1da Smith Dyer difford H Goodall Donna L Zetgtgerl

DYER GOODALL AND ZEEGERS

Auorneys at Law Casco Northern Bank Building

One Memorial Circle Augusta Maine 04330

March 18 1985

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TELEPHO NE t2071 622lt)b9)

Marilyn Wade 08 Bnvironaental Protection

Agency Enforc-nt and Coat Recovery

Beetion Waate Managnt Dividon JPJ Building Roo 1907 Boaton Maaaachuaetta 02203

Rei P OCOnnor COIIlpany Superfund SiteAuguata Maine

Dear Marilyn 1

We appreciate having had the opportunity to diacuaa with you varioua aapecta of thh auperfund aite clean-up when you vidted the aite on March 13th

During your viait I Mntioned that we had comple ted a container inventory and identification project at the Bite Pleaae find enclosed a MMIOrandua aua~arizing the reaulta of that work

The container nu~tbera are condatent with the nWIIbera uaed ehevhere by EPA and ita conaultanta However the nubera that ve have uaed include containerbull which vere not previoualy inventoried or numbered and hence our numbering ayatea ia greater than thoae previoualy uaed

Pleaae find alao find encloaed a copy of a letter which I have aent to Charlea C Bering Eaq in reaponae to hia letter to 11e of March 11 1985 Your modifying c011111enta and agreellenta to that letter while visiting the aite are aUJNIIarised

I I

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Marilyn Wade Page Two March 18 1985

Again if you have any quebulltionbull or wiah to diecubullbull any abullpect or any 11atter related to thibull project pleabullbull do not hebullitate to contact 1ne

CBGbullah Bnclobullurebull

cct Charlebull C Bering Bbullq BPA Henry Aho DBP Jbull Jilbreth Baq r o bull Connor Cmapany J J Richard Aaaociatebull Acheron Engineering Servicebull

I I I I

1- =-middot - -middot (II DYER GOODALL AND ZEEGERS tl

Auorneysat Law Casco Northern Bank Building

One Memorial Circle TpoundlfiI-IONpound 11Augusta Maine 04330

Linda Smith Dter ll07l6llolblll

Clifford H Goodall f~(lDonna L Zee11eri

IMarch 18 1985

Charles C Bering Esq Legal Division U S EnvirofUIIental Protection

Agency Region 1 JP Xennedy Federal Building Boaton Maaaachuaetta 02203

Rea CERCLA Order Docket No I-85-1031 P OConnor Company Superfund Site

Dear Charleaa

We are in receipt of your letter of March 11 1985 which containa EPAa reaponae to the Site Security Plan which waa autitted on behalf of F OConnor Company

On March 13 1985 1 I had the opportunity of diacuaain9 thia reaponae with Marilyn Wade at the aite Baaed on that aite inapection and my cUacuadon with her it ia 1Y understanding that the EPA reaponae to the fencing plan ia further 11odified bullbull followaamp

1 The three atranda of barbed wire will not be required

2 The fence which parallela Route tl7 ahall go to and connect with the end of the culvert which carries the brook underneath Route tl7 The property line which followbull the brook in an easterly direction will not be fenced in The fence will resume at the edge of the water courae and proceed in a northeasterly direction from a point in the approximate location of an existing elm tree dbh 6middotmiddot The fence will then connect with the easterly portion of the fence a a outlined in our proposal of February 6th The access road will be blocked off by either a fence or by the dropping of treea across it to make it impassable It will alao be signed at the time the fence barrier is signed

3 We will eubmit the revised fence plan for the Site Security Plan on or before 325BS

I I I I

Charles c Bering Esq fbulla ge TWo arch 18 1985

On the second page of your letter was a series of dates which establish a compliance schedule These dates are acceptable with three poaaible exceptions Having the ana lyais of the aamplea completed by 614 85 is achievable provided there is no delay by the laboratories The trial report receipt date for EPA of 71585 is also probably achievable but this also is out of our hands and we are dependent Upon the laboramptory for achieving this date we will do everything possible to achieve compliance with both dates The other date which may poae a problem to achieve is the 48 85 date for the completion of the fence construction We have undertaken the requests from fence contractors to build a fence and we do not yet have a firm date for construction completion from these contractors We also have to provide safety equipment for them given the hazardous nature of the area and this may cause delays I am not saying we cannot meet thia date~ we will try but there may be some minor slippage

Regarding fence construction it is our underatanding based on our conversations with Marilyn Wade that we will not need to have the fence constructJ on crew trained in safety IIUltters for hazardous waste sites She told us it will be sufficient to have the work supervised by s0111eone certified by EPA in haaardous site safety Jim Richard of J lt Richard Associates is so certified and will be that supervisory personnel

Thank you for your reaponae If you have any questions or calllent_ pleaae dont hesitate to contact me

Beat regards

CLIFFORD H GOODALL

CBGsah

cc 1 Marilyn Wade Henry Aho Ja111e s Jtilbreth Esq P OConnor Company Acheron Engineering J It Richard Associates

Jrbullbull 1itr~bull

~I

rrbull I middot~middotmiddot I

I I

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Marilyn Wade Page Two March 18 1985

Again if you have any quebulltionbull or wiah to diecubullbull any abullpect or any 11atter related to thibull project pleabullbull do not hebullitate to contact 1ne

CBGbullah Bnclobullurebull

cct Charlebull C Bering Bbullq BPA Henry Aho DBP Jbull Jilbreth Baq r o bull Connor Cmapany J J Richard Aaaociatebull Acheron Engineering Servicebull

I I I I

1- =-middot - -middot (II DYER GOODALL AND ZEEGERS tl

Auorneysat Law Casco Northern Bank Building

One Memorial Circle TpoundlfiI-IONpound 11Augusta Maine 04330

Linda Smith Dter ll07l6llolblll

Clifford H Goodall f~(lDonna L Zee11eri

IMarch 18 1985

Charles C Bering Esq Legal Division U S EnvirofUIIental Protection

Agency Region 1 JP Xennedy Federal Building Boaton Maaaachuaetta 02203

Rea CERCLA Order Docket No I-85-1031 P OConnor Company Superfund Site

Dear Charleaa

We are in receipt of your letter of March 11 1985 which containa EPAa reaponae to the Site Security Plan which waa autitted on behalf of F OConnor Company

On March 13 1985 1 I had the opportunity of diacuaain9 thia reaponae with Marilyn Wade at the aite Baaed on that aite inapection and my cUacuadon with her it ia 1Y understanding that the EPA reaponae to the fencing plan ia further 11odified bullbull followaamp

1 The three atranda of barbed wire will not be required

2 The fence which parallela Route tl7 ahall go to and connect with the end of the culvert which carries the brook underneath Route tl7 The property line which followbull the brook in an easterly direction will not be fenced in The fence will resume at the edge of the water courae and proceed in a northeasterly direction from a point in the approximate location of an existing elm tree dbh 6middotmiddot The fence will then connect with the easterly portion of the fence a a outlined in our proposal of February 6th The access road will be blocked off by either a fence or by the dropping of treea across it to make it impassable It will alao be signed at the time the fence barrier is signed

3 We will eubmit the revised fence plan for the Site Security Plan on or before 325BS

I I I I

Charles c Bering Esq fbulla ge TWo arch 18 1985

On the second page of your letter was a series of dates which establish a compliance schedule These dates are acceptable with three poaaible exceptions Having the ana lyais of the aamplea completed by 614 85 is achievable provided there is no delay by the laboratories The trial report receipt date for EPA of 71585 is also probably achievable but this also is out of our hands and we are dependent Upon the laboramptory for achieving this date we will do everything possible to achieve compliance with both dates The other date which may poae a problem to achieve is the 48 85 date for the completion of the fence construction We have undertaken the requests from fence contractors to build a fence and we do not yet have a firm date for construction completion from these contractors We also have to provide safety equipment for them given the hazardous nature of the area and this may cause delays I am not saying we cannot meet thia date~ we will try but there may be some minor slippage

Regarding fence construction it is our underatanding based on our conversations with Marilyn Wade that we will not need to have the fence constructJ on crew trained in safety IIUltters for hazardous waste sites She told us it will be sufficient to have the work supervised by s0111eone certified by EPA in haaardous site safety Jim Richard of J lt Richard Associates is so certified and will be that supervisory personnel

Thank you for your reaponae If you have any questions or calllent_ pleaae dont hesitate to contact me

Beat regards

CLIFFORD H GOODALL

CBGsah

cc 1 Marilyn Wade Henry Aho Ja111e s Jtilbreth Esq P OConnor Company Acheron Engineering J It Richard Associates

Jrbullbull 1itr~bull

~I

rrbull I middot~middotmiddot I

I I I I

1- =-middot - -middot (II DYER GOODALL AND ZEEGERS tl

Auorneysat Law Casco Northern Bank Building

One Memorial Circle TpoundlfiI-IONpound 11Augusta Maine 04330

Linda Smith Dter ll07l6llolblll

Clifford H Goodall f~(lDonna L Zee11eri

IMarch 18 1985

Charles C Bering Esq Legal Division U S EnvirofUIIental Protection

Agency Region 1 JP Xennedy Federal Building Boaton Maaaachuaetta 02203

Rea CERCLA Order Docket No I-85-1031 P OConnor Company Superfund Site

Dear Charleaa

We are in receipt of your letter of March 11 1985 which containa EPAa reaponae to the Site Security Plan which waa autitted on behalf of F OConnor Company

On March 13 1985 1 I had the opportunity of diacuaain9 thia reaponae with Marilyn Wade at the aite Baaed on that aite inapection and my cUacuadon with her it ia 1Y understanding that the EPA reaponae to the fencing plan ia further 11odified bullbull followaamp

1 The three atranda of barbed wire will not be required

2 The fence which parallela Route tl7 ahall go to and connect with the end of the culvert which carries the brook underneath Route tl7 The property line which followbull the brook in an easterly direction will not be fenced in The fence will resume at the edge of the water courae and proceed in a northeasterly direction from a point in the approximate location of an existing elm tree dbh 6middotmiddot The fence will then connect with the easterly portion of the fence a a outlined in our proposal of February 6th The access road will be blocked off by either a fence or by the dropping of treea across it to make it impassable It will alao be signed at the time the fence barrier is signed

3 We will eubmit the revised fence plan for the Site Security Plan on or before 325BS

I I I I

Charles c Bering Esq fbulla ge TWo arch 18 1985

On the second page of your letter was a series of dates which establish a compliance schedule These dates are acceptable with three poaaible exceptions Having the ana lyais of the aamplea completed by 614 85 is achievable provided there is no delay by the laboratories The trial report receipt date for EPA of 71585 is also probably achievable but this also is out of our hands and we are dependent Upon the laboramptory for achieving this date we will do everything possible to achieve compliance with both dates The other date which may poae a problem to achieve is the 48 85 date for the completion of the fence construction We have undertaken the requests from fence contractors to build a fence and we do not yet have a firm date for construction completion from these contractors We also have to provide safety equipment for them given the hazardous nature of the area and this may cause delays I am not saying we cannot meet thia date~ we will try but there may be some minor slippage

Regarding fence construction it is our underatanding based on our conversations with Marilyn Wade that we will not need to have the fence constructJ on crew trained in safety IIUltters for hazardous waste sites She told us it will be sufficient to have the work supervised by s0111eone certified by EPA in haaardous site safety Jim Richard of J lt Richard Associates is so certified and will be that supervisory personnel

Thank you for your reaponae If you have any questions or calllent_ pleaae dont hesitate to contact me

Beat regards

CLIFFORD H GOODALL

CBGsah

cc 1 Marilyn Wade Henry Aho Ja111e s Jtilbreth Esq P OConnor Company Acheron Engineering J It Richard Associates

Jrbullbull 1itr~bull

~I

rrbull I middot~middotmiddot I

I I I I

Charles c Bering Esq fbulla ge TWo arch 18 1985

On the second page of your letter was a series of dates which establish a compliance schedule These dates are acceptable with three poaaible exceptions Having the ana lyais of the aamplea completed by 614 85 is achievable provided there is no delay by the laboratories The trial report receipt date for EPA of 71585 is also probably achievable but this also is out of our hands and we are dependent Upon the laboramptory for achieving this date we will do everything possible to achieve compliance with both dates The other date which may poae a problem to achieve is the 48 85 date for the completion of the fence construction We have undertaken the requests from fence contractors to build a fence and we do not yet have a firm date for construction completion from these contractors We also have to provide safety equipment for them given the hazardous nature of the area and this may cause delays I am not saying we cannot meet thia date~ we will try but there may be some minor slippage

Regarding fence construction it is our underatanding based on our conversations with Marilyn Wade that we will not need to have the fence constructJ on crew trained in safety IIUltters for hazardous waste sites She told us it will be sufficient to have the work supervised by s0111eone certified by EPA in haaardous site safety Jim Richard of J lt Richard Associates is so certified and will be that supervisory personnel

Thank you for your reaponae If you have any questions or calllent_ pleaae dont hesitate to contact me

Beat regards

CLIFFORD H GOODALL

CBGsah

cc 1 Marilyn Wade Henry Aho Ja111e s Jtilbreth Esq P OConnor Company Acheron Engineering J It Richard Associates

Jrbullbull 1itr~bull

~I

rrbull I middot~middotmiddot I

I I I I

HE H 0

middotroa Millin B Ball~ Dovid S DyerFROH

February 21 1985

RE Frank OConnor Site

DATE I

on thia date Jia Richard and Eric Saunders o JK Richard

Aaaociatea alonq with Greg Brown Bill Ball and myself were at

the F OConnor site to identify any tanka and druaa which eight

need to ))e aaapled Each Tank and drum exiatinq at the site was

viaUampllJ inapected to deteraine size location condition aeana

of acceu and whether or not the tanke and dnaa contained

liquid aaterial Each tank was photo9raphed

) Tho followinCJ 1a an inventory of the tanka ao

on this date s

Tank I

l 2 3 4 5 6 7 8 9

10 ll 12 13 l4 15 16 17 18

l9 20

Access Contentbull Opening Size

4 Liquid Liquid

3 Liquid 4 Liquid 4

3 Liquid 2 Dopty 2 Eapty

Unknown

3 Eapty none Eapty none Eapty none Dopty 4 Eapty none

4 Eapty 2 Dopty

Dopty

3 Dopty none Eapty none (very rusted)

4 Undetermined 4 Dopty

- l shy

Size of Tank Oia bull Lenqth

S x24 5xl2

550x24 4xl0 5 4xl0 4X 9 4Xl2 4 xl05 5 xl2 5 xl2

350 x 7 5 525 xl2 5 33 xl2

4 xl0 5 3 xl0 4 xl2 5 x24 3 xl0 5

5 SO x12 10SO xl2

they appeared

Capacity

3525 qall l 762 qall 4265 qall

987 qalo 940 qals 846 CJampll

1128 qals 987 qals

l 762 qals 1 762 CJampll

540 gala 1943 qals 2 003 CJamplS

987 qals 353 qals

1128 qals 3525 qals

370 qals

2133 qampls 21374 gall

A IJbullUbullr inventory was performed for a nuaber of 55 qallon

drWIS at the site with the following information availoble

Access Drua t Content s lcceseibility Opening size Size of Tampnk Capacity

55 qampll Dl Eapty 55 qalsBarrel Bung DZ Eapty 55 qampllBarrel Bung D3 Eapty 55 CJampll Barrel Bunq D4 tlllpty 55 qalaBarrel Bunq D5 Eapty 55 qalaBarrel Bunq D6 Un4eterbull1nec1 55 galaBarrel Bunq D7 Eapty 55 galaBarrel Bunq D8 Undeterbullined 55 qalaBarrel Bunq D9 Eapty 55 galbullBarrel Bung DlO Eapty Barrel Bung

DIIDbc

CC I ~~~~ ~=~~ lUlUbullbull O Connor Jack O Connor)

- 2 shy

I I

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~HII (~fl1

I

Jlt middot~

1. barcode 566793
2. barcodetext SDMS Doc ID 566793

A IJbullUbullr inventory was performed for a nuaber of 55 qallon

drWIS at the site with the following information availoble

Access Drua t Content s lcceseibility Opening size Size of Tampnk Capacity

55 qampll Dl Eapty 55 qalsBarrel Bung DZ Eapty 55 qampllBarrel Bung D3 Eapty 55 CJampll Barrel Bunq D4 tlllpty 55 qalaBarrel Bunq D5 Eapty 55 qalaBarrel Bunq D6 Un4eterbull1nec1 55 galaBarrel Bunq D7 Eapty 55 galaBarrel Bunq D8 Undeterbullined 55 qalaBarrel Bunq D9 Eapty 55 galbullBarrel Bung DlO Eapty Barrel Bung

DIIDbc

CC I ~~~~ ~=~~ lUlUbullbull O Connor Jack O Connor)

- 2 shy

I I

I I

~HII (~fl1

I

Jlt middot~

1. barcode 566793
2. barcodetext SDMS Doc ID 566793

I I

I I

~HII (~fl1

I

Jlt middot~

1. barcode 566793
2. barcodetext SDMS Doc ID 566793