Since the last POLREP, ERRS removed and segregated construction and demolition (C&D) debris, CRTs and other recyclable materials into different waste streams, conducted disposal sampling of each waste stream, completed the loadout of CRTs and other recyclable materials to CERCLA-approved offsite facilities for recycling, and commenced the excavation and loadout of contaminated soil and C&D debris to CERCLA-approved offsite disposal facilities. 


2.1.2 Response Actions to Date

- On 23 March 2011, a large quantity of buried wire, wire casing and miscellaneous containers and debris were uncovered at the back wetland area during a debris removal by an ERRS equipment operator.  Subsequently, START and OSC Tsang contacted the Weston NH-Certified Wetland Scientist (CWS) and the NH Department of Environmental Services (NHDES) to discuss options for test excavating a portion of the back wetland area to determine the extent of buried materials while minimizing the damage/disturbance to the wetland area.  

- On 24 March 2011, Weston CWS Joe Schmidl conducted a site visit to inspect the back wetland area and recommended minimal reworking of the soil surface for a soil removal that averages less than 1 foot and appears to re-expose the pre-existing wetland soil surface. For a deeper soil removal where mature tree roots are exposed below the pre-existing wetland soil surface, CWS Schmidl recommended restoration of the pre-excavation grade using seed-free wetland soil material (e.g., Agresource wetland soil mix) prior to a light coverage of the exposed surface with organic material obtained on-site to provide native seed stock and protect the ground surface until the following leaf fall, and the emplacement of logs stumps, rocks, etc. to provide wetland faunal habitat.

- From 10 March to 28 April 2011, approximately 145 tons of C&D debris were shipped to Mt. Carberry Landfill in Berlin, New Hampshire for disposal.

- On 25 March 2011, one (1) cubic yard box weighed 325 pounds containing miscellaneous lab-packed waste flammable, one (1) drum of waste pesticide and flammable aerosols, and one (1) drum of waste corrosive were sent to ENPRO services of Vermont, Inc. (ENPRO) in Williston, Vermont for disposal.

- From 28 March to 21 April 2011, approximately 44,136 pounds (81 cubic yard boxes) of CRT monitors and electronic wastes and miscellaneous sized mercury containing light bulbs were sent to RMG Enterprise, Inc. in Londonderry, New Hampshire for recycling.

- On 29 March 2011, OSC Tsang met with Ralph Wickson and John Regan of NHDES to review the removal progress and the erosion control measures implemented on-site for the upcoming test excavation at the back wetland area.

- From 30 March to 27 April 2011, OSC Tsang corresponded with Kirsten Pulkkinen, a NHDES Wetland Specialist, via emails and teleconferences to discuss the findings of the test excavation and the requirements and specifications of the general site and wetland restorations.  Ms. Pulkkinen concurred with EPA's proposed restoration plan in which EPA will spread approximately four (4) inches of native top soil all over the excavated areas including the channel banks and use geo-matting such as straw blankets to cover the entire excavated areas to control erosion while letting vegetation return naturally over time. Native weed free seed mix may also be spread to promote vegetation growth. 

- On 30 March 2011, elevation survey was conducted by START to map the original topography of the back wetland area prior to the 1 April test excavation. 

- From 31 March to 28 April 2011, a total of two (2) refrigerators, four (4) air conditioners, eight (8) propane tanks, one (1) washing machine and one (1) mercury thermometer were taken to Hillsborough Transfer Station for recycling.

- On 1 April 2011, ERRS, START and OSC Tsang conducted a test excavation at five (5) different locations at the back wetland area to evaluate the extent of the buried materials.  Soil samples were collected from each test excavation location and sent to the EPA New England Regional Laboratory (NERL) in North Chelmsford, MA for metals, SVOCs, VOCs, PCBs/Pesticide and cyanide analyses.

- From 4 April to 6 May 2011, ERRS excavated approximately 358 tons of contaminated soil and debris. Contaminated soil was shipped to Aggregate Recycling Corp. (ARC) in Eliot, Maine or Turnkey Landfill (Turnkey) in Rochester, New Hampshire depending upon the percentage of debris in soil.  Approximately 295 tons of contaminated soil were shipped to ARC. Approximately 63 tons of contaminated soil with higher percentage of debris were shipped to Turnkey for disposal.

- On 6 April 2011, Kevin Belanger of NH Department of Transportation (DOT) visited the Site and discussed with the ERRS Response Manager regarding the temporary road access permit for installing a driveway for the loadout of the contaminated soil.  During the surface debris removal, several pieces of asbestos-containing transite boards were uncovered at the area where the camper once was located.  A sample was taken for asbestos analysis.   The sampling result showed that the transite boards contained up to 20 percent chrysotile asbestos.

- On 12 April 2011, approximately 40,620 pounds of scrap steel were sent to William Reisner Corporation in Clinton, Massachusetts for recycling.

- On 20 and 21 April 2011, the first round of post-excavation sampling was conducted at 88 sampling grids.  The dimension of each sampling grid is 25 feet by 25 feet. A total of 86 surface (0" - 6") soil samples and 19 subsurface (12") soil samples were collected and sent to NERL.  A total of 105 samples was screened for arsenic, antimony and lead using X-ray fluorescence (XRF) technology. A total of 50 samples were analyzed for SVOCs.  A total of 28 samples were analyzed for PCBs/pesticides and VOCs. Twelve (12) samples were analyzed for cyanide.  The sampling results showed that a total of 10 grids required additional excavation.  

- On 22 April 2011, at the request of the town, approximately 80 lbs of miscellaneous household chemicals removed from the abandoned on-site residence, were taken to the Hillsborough Transfer Station.

- On 5 May 2011, ERRS excavated an additional 6 inches of contaminated soil from eight (8) of the ten (10) grids that were above the NH Site Remediation Standards (SRS) for arsenic, antimony, and several PAHs compounds. Two samples (grids# 51 and 55) located in heavily vegetated stream bank areas of the wetlands were not excavated due to the fact that the levels of contamination were either at or slightly above the NHSRS.  OSC Tsang determined that the contamination was not easily accessible and that the risk of destroying or damaging the wetlands outweighed the benefit from removing the soil.

- On 6 May 2011, START conducted a second round of post-excavation sampling at the eight (8) sampling grids for metals and SVOCs analyses.  At the request of the Town, samples of the broken wall board and siding were taken from the residence to NERL for asbestos analysis.  A chemist from ENPRO was on-site for the disposal of the asbestos transite boards and the hazard categorization (hazcat) and disposal of an old amber bottle labelled "chlorox" that was uncovered during the 1 April test excavation.

2.1.3 Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

See POLREP#1. 

• Complete the excavation and disposal of contaminated soil.
• Conduct stabilization and restoration activities at areas, including the wetlands, disturbed or damaged by the removal activities.

• Remobilize to complete disposal and/or excavation of contaminated soil. 

2.2.2 Issues

• Two intermittent streams and wetlands are located on-site.  Site and wetlands restoration activities must be conducted as soon as possible before the flood season begins in the Spring.   

* The above accounting of expenditures is an estimate based on figures known to the OSC at the time this report was written. The OSC does not necessarily receive specific figures on final payments made to any contractor(s). Other financial data which the OSC must rely upon may not be entirely up-to-date. The cost accounting provided in this report does not necessarily represent an exact monetary figure which the government may include in any claim for cost recovery.