate the sludge from the lagoons and the river bank.

*  Continue with the excavation of chromium-contaminated soil;
*  Remove sheet piling along the Little Androscoggin River; and
*  Remove remaining berm along the northern wall of Lagoon 1.

While conducting the title search and speaking with area property owners, OSC McKeown learned that that AC Lawrence removed waste over a period of several years from the lagoons at the AC Lawrence Tannery Superfund Removal Site (the Site) and placed it into the disposal area located off of Kilgore Road. Based on preliminary assessment, EPA believes that there is adequate storage capacity to accept the remaining approximately 15,000 tons of waste from the Site.
If the option of disposing of the waste locally, (at the AC Lawrence Disposal Site) is environmentally acceptable and would present significant cost savings, EPA would prefer to use this option.  EPA and the MEDEP are currently investigating and discussing this option.