I I

~ I I

~ v-shyNI Polmerbull Vice President 11middot1middot1 Polyfibron Division

WR Groce amp Co 55 Hoyden Avenue Lexington Moss 02173

(617) 861-6600

RECE~IED APR 18l83

[I

( - i GRACE

April 14 1983

Mr John R Moebes Chief Waste Response ampCompliance Branch micros Environmental Protection Agency Region John P Kennedy Federal Building Room 2103 Boston Massachusetts 02203

Mr Gilbert T Joly PE Regional Environmental Engineer Massachusetts Department of Environmental

Quality Engineering Central Regional Office 75 Grove Street Worcester Massachusetts 01605

Dear Messrs Moebes and Joly

Attached is the Historical Operational Usage Report on the Acton plant industrial landfill as

NIPmlr

Attachment

referred to in your letter of April 7 1983

Sincerely

bull

Nigel I Palmer Vice President Technical Services Polyfibron Division

cc Stephen Anderson - Palmer ampDodge middot Nancy Banks - Acton Town Hall middot Karin P Sheldon - Sierra Club Legal

Defense Fund

I I

~ I I

J ~ F Murphy Jr April 13 middot 1983

HISTORICAL OPERATIONAL USAGE REPORT

middot i

The foilotifng report of ~he industrial landfill at the W R Grace Co ACton pi~tia the beat information available from the people who were

bullmiddot associa~ed with this operation middot middot

The pl~ntbull during most of its ~peration when the landfill was in use was composed of three operationsbull

i

F~om ttie late 1940s to 1976 the Dewey and Almy Chemical DivisioP of i w R Grace amp Co manufactured container sealing compounds These were primarily FDA approved products used for sealing tin cans The products were made by ~iaaolving various types of rubber and fillers in solvents

2 CellUlosic battery separators were made to supply the leadacid storage batterJ manufacturers The separators were basically a phenolic resin impregnated paper sheet which was used as an insulator between the posishytive 8ud negative plates in a storage battery

3 The third line of products was a group of organic polymer resins made and sold to the adhesive and paint industry by the Organic Chemical Division of W R Grace ampCo

All three of these manufacturing operations have been shut down or moved to other locations

The DARAlllC plastic battery separator operation and the Construction Prodshymiddotucts Division of W R Grace ampCos concrete additive operation both of which now GfKate in the Acton plant never disposed of any waste aaterials

in the industrial landfill middot

The folloaing report starts with a listing of the raw materials used in the middot products and wastes disposed of in the industrial landfill

bull Time Span

A Ma~dal in the Landfill

1 Slllid Coagulum

Bom tank car cleaning process From early 1950s to February tranlt cleaning storage tank 1 1980 ~aning

bull Salids in Coagulum Included

middot~--

I I

~ I I

J ~ F Murphy Jr April 13 middot 1983

HISTORICAL OPERATIONAL USAGE REPORT

middot i

The foilotifng report of ~he industrial landfill at the W R Grace Co ACton pi~tia the beat information available from the people who were

bullmiddot associa~ed with this operation middot middot

The pl~ntbull during most of its ~peration when the landfill was in use was composed of three operationsbull

i

F~om ttie late 1940s to 1976 the Dewey and Almy Chemical DivisioP of i w R Grace amp Co manufactured container sealing compounds These were primarily FDA approved products used for sealing tin cans The products were made by ~iaaolving various types of rubber and fillers in solvents

2 CellUlosic battery separators were made to supply the leadacid storage batterJ manufacturers The separators were basically a phenolic resin impregnated paper sheet which was used as an insulator between the posishytive 8ud negative plates in a storage battery

3 The third line of products was a group of organic polymer resins made and sold to the adhesive and paint industry by the Organic Chemical Division of W R Grace ampCo

All three of these manufacturing operations have been shut down or moved to other locations

The DARAlllC plastic battery separator operation and the Construction Prodshymiddotucts Division of W R Grace ampCos concrete additive operation both of which now GfKate in the Acton plant never disposed of any waste aaterials

in the industrial landfill middot

The folloaing report starts with a listing of the raw materials used in the middot products and wastes disposed of in the industrial landfill

bull Time Span

A Ma~dal in the Landfill

1 Slllid Coagulum

Bom tank car cleaning process From early 1950s to February tranlt cleaning storage tank 1 1980 ~aning

bull Salids in Coagulum Included

middot~--

I I

~ I I

J F Murphy Jr April 13 1983

Page 2 Time Span

2 Discarded Material fr-om Production of Container Sealing Compounds and OrSanic Polymer Production middot middot middot

Off-spec product which was rubber dissolved in a solvent (Container Sealing) compounds

From late 1940s to 1976

Rubbers were Variously over the entire life acrylonitrilebutadiene rubber of the landfill (late 191+08shybutyl rubber to 19i0)natural rubber neoprene styrenebutadiene rubber

The major solvents were hexane toluene isopropyl alcohol methyl ethyl ketone cyclohexane

middot Other raw materials were alkylated aryl phosphite calcium carbonate calcium nitrate carbon black clay di-B-napthyl-P-phenylene diamine di-isodesyl pbthalate di-octyl sebacate ester gum ethyl alcohol ethyl cellulose ethyl glycolate fossil hydrocarbon resin hexane contaminated with ethyl

benzene iron oxide (y~llow)

isoheptane isopropyl alcohol lecithin magneseium oxide methyl cyclohexylphenol octylated diphenylamine pentamethylene dithiocarbonate petroleum hydrocarb~n bull phenol formaldehyde res~n

phenolic resin pinene resin polybutene middot polyethylene

I I

~ I I

J F middotMurphy Jr middot April 13 198~

P~ge 3

Time Span

polystyrene polystyrenesoy bean oil polyvinyl chloride propylene oxide rosin methyl ester sodium acetate sodium dioctyl sulfosuccinate

sulphur middot tetraethylthiuram disulfide

titanium dioxide tolune sulphonamide formaldehyde middot trichloroethane wood rosin xylol

middot zinc oxide

B Origin of Specific Contaminants in the Landfill

1 Benzene

The majority (about 90) of the container sealings compounds were made using the solvent hexane Through the years of operation in Acton the hexane supplied had various contamination levels of benshyzene which averaged 37 from 1954 to 1966 31 from 1967 to 1971 and lt2 from 1972 through 1976 Today hexane contains less than 1 benzene The best estimate is that the average benzene level in the hexane over the years was about 2-12 to 3 by weight Since middot t~e compounds were an average of 40 solids the benzene content of the discarded compound was about 2 by weight~

2 middot Toluene

The principal source of toluene in the landfill was from off-spec can sealing compound known as GK-45 This was 60 solids sealant

middotthat was rubber dissolved in toluene It was made for most of the time that the landfill was in use and therefore off-spec material from bad batches of this material could be in any location in the landfill

c Quantities of Contamination in the Landfill

1 Benzene

Of the compounds containing h~xane it is estimated that about 7 gallonsday were discarded to the landfill At the 2 by weight of benzene in the compound this would mean that during the life of the landfill about 375 poundsyear of benzene was discarded or a total of 9200 pounds over the life of the landfill

bull

)

D

made in Acton it is estimated that about 28 gallonsday of that type of compound was discarded to the landfill was 60 solids that would mean about 2800 poundsyear of toluene or 75000 pounds of toluene would have been deposited in the landshyfill over its life

I

3 Dried Sludge from the Primary Lagoon

The dried coagulum from the Primary Lagoon was dredged out of the lagoon every other year about 250 cubic yards which was started in the early 1950s and was that during the life of the landfill about 3250 cubic yards of this dried coaguium was

middot about 5 1 of the volume of the landfill middot

In order t_gcheck for possible leaching of contaminants from the dried sludge from the Primary Lagoon ~nd deposited in the landfill we did a leach t~s~ on some of this dried sludge

ilar in all respects to the EP toxicity test for determining whether I

a matelial leaches toxic materials with three exceptions bull middotshy 1 bull

-- a ~o-pH ~dju~_tments were made - middot

J middot _ ~ b The c~ntainer in which the extraction wa~ cond~~~~d had no head

space

c The extract was allowed tQ settle and was and analyzed for volatile organics~

The only compound detected in the leachate was ppb

SummaX of Contents of Landfill

Dried coagulum from Primary Lagoon and elsewhere (some ~n drums)

Paper out-of-spec Battery Separator paper bags broken pallets

Hexane-based can sealing compounds in drums

Toluene-based can sealing compounds in drums

Dirt fill around debris

Ibull bull J F Murphy Jr

April 13 1983

Page 4

2 Toluene

Over the time that can sealing compounds containing toluene were

Since the compound

After being dried it had a volume of deposited in the landfill This

last done in 1978 middot This means ~

deposited inthe landfill Jlis representa bull

The test was sim-

I

decant~d c~ot filtered)

ethylbenzene at 105

3250 cuyds 51

27500 cuyds 432

395 cuyds 6

bull179 cuyds 3

19500 cuyds 306

I I

~ I I

~ J F Murphy Jr Apr~l 13 1983

Page 5

Old pipe metal fittings angle iron battered drums other rubbish 12800 cuyds 201

~ff-spec research lab sealing compounds = ~r~m Cambridge lab material concrete t ~l~cks lubricants and cutting oils etc 78 cu yds 1

middot Total 1000

See more detail in the attached Chart 11

Major Factor Affecting Landfill Content

As can be seen from the Summary of Contents the known drums in middotthe landfill account for less than 1 of the volume Even if this

middot is doubled or tripled it is still a small amount The most signifshy icant factor is that in 1959 or 1960 after a particularly large fire in the landfill including many exploding drums a rule was established by plant management to no longer put closed drums into the landfill The covers were left off open-head drums and the plugs ieft out of the bungs on closed-head drums The purpose of the rule was to prevent exploding drums in case of a fire The peoshyple most closely associated with the landfill operation indicate that this rule was observed This would mean that the only closed drums in the landfill would be over 20 years old and probably corroshyded through

The fact that there was such a rule and that it was known and cArshyried out has been confirmed by at least five different people who were part of the plant manag~ment a~ Acton at one time or another

Assuming the drums were open it is probalgtie that much of the volashytile organics would have evaporated This is fairly evident from the numerous fires that took place at the landfill over the years

Also assuming the drums are open and any solvent is lighter than water it would be floated out on rainwater regardless of the orientation of the drum in the landfill

F Structure of the Landfill

middot The landfill was started in the mid to late 1940s by disposing of plant trash in a natural depression about 1000 feet south~ast of the industrial buildings then in use This depression (commonly called a kettle hole) was about 2 acres in size and was 25 feet deep at the deepest point but averaged about 10 feet deep over the o

entire 2 acres During the time up to 1960 to 1962 the operation consisted of filling up the hole at random with the various disshycarded material mentioned above Any compaction that was done was

I I

~ I I

J I

J F Murphy Jr April 13 1983

Page 6

done with a bulldozer and very little eart~ coverage was done until the hole was almost filled The contents of the landfill is probashybly almos t completely non-homogenous The dried coagulum froca the Primary Lagoon may be in pockets distributed around the landfill

I only because they were transported in truckload lots from the Pri~ - mary Lagoon

After the early 1960s when the original kettle hole was filled the landfill operation moved to the 2 acres east where trenches were dug The dirt was stored on either aide of the trench and from middottime-to-time used to cover the discarded material which was placed in the trench This eastern half of the landfill was excavated and filled to a 10 to 12 foot depth on the average

middot There are several plac~s in the landfill where large objects have been buried One of these is the body of a tank truck which is filled with set-up compound placed in the landfill in the early1970bullmiddot

The truck was about a third full of a hexane based container sealing compound which set up (jelled) and could not be economically removed

The other large object in the landfill is the former blowdown tank froa the Organic Chemical plant operation This is a 5000 gallon tank that is full of coagulated latex not dissimilar to the sludge removed from the Primary Lagoon and deposited occasionally in the landfill This tank was on the emergency vent line from the reacshytors in Building 13 in the Acton plant

These items were located by ground penetrating radar

JFMJRm1 r

Attacbmr middot

0

I I

~ I I

J F middotMurphy Jr middot April 13 198~

P~ge 3

Time Span

polystyrene polystyrenesoy bean oil polyvinyl chloride propylene oxide rosin methyl ester sodium acetate sodium dioctyl sulfosuccinate

sulphur middot tetraethylthiuram disulfide

titanium dioxide tolune sulphonamide formaldehyde middot trichloroethane wood rosin xylol

middot zinc oxide

B Origin of Specific Contaminants in the Landfill

1 Benzene

The majority (about 90) of the container sealings compounds were made using the solvent hexane Through the years of operation in Acton the hexane supplied had various contamination levels of benshyzene which averaged 37 from 1954 to 1966 31 from 1967 to 1971 and lt2 from 1972 through 1976 Today hexane contains less than 1 benzene The best estimate is that the average benzene level in the hexane over the years was about 2-12 to 3 by weight Since middot t~e compounds were an average of 40 solids the benzene content of the discarded compound was about 2 by weight~

2 middot Toluene

The principal source of toluene in the landfill was from off-spec can sealing compound known as GK-45 This was 60 solids sealant

middotthat was rubber dissolved in toluene It was made for most of the time that the landfill was in use and therefore off-spec material from bad batches of this material could be in any location in the landfill

c Quantities of Contamination in the Landfill

1 Benzene

Of the compounds containing h~xane it is estimated that about 7 gallonsday were discarded to the landfill At the 2 by weight of benzene in the compound this would mean that during the life of the landfill about 375 poundsyear of benzene was discarded or a total of 9200 pounds over the life of the landfill

bull

)

D

made in Acton it is estimated that about 28 gallonsday of that type of compound was discarded to the landfill was 60 solids that would mean about 2800 poundsyear of toluene or 75000 pounds of toluene would have been deposited in the landshyfill over its life

I

3 Dried Sludge from the Primary Lagoon

The dried coagulum from the Primary Lagoon was dredged out of the lagoon every other year about 250 cubic yards which was started in the early 1950s and was that during the life of the landfill about 3250 cubic yards of this dried coaguium was

middot about 5 1 of the volume of the landfill middot

In order t_gcheck for possible leaching of contaminants from the dried sludge from the Primary Lagoon ~nd deposited in the landfill we did a leach t~s~ on some of this dried sludge

ilar in all respects to the EP toxicity test for determining whether I

a matelial leaches toxic materials with three exceptions bull middotshy 1 bull

-- a ~o-pH ~dju~_tments were made - middot

J middot _ ~ b The c~ntainer in which the extraction wa~ cond~~~~d had no head

space

c The extract was allowed tQ settle and was and analyzed for volatile organics~

The only compound detected in the leachate was ppb

SummaX of Contents of Landfill

Dried coagulum from Primary Lagoon and elsewhere (some ~n drums)

Paper out-of-spec Battery Separator paper bags broken pallets

Hexane-based can sealing compounds in drums

Toluene-based can sealing compounds in drums

Dirt fill around debris

Ibull bull J F Murphy Jr

April 13 1983

Page 4

2 Toluene

Over the time that can sealing compounds containing toluene were

Since the compound

After being dried it had a volume of deposited in the landfill This

last done in 1978 middot This means ~

deposited inthe landfill Jlis representa bull

The test was sim-

I

decant~d c~ot filtered)

ethylbenzene at 105

3250 cuyds 51

27500 cuyds 432

395 cuyds 6

bull179 cuyds 3

19500 cuyds 306

I I

~ I I

~ J F Murphy Jr Apr~l 13 1983

Page 5

Old pipe metal fittings angle iron battered drums other rubbish 12800 cuyds 201

~ff-spec research lab sealing compounds = ~r~m Cambridge lab material concrete t ~l~cks lubricants and cutting oils etc 78 cu yds 1

middot Total 1000

See more detail in the attached Chart 11

Major Factor Affecting Landfill Content

As can be seen from the Summary of Contents the known drums in middotthe landfill account for less than 1 of the volume Even if this

middot is doubled or tripled it is still a small amount The most signifshy icant factor is that in 1959 or 1960 after a particularly large fire in the landfill including many exploding drums a rule was established by plant management to no longer put closed drums into the landfill The covers were left off open-head drums and the plugs ieft out of the bungs on closed-head drums The purpose of the rule was to prevent exploding drums in case of a fire The peoshyple most closely associated with the landfill operation indicate that this rule was observed This would mean that the only closed drums in the landfill would be over 20 years old and probably corroshyded through

The fact that there was such a rule and that it was known and cArshyried out has been confirmed by at least five different people who were part of the plant manag~ment a~ Acton at one time or another

Assuming the drums were open it is probalgtie that much of the volashytile organics would have evaporated This is fairly evident from the numerous fires that took place at the landfill over the years

Also assuming the drums are open and any solvent is lighter than water it would be floated out on rainwater regardless of the orientation of the drum in the landfill

F Structure of the Landfill

middot The landfill was started in the mid to late 1940s by disposing of plant trash in a natural depression about 1000 feet south~ast of the industrial buildings then in use This depression (commonly called a kettle hole) was about 2 acres in size and was 25 feet deep at the deepest point but averaged about 10 feet deep over the o

entire 2 acres During the time up to 1960 to 1962 the operation consisted of filling up the hole at random with the various disshycarded material mentioned above Any compaction that was done was

I I

~ I I

J I

J F Murphy Jr April 13 1983

Page 6

done with a bulldozer and very little eart~ coverage was done until the hole was almost filled The contents of the landfill is probashybly almos t completely non-homogenous The dried coagulum froca the Primary Lagoon may be in pockets distributed around the landfill

I only because they were transported in truckload lots from the Pri~ - mary Lagoon

After the early 1960s when the original kettle hole was filled the landfill operation moved to the 2 acres east where trenches were dug The dirt was stored on either aide of the trench and from middottime-to-time used to cover the discarded material which was placed in the trench This eastern half of the landfill was excavated and filled to a 10 to 12 foot depth on the average

middot There are several plac~s in the landfill where large objects have been buried One of these is the body of a tank truck which is filled with set-up compound placed in the landfill in the early1970bullmiddot

The truck was about a third full of a hexane based container sealing compound which set up (jelled) and could not be economically removed

The other large object in the landfill is the former blowdown tank froa the Organic Chemical plant operation This is a 5000 gallon tank that is full of coagulated latex not dissimilar to the sludge removed from the Primary Lagoon and deposited occasionally in the landfill This tank was on the emergency vent line from the reacshytors in Building 13 in the Acton plant

These items were located by ground penetrating radar

JFMJRm1 r

Attacbmr middot

0

bull

)

D

made in Acton it is estimated that about 28 gallonsday of that type of compound was discarded to the landfill was 60 solids that would mean about 2800 poundsyear of toluene or 75000 pounds of toluene would have been deposited in the landshyfill over its life

I

3 Dried Sludge from the Primary Lagoon

The dried coagulum from the Primary Lagoon was dredged out of the lagoon every other year about 250 cubic yards which was started in the early 1950s and was that during the life of the landfill about 3250 cubic yards of this dried coaguium was

middot about 5 1 of the volume of the landfill middot

In order t_gcheck for possible leaching of contaminants from the dried sludge from the Primary Lagoon ~nd deposited in the landfill we did a leach t~s~ on some of this dried sludge

ilar in all respects to the EP toxicity test for determining whether I

a matelial leaches toxic materials with three exceptions bull middotshy 1 bull

-- a ~o-pH ~dju~_tments were made - middot

J middot _ ~ b The c~ntainer in which the extraction wa~ cond~~~~d had no head

space

c The extract was allowed tQ settle and was and analyzed for volatile organics~

The only compound detected in the leachate was ppb

SummaX of Contents of Landfill

Dried coagulum from Primary Lagoon and elsewhere (some ~n drums)

Paper out-of-spec Battery Separator paper bags broken pallets

Hexane-based can sealing compounds in drums

Toluene-based can sealing compounds in drums

Dirt fill around debris

Ibull bull J F Murphy Jr

April 13 1983

Page 4

2 Toluene

Over the time that can sealing compounds containing toluene were

Since the compound

After being dried it had a volume of deposited in the landfill This

last done in 1978 middot This means ~

deposited inthe landfill Jlis representa bull

The test was sim-

I

decant~d c~ot filtered)

ethylbenzene at 105

3250 cuyds 51

27500 cuyds 432

395 cuyds 6

bull179 cuyds 3

19500 cuyds 306

I I

~ I I

~ J F Murphy Jr Apr~l 13 1983

Page 5

Old pipe metal fittings angle iron battered drums other rubbish 12800 cuyds 201

~ff-spec research lab sealing compounds = ~r~m Cambridge lab material concrete t ~l~cks lubricants and cutting oils etc 78 cu yds 1

middot Total 1000

See more detail in the attached Chart 11

Major Factor Affecting Landfill Content

As can be seen from the Summary of Contents the known drums in middotthe landfill account for less than 1 of the volume Even if this

middot is doubled or tripled it is still a small amount The most signifshy icant factor is that in 1959 or 1960 after a particularly large fire in the landfill including many exploding drums a rule was established by plant management to no longer put closed drums into the landfill The covers were left off open-head drums and the plugs ieft out of the bungs on closed-head drums The purpose of the rule was to prevent exploding drums in case of a fire The peoshyple most closely associated with the landfill operation indicate that this rule was observed This would mean that the only closed drums in the landfill would be over 20 years old and probably corroshyded through

The fact that there was such a rule and that it was known and cArshyried out has been confirmed by at least five different people who were part of the plant manag~ment a~ Acton at one time or another

Assuming the drums were open it is probalgtie that much of the volashytile organics would have evaporated This is fairly evident from the numerous fires that took place at the landfill over the years

Also assuming the drums are open and any solvent is lighter than water it would be floated out on rainwater regardless of the orientation of the drum in the landfill

F Structure of the Landfill

middot The landfill was started in the mid to late 1940s by disposing of plant trash in a natural depression about 1000 feet south~ast of the industrial buildings then in use This depression (commonly called a kettle hole) was about 2 acres in size and was 25 feet deep at the deepest point but averaged about 10 feet deep over the o

entire 2 acres During the time up to 1960 to 1962 the operation consisted of filling up the hole at random with the various disshycarded material mentioned above Any compaction that was done was

I I

~ I I

J I

J F Murphy Jr April 13 1983

Page 6

done with a bulldozer and very little eart~ coverage was done until the hole was almost filled The contents of the landfill is probashybly almos t completely non-homogenous The dried coagulum froca the Primary Lagoon may be in pockets distributed around the landfill

I only because they were transported in truckload lots from the Pri~ - mary Lagoon

After the early 1960s when the original kettle hole was filled the landfill operation moved to the 2 acres east where trenches were dug The dirt was stored on either aide of the trench and from middottime-to-time used to cover the discarded material which was placed in the trench This eastern half of the landfill was excavated and filled to a 10 to 12 foot depth on the average

middot There are several plac~s in the landfill where large objects have been buried One of these is the body of a tank truck which is filled with set-up compound placed in the landfill in the early1970bullmiddot

The truck was about a third full of a hexane based container sealing compound which set up (jelled) and could not be economically removed

The other large object in the landfill is the former blowdown tank froa the Organic Chemical plant operation This is a 5000 gallon tank that is full of coagulated latex not dissimilar to the sludge removed from the Primary Lagoon and deposited occasionally in the landfill This tank was on the emergency vent line from the reacshytors in Building 13 in the Acton plant

These items were located by ground penetrating radar

JFMJRm1 r

Attacbmr middot

0

I I

~ I I

~ J F Murphy Jr Apr~l 13 1983

Page 5

Old pipe metal fittings angle iron battered drums other rubbish 12800 cuyds 201

~ff-spec research lab sealing compounds = ~r~m Cambridge lab material concrete t ~l~cks lubricants and cutting oils etc 78 cu yds 1

middot Total 1000

See more detail in the attached Chart 11

Major Factor Affecting Landfill Content

As can be seen from the Summary of Contents the known drums in middotthe landfill account for less than 1 of the volume Even if this

middot is doubled or tripled it is still a small amount The most signifshy icant factor is that in 1959 or 1960 after a particularly large fire in the landfill including many exploding drums a rule was established by plant management to no longer put closed drums into the landfill The covers were left off open-head drums and the plugs ieft out of the bungs on closed-head drums The purpose of the rule was to prevent exploding drums in case of a fire The peoshyple most closely associated with the landfill operation indicate that this rule was observed This would mean that the only closed drums in the landfill would be over 20 years old and probably corroshyded through

The fact that there was such a rule and that it was known and cArshyried out has been confirmed by at least five different people who were part of the plant manag~ment a~ Acton at one time or another

Assuming the drums were open it is probalgtie that much of the volashytile organics would have evaporated This is fairly evident from the numerous fires that took place at the landfill over the years

Also assuming the drums are open and any solvent is lighter than water it would be floated out on rainwater regardless of the orientation of the drum in the landfill

F Structure of the Landfill

middot The landfill was started in the mid to late 1940s by disposing of plant trash in a natural depression about 1000 feet south~ast of the industrial buildings then in use This depression (commonly called a kettle hole) was about 2 acres in size and was 25 feet deep at the deepest point but averaged about 10 feet deep over the o

entire 2 acres During the time up to 1960 to 1962 the operation consisted of filling up the hole at random with the various disshycarded material mentioned above Any compaction that was done was

I I

~ I I

J I

J F Murphy Jr April 13 1983

Page 6

done with a bulldozer and very little eart~ coverage was done until the hole was almost filled The contents of the landfill is probashybly almos t completely non-homogenous The dried coagulum froca the Primary Lagoon may be in pockets distributed around the landfill

I only because they were transported in truckload lots from the Pri~ - mary Lagoon

After the early 1960s when the original kettle hole was filled the landfill operation moved to the 2 acres east where trenches were dug The dirt was stored on either aide of the trench and from middottime-to-time used to cover the discarded material which was placed in the trench This eastern half of the landfill was excavated and filled to a 10 to 12 foot depth on the average

middot There are several plac~s in the landfill where large objects have been buried One of these is the body of a tank truck which is filled with set-up compound placed in the landfill in the early1970bullmiddot

The truck was about a third full of a hexane based container sealing compound which set up (jelled) and could not be economically removed

The other large object in the landfill is the former blowdown tank froa the Organic Chemical plant operation This is a 5000 gallon tank that is full of coagulated latex not dissimilar to the sludge removed from the Primary Lagoon and deposited occasionally in the landfill This tank was on the emergency vent line from the reacshytors in Building 13 in the Acton plant

These items were located by ground penetrating radar

JFMJRm1 r

Attacbmr middot

0

I I

~ I I

J I

J F Murphy Jr April 13 1983

Page 6

done with a bulldozer and very little eart~ coverage was done until the hole was almost filled The contents of the landfill is probashybly almos t completely non-homogenous The dried coagulum froca the Primary Lagoon may be in pockets distributed around the landfill

I only because they were transported in truckload lots from the Pri~ - mary Lagoon

After the early 1960s when the original kettle hole was filled the landfill operation moved to the 2 acres east where trenches were dug The dirt was stored on either aide of the trench and from middottime-to-time used to cover the discarded material which was placed in the trench This eastern half of the landfill was excavated and filled to a 10 to 12 foot depth on the average

middot There are several plac~s in the landfill where large objects have been buried One of these is the body of a tank truck which is filled with set-up compound placed in the landfill in the early1970bullmiddot

The truck was about a third full of a hexane based container sealing compound which set up (jelled) and could not be economically removed

The other large object in the landfill is the former blowdown tank froa the Organic Chemical plant operation This is a 5000 gallon tank that is full of coagulated latex not dissimilar to the sludge removed from the Primary Lagoon and deposited occasionally in the landfill This tank was on the emergency vent line from the reacshytors in Building 13 in the Acton plant

These items were located by ground penetrating radar

JFMJRm1 r

Attacbmr middot

0