Old Pillsbury Mill

All POLREP's for this site Old Pillsbury Mill
Tilton, NH - EPA Region I
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On-Scene Coordinator - Dan Wainberg 7/9/2004
Time-Critical - Removal Action Pollution Report (POLREP) #2
Start Date: 4/21/2004
Site Description
The Site is located in a mixed residential and commercial area near the town center at 336 West Main Street, Tilton, New Hampshire.  The 1.94 acre site is identified as Parcels U06-03-00 and U06-04-00 by the Town of Tilton Tax Assessor.  The town is 20 miles north of Concord and encompasses an area that approaches 12 square miles.  Its population is approximately 3,477 with a population density of 308 inhabitants per square mile.

In 2001, the New Hampshire Department of Environmental Services (NHDES) conducted a Brownfields assessment to characterize the environmental conditions at the Site.  The investigation found ash remaining from the fire, and soil mixed with ash containing lead and barium in concentrations that make it a hazardous material.  This inactive Site is currently owned by the town of Tilton.
On 5 and 6 November of 2003, the EPA On-Scene Coordinator (OSC) and EPA contractors conducted a Removal Program Preliminary Assessment/Site Investigation (PA/SI).

Based on the PA/SI findings and a file review, the OSC recommended a time critical removal action in a February 27, 2004 closure memorandum.
The contaminants of concern and their maximum concentrations are lead and barium detected during the PA/SI at concentrations up to 6,800ppm and 5,520ppm respectively.  
See POLREP #1 for additional background information.    

Current Activities
Since POLREP No. 1, the following work has been completed:

- During the weeks of 31 May and 7 June, excavation and contaminated soil staging continued.  At the end of the week of 7 June, the soil staging area was filled to capacity.
- During the weeks of 15 June and 21 June, additional soil samples were collected and laboratory analysis performed to further characterize the staged soil and determine appropriate disposal options.  
- During the weeks of 28 June and 5 July, excavated soils were consolidated and placed in the western portion of the mill foundation, portions of the excavated areas were backfilled, and approximately 475 tons of contaminated soil were shipped off-site for disposal.  

Next Steps
1) Ship any contaminated soil that will be disposed off-site at a licensed facility.
2) Continue with contaminated soil excavation.
3) Backfill and grade excavated areas.

Key Issues
- Space constraints on the site limit the amount of staging area for excavated soil.
- As excavation activities commenced and the extent of contamination was further defined, EPA discovered a larger than anticipated volume of contaminated soil.  The EPA OSC is currently exploring options to appropriately address this increased volume of contaminated soil.  
- Laboratory analysis of the staged soil pile revealed that this soil pile is considered a Resource Conservation and Recovery Act (RCRA) Hazardous Waste.  This RCRA characterization requires that the soil is stabilized and disposed of at an appropriately licensed facility at an increased cost.  
- Despite the increased volume of contaminated soil and the RCRA characterization of the soil that was staged for shipment, the removal action is expected to remain within budget.