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PRELIMINARY SITE ASSESSMENT FOR

NEW HAMPSHIRE PLATING COMPANY MERRIMACK HILLSBOROUGH COUNTY NEW HAMPSHIRE

Prepared for

US Environmental Protection AgencyEmergency Planning amp Response Branch

60 Westview Street Lexington MA 02i73

CONTRACT NO 68-01-7367

TAT-01-N-00415

TDD NO 01-8902-10A

Prepared by

ROY F WESTON INC Major Programs Division Technical Assistance Team

Region I

June 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

LIST OF ATTACHMENTS V

10 PURPOSE 1

20 SITE DESCRIPTION 1

30 SITE HISTORY 5

40 SITE ASSESSMENT 9

50 PRELIMINARY FINDINGS 12

REFERENCES 12

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LIST OF FIGURES

PAGE

1 General Location Map New Hampshire Plating CompanyMerrimack New Hampshire bull 2

2 Site Sketch Map New Hampshire Plating CompanyMerrimack New Hampshire 4

3 Sampling Locations New Hampshire Plating CompanyMerrimack New Hampshire March 24 1989 10

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LIST OF TABLES

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Table 1 Maximum Concentrations Detected in Lagoon WaterGroundwater and Sludge Samples Collected in 1981 and 1982 6

Table 2 New Hampshire Plating Company Soil Sample Results1987 8

Table 3 Lagoon Sludge Sampling Results NH Plating CompanyMerrimack NH March 24 1989 11

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LIST OF ATTACHMENTS

A Sampling Plan

B Chain of Custody and Analytical Results for Samples Collected at New Hampshire Plating Company Merrimack New HampshireMarch 24 1989

C EPA Bioassessment

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10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

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42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

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GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

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west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

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30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

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TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

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SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

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200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

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TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

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FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

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TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

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50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

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REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

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LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

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LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

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10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

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The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

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Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

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Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

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spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

LIST OF ATTACHMENTS V

10 PURPOSE 1

20 SITE DESCRIPTION 1

30 SITE HISTORY 5

40 SITE ASSESSMENT 9

50 PRELIMINARY FINDINGS 12

REFERENCES 12

ii

LIST OF FIGURES

PAGE

1 General Location Map New Hampshire Plating CompanyMerrimack New Hampshire bull 2

2 Site Sketch Map New Hampshire Plating CompanyMerrimack New Hampshire 4

3 Sampling Locations New Hampshire Plating CompanyMerrimack New Hampshire March 24 1989 10

iii

LIST OF TABLES

PAGE

Table 1 Maximum Concentrations Detected in Lagoon WaterGroundwater and Sludge Samples Collected in 1981 and 1982 6

Table 2 New Hampshire Plating Company Soil Sample Results1987 8

Table 3 Lagoon Sludge Sampling Results NH Plating CompanyMerrimack NH March 24 1989 11

iv

LIST OF ATTACHMENTS

A Sampling Plan

B Chain of Custody and Analytical Results for Samples Collected at New Hampshire Plating Company Merrimack New HampshireMarch 24 1989

C EPA Bioassessment

v

10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

l

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

3

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

I

I

I

I

pound ATTACHMENT A

SAMPLING PLAN

I

I

I

I

I

I

I

I

I

I

I

I

I

I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

LIST OF FIGURES

PAGE

1 General Location Map New Hampshire Plating CompanyMerrimack New Hampshire bull 2

2 Site Sketch Map New Hampshire Plating CompanyMerrimack New Hampshire 4

3 Sampling Locations New Hampshire Plating CompanyMerrimack New Hampshire March 24 1989 10

iii

LIST OF TABLES

PAGE

Table 1 Maximum Concentrations Detected in Lagoon WaterGroundwater and Sludge Samples Collected in 1981 and 1982 6

Table 2 New Hampshire Plating Company Soil Sample Results1987 8

Table 3 Lagoon Sludge Sampling Results NH Plating CompanyMerrimack NH March 24 1989 11

iv

LIST OF ATTACHMENTS

A Sampling Plan

B Chain of Custody and Analytical Results for Samples Collected at New Hampshire Plating Company Merrimack New HampshireMarch 24 1989

C EPA Bioassessment

v

10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

l

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

3

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

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Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

LIST OF TABLES

PAGE

Table 1 Maximum Concentrations Detected in Lagoon WaterGroundwater and Sludge Samples Collected in 1981 and 1982 6

Table 2 New Hampshire Plating Company Soil Sample Results1987 8

Table 3 Lagoon Sludge Sampling Results NH Plating CompanyMerrimack NH March 24 1989 11

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LIST OF ATTACHMENTS

A Sampling Plan

B Chain of Custody and Analytical Results for Samples Collected at New Hampshire Plating Company Merrimack New HampshireMarch 24 1989

C EPA Bioassessment

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10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

l

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

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30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

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TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

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SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

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TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

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TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

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50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

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REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

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LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

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10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

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Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

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Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

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spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

LIST OF ATTACHMENTS

A Sampling Plan

B Chain of Custody and Analytical Results for Samples Collected at New Hampshire Plating Company Merrimack New HampshireMarch 24 1989

C EPA Bioassessment

v

10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

l

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

3

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

I

I

I

I

pound ATTACHMENT A

SAMPLING PLAN

I

I

I

I

I

I

I

I

I

I

I

I

I

I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

10 PURPOSE

In March 1989 Roy F Weston (Weston) received a Technical Direction Document (TDD No 01-8902-10A) to provide technical assistance to the US EPA Region I Emergency Planning amp ResponseBranch by performing a preliminary assessment of the New HampshirePlating Company Inc Site located in Merrimack New HampshireThe purpose of this investigation is to evaluate the site and determine if conditions meet the National Contingency Plan (NCP)Section 30065 criteria for a removal action under CERCLA as amended by the Superfund Amendments and Reauthorization Act (SARA)of 1986 The site has been under investigation by the New Hampshire Department of Environmental Services (DES) and was referred to the EPA by John Duclos Environmentalist New Hampshire DES Waste Management Division State funding to continue work at the site is expected to cease following the completion of an extensive hydrogeologic report in April 1989 The DES has indicated that it would like the EPA to assume the lead regardingfurther action at the site including potential cleanup activities The facility operated under RCRA interim status from 1980 to 1985 when it ceased operations due to an inability to comply with EPAs ratification requirements to retain interim status as a treatmentstorage and disposal (TSD) facility The site has been evaluated under the hazard ranking system (HRS) but is not a designated NPL site As part of the preliminary site assessment the Weston Technical Assistance Team (TAT) reviewed background information obtained from the New Hampshire DES conducted a visual site inspection and collected samples for laboratory analyses to document and evaluate site conditions All materials referenced in this report are presently available for inspection at the US EPA Region I Emergency Planning and Response Branch 60 Westview Street Lexington MA 01872 The following sections of this report provide information regarding the site investigationincluding results of sample analyses and a discussion of preliminary findings

20 SITE DESCRIPTION

The New Hampshire Plating Company Site is located on Wright Avenue in Merrimack New Hampshire The site occupies two parcels of land approximately five acres situated in the central portion of the Nashua North Quadrangle (42 51 IV N latitude and 71 29 17 W longitude) The property is defined on the Town of Merrimack property map 4D-2 parcels 2 and 3 The site is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond a recreational surface water of the State of New Hampshire (Figure 1) The area surrounding the site is lightlyindustrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR fto the east a wetland area to the west and Wright Avenue to the south The nearest residential areas are along State Route 3 approximately 05 miles

l

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

3

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

yreg NASHUA NORTHNHSW4 MANCHESTER 13 QUADRANGLE

42071-G4-TF-024

1968 PHOTOREVISEO 198S DMA STS9 (V SW-SERIES V8I2

s bull JU 3V-^ mdash--I

GENERAL LOCATION MAPNEW HAMPSHIRE PLATING COMPANY

MERRIMACK NEW HAMPSHIRE APPROVED G MAVRIS

TOO raquo 01-8902-1OA

I I

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

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30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

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TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

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SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

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7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

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TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

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TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

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50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

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LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

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Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

west of the site and along Horseshoe Pond A pre-school is located in this area

The New Hampshire Plating Company (NHPC) is an abandoned metal plating facility which primarily utilized gold silver tincopper nickel cadmium chromium and other metals in their electroplating process As a result of these processes the companygenerated chemical wastes consisting of spent plating bath solutions and sludges which contained cyanide heavy metalschlorinated solvents and acids The facility consists of a single building a parking lot and a waste disposal lagoon systemThis lagoon system is situated north of the building and parkinglot and is comprised of three separate but connected surface impoundments which received untreated and treated plating wastes The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped downgradient and about twice the size of the first The third lagoon was used to receive Overflow from the second lagoon and is also irregularly shaped but slightlysmaller than the primary lagoon The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment The lowest lagoon is located below the intermediate flood level of the Merrimack River Between the parking lot and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from the banks (Figure 2)

According to the preliminary site investigation report prepared byWehran Engineering in 1984 the facility is underlain by alluvial sediments deposited by the Merrimack River and other glaciallyderived sediments Test borings conducted by Wehran Engineering1984 indicated that the bedrock is approximately 100 feet below the present grade and that soils are made up of a series of siltsand and siltclay layers Groundwater flow is to the south which is opposite to that of surface water in the vicinity of the lagoons

There are both confined and unconfined aquifers in the region due to a confining siltclay sequence The contour of this layer also controls the lateral movement of the upper aquifer resulting in a complex pattern of groundwater movement compared to the regionalgroundwater flow toward the Merrimack river

3

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

30 SITE HISTORY

Background information compiled about the site dates back as far as 1962 and was compiled from NH DES site file reports The owners of the land since inception of the site in 1962 are Aldo and Ida Bracci They have leased the land to NHPC since that time Mr Aldo Bracci and Jack O Labovitz owned the company from 1962 to 1972 at which time Mr Labovitz resigned and sold his interest to Mr Bracci Mr Bracci then became sole shareholder and principalofficer

NHPC routinely discharged cyanide wastes sludges acids and solvents into the lagoon system during the operating life of the plant The NH DES 1986 preliminary assessment reported that NHPC ceased using solvents for degreasing purposes during the later 1970s The first notification the US EPA received from NHPC of its status as a disposal facility was when NHPC filed for a permiton November 6 1980 During April 1982 a RCRA inspection was conducted at the facility which resulted in a Notice of Violation and Order of Abatement (NOVOA) siting twelve violations A preliminary injunction was issued in 1983 which ordered NHPC to neutralize acids treat cyanides and maintain a lagoon pH of 9mdash 10 From 1982 to 1985 a total of four RCRA inspections were conducted at the facility all of which noted non-compliance with the original NOVOA of 1982 In 1983 the State of New Hampshirefiled a suit for preliminary injunction permanent injunction and civil penalty which resulted in a $600000 attachment of propertyaward to the State It should be noted that NHPC complied with the conditions of the preliminary injunction except for cyanide treatment standards

In November 1985 approximately 600 gallons of treatment tank material were emptied onto the ground adjacent to the northside of the building

During the last RCRA inspection in November 19Sl5pound NHPC ceased operations due to their inability to comply with 40[CjR265 subpartF G and H requirements and submit a Part B permft-^application

In 1987 the NH DES conducted a removal action at the NHPC facility All hazardous wastes inside the facility as well as the buildings interior surfaces were cleaned The primary lagoon was also treated with lime and a solution of chlorine in an efforts to minimize soil contamination

31 Site Analytical History

A review of the NH DES site files indicated that samplingactivities at the site began in 1981 The maximum concentrations of contaminants detected in lagoon water groundwater and sludgesamples collected in 1981 and 1982 and analyzed by NH DES are found in Table 1 The concentrations of inorganic contaminants are reported in parts per million (ppm) The concentrations of

5

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

I

I

I

I

pound ATTACHMENT A

SAMPLING PLAN

I

I

I

I

I

I

I

I

I

I

I

I

I

I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE 1 MAXIMUM CONCENTRATIONS OF CONTAMINANTS DETECTED IN

LAGOON WATER GROUNDWATER AND SLUDGE SAMPLES

INORGANIC CONTAMINANTS

CADMIUM (01)CHROMIUM (05)COPPER CYANIDE (TOTAL)CYANIDE (AMENABLE)GOLD IRON LEAD (05)MANGANESE MERCURY (002)NICKEL SILVER (05)TIN ZINC

VOLATILE ORGANIC CONTAMINANTS

CARBON TETRACHLORIDE ETHYLBENZENE CHLORODIBROMOMETHANE METHYLENE CHLORIDE TETRACHLOROETHYLENE TOLUENE TRICHLOROETHYLENE TRICHLOROMETHANE T-12 DICHLOROETHYLENE 11 DICHLOROETHYLENE 11 DIGHLORETHANE 111 TRICHLOROETHANE

COLLECTED IN 1981 AND 1982

(CONCENTRATIONS IN PPM)LAGOON WATER GROUNDWATER

12 15 34 140 120

11 002 024

90

03 95

LAGOON WATER GROUNDWATER

95 lt5

103 60

379 73 90 990

234 261 30

200 lt5 165

238 400

046 0536111 155

20 008 213

00075

0013 12

051

(CONCENTRATIONS IN PPB)

MCL = Maximum Contaminant Level MCLs for potable water are given in parenthesesfor inorganic contaminants

6

SLUDGE

89200 22000 62000 4500

421062000860 1200

15000 167

42000

MCL

5

7

200

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

volatile organic contaminants are reported in parts per billion (PPb)bull

As indicated in Table 1 extremely high levels (greater than 10000ppm) of cadmium chromium copper iron nickel and zinc were detected in the sludge samples collected from the lagoon systemThe maximum concentration for total cyanide detected was 4500 ppmMany of these contaminants appear to have leached into the groundwater as evidence by the levels of contamination found in the groundwater These levels are greater than the federal potablewater maximum contaminant levels (MCL)s established for Cadmiumchromium mercury and silver The maximum concentration of total cyanide detected in the groundwater was 155 ppm which is greaterthan the one day EPA health advisory of 02 ppm In December 1982 a cyanide concentration of 058 ppm was detected in a surface water sample collected from Horseshoe Road

A total of nine volatile organic contaminants (VOG)s were detected in the groundwater at maximum concentrations ranging from 10 to 990 ppb All compounds with assigned MCL values exceeded allowable concentrations for potable water However six surface water samples collected by NH DES on July 20 1988 from Horseshoe Pond and the Merrimack River were found to contain no detectable levels of VOCs and less than 01 ppm cyanide

The concentrations of inorganic contaminants found in sedimentsludge samples collected (by NH DES) from the lagoonsystem and Horseshoe Pond in February 1987 are found in Table 2 The levels of contamination displayed in Table 2 are still extremely high for lagoon-1 despite an overall decrease in levels compared to levels detected in 1981-1982 The decrease in levels may reflect the present inactivity of the site and the dispersalof contaminants over time

Facility Address New Hampshire Plating Company Inc Wright Avenue Merrimack New Hampshire 03054

US EPA ID NO NHD 001091453

Potentially Site Owner and OperatorResponsible Aldo Bracci Party 75 Dublin Avenue

Nashua New Hampshire 03063

TelephoneNumber 603-882-3610

7

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE 2

NEW HAMPSHIRE PLATING COMPANY SOIL SAMPLE RESULTS 1987

INORGANIC STATION LOCATION CONTAMINANT SS-1 SS-2 SS-3 SS-4 SS-5 SS-6 SS-7 SS-8 SS-9 SS-10 SS-11 SS-11

CONCENTRATIONS IN PPM ARSENIC 45 63 106 4 5 16 20 22 33 lt10 57 186 168

CADMIUM 350 1950 3650 2000 300 840 200 150 lt20 lt20 lt20 lt20

CHROMIUM 700 3000 6800 4200 600 1800 lt200 350 800 lt200 800 600

COPPER lt100 100 200 lt100 200 200 85 185 lt100 100 lt100 100

IRON 13500 21450 30500 17400 9000 9000 5400 7300 4000 9400 8500 9500 00

LEAD 30 150 160 150 20 60 20 50 30 40 40 30

NICKEL 550 1650 1100 600 lt200 200 lt200 lt100 lt200 lt200 lt200 lt200

SILVER lt20 30 50 lt20 lt20 20 lt20 36 lt20 lt20 lt20 lt20

SODIUM 1500 300 700 1100 700 800 400 700 900 600 400 700

ZINC 6000 13700 27500 24000 5000 7000 1700 2700 lt1000 lt1000 6000 4000

CHLORIDE lt200 lt200 lt200 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400 lt400

SULFATE lt100 120 230 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200 lt200

CN (amenable) 1403 496 28 670 lt80 lt80 123 40 NA NA NA NA

CN (total) 2086 1665 758 1020 225 614 106 16 lt20 lt20 lt20 lt20

MANGANESE 175 208 345 220 i40 140 63 90 40 100 HO 220

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

Previous Type Generator Treatment Storageof Operation Disposal

40 SITE ASSESSMENT

An initial site visit was conducted by the TAT at the New HampshirePlating Company on February 27 1989 TAT member Dennis Giustra travelled to the site with Alex Sherrin US EPA and met John Duclos New Hampshire DES to perform a brief walk-throughinspection The facility and surrounding area were found to be as previously described The facility building had been abandoned and no evidence of current site activities existed The lagoon waste disposal system was also inspected The primary lagoon and other surface impoundments were found to be surrounded by a chain-link fence which was locked Snow cover at the time of the inspectionprecluded any visual determination of the lagoon contents At the conclusion of the site visit the EPA indicated that samples from the lagoon needed to be taken to confirm the states previousanalyses Oh Friday March 24 1989 TAT member Dennis Giustra and Steve Allen returned to the NHPC site to perform samplingactivities The TAT members accompanied by Dennisses Valdes US EPA met with John Duclos and John Regan New Hampshire DES Six subsurface sludge samples (including one duplicate sample) were collected from the primary lagoon(Figure 2) and were submitted for total metals and total cyanide analyses (Attachment A) Sampledepths ranged from 0 to 3 feet No problems were encountered during the sampling visit and all samples were obtained in generalaccordance with the sampling plan prepared for this site All analyses were performed at the US EPA New England RegionalLaboratory (NERL)

The six subsurface sludge samples were screened for heavy metals including chromium cadmium tin and zinc using an x-rayfluorescence screening method Atomic Absorption spectroscopy was used to confirm the x-ray fluorescence results The same sampleswere analyzed for total cyanide using method 9010 (SW-846) The results of these analyses are found in Table 3 The metals analyses correlate well with those state values found in Table 2 for Lagoon-1 The total cyanide levels detected in the six samplescollected by Weston range from 710 to 1280 ppm and comparefavorably to those values obtained by the state in 1987 (76-1020ppm)

9

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

FIGURE 3 Sampling Locations New Hampshire Plating Co

PCS sectZMiMerrimack New Hampshire fa

SSS9SSB9SSBBBSHS

APPROVED DATE TO)March 24 1989 3TJ oi-noi- ioAgM

10

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE 3

LAGOON SLUDGESAMPLING RESULTS NH PLATING COMPANY MERRIMACK NH

MARCH 241989

SAMPLE pH TOTAL

CYANIDE CADMIUM CHROMIUM TIN ZINC

78467 655 710 1800 1000 2400 12000

78468 650 880 1600 800 5000 10000

78469 640 990 2500 1400 4000 12000

78470 640 810 2000 2400 2400 20000

78471 670 1280 1800 1400 1700 12000

78472 740 990 1200 800 1400 7000

concentrations are reportedin ppm pH values are reported in pH units

11

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

50 PRELIMINARY FINDINGS

The sampling activities conducted by Weston TAT on March 24 1989 confirm the presence of heavy metals contamination in the lagoonsystem at the NH Plating Site The maximum concentrations of cadmium chromium tin and zinc were found to be 2500 2400 5000and 20000 ppm respectively In addition the maximum total cyanideconcentration measured in the lagoon system was 1280 ppm

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment Previous sampling activities conducted by the NH DES have confirmed the presence of cyanide and other contaminants in groundwater suggesting that these contaminants are migrating off-site

12

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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I

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

REFERENCES

New Hampshire Division of Public Health Services (DPHS) 1985 Preliminary Assessment of the New Hampshire Plating CompanyInc Site Wright Avenue Merrimack NH October 25 1985

Wehran Engineering (WE) 1984 Preliminary Site InvestigationReport Prepared for the New Hampshire Plating Company IncMerrimack New Hampshire December 1984

13

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

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pound ATTACHMENT A

SAMPLING PLAN

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NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

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TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

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Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

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411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

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51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

NEW HAMPSHIRE PLATING CO SAMPLING PLAN

MERRIMACK NEW HAMPSHIRE

Prepared For

US Environmental Protection AgencyRegion I

60 Westview Street Lexington MA 02173

CONTRACT NO 68-01-7367

TAT-01-N-00379

TDD NO 01-8902-10A

Prepared By

ROY F WESTON INC Technical Assistance Team

Region I

March 1989

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE OF CONTENTS

PAGE

LIST OF FIGURES iii

LIST OF TABLES iv

10 INTRODUCTION 1 11 Background 1

20 SAMPLING OBJECTIVES 2 21 Project Organization and Responsibilities 4

30 QUALITY ASSURANCE OBJECTIVES 4

40 APPROACH AND SAMPLING METHODOLOGIES 4 41 Sample Locations 4 42 Sample Collection Procedures 7 43 Field Decontamination 7 44 Analytical Requirements 8

50 QUALITY ASSURANCE REQUIREMENTS 8 51 QAQC Samples 9 52 Data Validation 9 53 Sample Documentation 9 54 Chain of Custody and Sample Transport 9

60 HEALTH AND SAFETY CONSIDERATIONS 10

ii

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

LIST OF FIGURES

PAGE

FIGURE 1 - General Location Map New Hampshire PlatingCompany Site Merrimack New Hampshire 3

FIGURE 2 - Sample Locations New Hampshire PlatingCompany Site Merrimack New Hampshire 6

iii

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

5

LIST OF TABLES

PAGE

TABLE 1 Field Sampling Summary New Hampshire PlatingCompany Merrimack New Hampshire

iv

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

10 INTRODUCTION

In March 1989 Roy F Weston Inc Technical Assistance Team (TAT) received a Technical Direction Document (TDD 01-8902^10A)to provide technical assistance to the US Environmental Protection Agency (EPA) Region I Emergency Planning amp ResponseBranch (EPRB) by conducting a site assessment of the New HampshirePlating Company Site in Merrimack New Hampshire Contamination by heavy metals and cyanide as a result of former electroplatingactivities on-site by New Hampshire Plating has been documented by the State of New Hampshire Department of Environmental Services (DES) Sampling activities have subsequently been deemed necessaryby the EPA to confirm the states analyses and provide EPA with additional analytical data to support further action at the site The results of these sampling activities are to be included in the preliminary site assessment report prepared by the TAT

The following section of this plan provide information regarding the site and activities to be conducted as part of the proposed sampling visit

11 Background

The New Hampshire Plating (NHP) Company Site is located on Wright Avenue in Merrimack Hillsborough County New Hampshire The site occupies approximately three acres in the central portion of the Nashua North Quadrangle (42deg 51 17 N latitude and 72deg 29 17 w longitude) and is situated about 1000 feet west of the Merrimack River and 1500 feet north of Horseshoe Pond (Figure 1)

The area surrounding the site is lightly industrial and commercial A chemical company exists north of the site and a concrete mixing operation is located to the west The site is bordered by the Boston amp Maine RR to the east and Wright Avenue and a wetland area to-the-south The nearest residential areas are along State Route 3 approximately 05 miles west of the site and along Horseshoe Pond

The New Hampshire Plating Company was engaged in the business of coating metal parts with gold silver tin copper nickelzinc Cadmium chromium and other substances utilizing an electroplating process As a result of this process the companygenerated chemical wastes consisting of spent plating bath solutions and sludges from the bottom of plating baths containingcyanide heavy metals and solvents

The facility which began operations in 1962 and closed in 1985 consists of a single building a parking area and a waste disposal lagoon system This system is situated north of the building and parking lot and is comprised of three separate but connected surface impoundments which received untreated or inadequately treated plating wastes

1

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

The lagoon system is aligned along a roughly northerly trend The first and primary surface impoundment is rectangular in shapeapproximately 250 feet long and 100 feet wide Plating wastes were fed to this lagoon by an outlet pipe connected to the facilitybuilding Overflow from this lagoon was collected in a second lagoon which is irregularly shaped and about twice the size of the first The third lagoon was used to receive overflow from the second one and is also irregularly shaped but slightly smaller than the primary lagoon This lower impoundment is believed to intersect the groundwater table near the northern boundary of the NHP property

The lagoon system is unlined and has no leachate detection or collection system to prevent the contents from entering the surrounding environment (soils groundwater surface water) The maximum sludge thickness in the primary lagoon has been estimated at 6 feet Standing water is typically present after heavyrainfalls The lagoon system is located below the intermediate flood level of the Merrimack River Between the parking area and southwest corner of the primary lagoon is a low wet area which apparently ponds water seasonally The entire lagoon system is surrounded by a six-foot chain-link fence set approximately ten feet away from its banks A locked gate is present at the southern end of the primary lagoon near the outfall of the waste dischargepipe

Sample analyses have shown significant concentrations of cyanide in the lagoon liquid (120 ppm) and in the lagoon sludge(4500 ppm) Low level contamination has also been detected in ground and surface water in the vicinity of the site These contaminants include cyanide heavy metals and chlorinated solvents

In July 1987 the State of New Hampshire DES removed all hazardous wastes form inside the NHP Company building and surface cleaned the interior Additionally the waste lagoon was treated with lime and a chlorine solution and an extensive hydrogeologicstudy of the site was performed by the DES The results of this study have not yet been released

20 SAMPLING OBJECTIVES

The sampling visit by Weston TAT will involve the collection of up to 6 sludge samples from the primary lagoon located at the NHP site Portions of the lagoon to be sampled were determined upon review of previous site investigations and guidance received from US EPA EPRB The specific objectives of the sampling visit at the NHP site are as follows

o Identify heavy metals and cyanide contaminants presentin sludge material by collecting samples from the lagoonon-site

2

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

Sourse USGS 75 Quadrangle Nashua North 1968 shyPhoto Revised 1985

Figure

US Geological Survey Quagrangle Map

New Hampshire Plating Company Site Merrimack NH

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

o Verify previous analyses performed on sludge material obtained from lagoon which yielded significantconcentrations of contaminants

o Provide US EPA with analytical data which can be used to support further action at the site

21 Project Organization and Resposibilities

The following is a list of key project personnel and their

US EPA New England Regional Laboratory Laboratory QC

corresponding responsibilities

Roy F Weston Technical Assistance Team Dennis GiUstra Steve Allen

Sampling QCSampling OperationsData Quality Review

US Environmental Protection AgencyAlex Sherrin Dennisses Valdes

-Project Coordinator Site InvestigationOverall QA

-Sample Analysis

Data Processing QC

30 QUALITY ASSURANCE OBJECTIVES

The quality assurance objectives for sampling activites at the NHP site are to provide data which verify contaminant identification and quantification through laboratory analysis and analytical screening methods The data generated must be of sufficient quality to support a removal action decision based on action levels established for the site or other NCP criteria To accomplish this objective all samples will be analyzed for total cyanide following standard EPA NERL protocol All samples will also be screened for the presence of total metals using x-rayfluorescence followed by a definitive quantification of at least two of these samples using laboratory and quality assurance methods

40 APPROACH AND SAMPLING METHODOLOGIES

41 Sample Locations

The proposed sampling visit and extent of sampling are based primarily upon specific guidance provided by US EPA EPRB and information gathered and evaluated during previous site investigations Sampling will generally occur within areas expected to yield the highest levels of contamination without trying to fully characterize the sludge material found in the waste lagoon system Table 1 summarizes the sampling to be conducted within these areas Sample locations and numbers designated in Table 1 are shown in Figure 2

4

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

TABLE 1

FIELD SAMPLING SUMMARY HEU HAMPSHIRE PLATING COMPANY MERRIMACK NH

ANALYTICAL TOTAL SAMPLE LOCATION SAMPLE MATRIX CONTAINER TYPE PRESERVATIVE METHOD REF FIELD SAMPLES

Primary Lagoon

NHP-1 NHP-2 Sludgesoil 1x8 oz glass jar Cool to 4degC Cyanide SW-846 NHP-3 NHP-4 grab 1x4 oz glass jar Metals SW-846 NHP-5

NHP-1D SludgesoiI 1x8 oz glass Jar Cool to 4 C Cyanide SW-846 duplicate 1x4 oz glass jar Metals SW-846

5

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

I

Fence

Primary Lagoon

Discharge Pipe Outfall

Approx Property

Boundary

Parking Area

Not to scale

FIGURE 2 Sampling Locations New Hampshire Plating Co OHAI Merrimack New Hampshire

APPROVED

MTM

PCS 9zli

DATE TDD 9 2141 0-W2-1OA

I

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

411 Primary Laaoon

The primary lagoon is located approximately 150 feet north of the NHP Company building and occupies an area of approximately25000 square feet The NHP electro-plating process resulted in the generation of spent plating bath solutions and sludges which were discharged from the processing area (inside of building) to the lagoon system For approximately 20 years the company disposedof wastes by discharging them in this manner Subsequently the primary lagoon has been found to contain significant concentrations of cyanide and heavy metals Elevated levels of these contaminants have also been detected in the soils of the second and third lagoonwhich received overflow from the first

During the sampling visit sludgesoil samples will be collected from the primary lagoon to identify contaminants presentSamples will primarily be obtained along the edge of the lagoonThe exact locations of these samples will be determined in the field and accurately documented in a bound field logbook All samples collected from the primary lagoon will be analyzed for total cyanide and heavy metal parameters

42 Sample Collection Procedures

All samples will be collected with US EPA-approved samplingdevices and procedures In general samples will be analyzed byfollowing US EPA-approved test methods for evaluating solid waste and chemical analyses of water and wastes Sample volumes required by analytical procedures and quality control specifications will follow levels outlined by the US EPA New England Regional Laboratory (NERL)

421 SludgeSoil Samples

A total of six sludgesoil samples (including one duplicatesample) will be collected during the NHP Company sampling visit All samples will be grab type samples collected with precleaneddisposable plastic scoops Samples will be collected at shallow depths of 0 to 6 inches at all locations Sample material will be placed on a plastic tray or in a polyethylene bag Once enoughsample material has been obtained it will be thoroughly mixed and transferred into one (or more) precleaned 8-ounce wide-mouth glass jars with Teflon-lined lids using the same sample scoop used to collect the sample

If representative sludgesoil samples are not obtainable near the lagoon edge a sludge sampler with an extension device will be used to collect the sample further from the edge

43 Field Decontamination

All sampling equipment used during the sampling visit will be precleaned at Weston TAT prior to the start of site activities

7

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

Sufficient equipment will be available to minimize reuse during the course of sampling therefore field decontamination of samplingequipment is not anticipated When equipment is to be reused it will be field decontaminated according to the following procedure

1 Brush off loose dirt with a soft bristle brush or cloth 2 Rinse thoroughly with tap water 3 Wash with nonphosphate detergent in water 4 Rinse thoroughly with tap water 5 Rinse with pesticide-grade hexane or methanol (rinsate

will be collected for proper disposal)6 Rinse thoroughly with deionized water 7 Air dry equipment in a clean area 8 Wrap in aluminum foil or store in plastic bags

All decontamination procedures will be documented in the field logbook Field decontamination will not be performed on any pieceof equipment more than once between formal decontamination

44 Analytical Requirements

Laboratory sample analyses will be performed by the US EPA NERL in accordance with procedures specified under the EPA Contract Laboratory Program (CLP) and SW-846 Routine analytical services will be required for the sludge samples collected for total cyanideand total metal analyses

Metal samples will initially be screened using an x-rayfluorescence spectrophotometer to tentatively identify and quantifyheavy metals present Based on this screening two or more sampleswill be selected for complete laboratory analysis followingstandard EPA protocol Total metal parameters will include at a minimum cadmium chromium lead nickel and zinc

50 QUALITY ASSURANCE REQUIREMENTS

Quality assurance requirements which apply to the samplescollected from the New Hampshire Plating Company include sampledocumentation chain of custody sample holding time definitive identification and quantification initial and continuinginstrument calibration and 10 matrix spike and matrix spikeduplicate analysis following standard EPA NERL protocol and methodology These indicators will be used to evaluate the data necessary to meet the QAQC objectives for the sampling activities as previously stated

Sampling methods detailed in this sampling plan will be strictly adhered to deviations from or additions to this plan will be carefully documented in a bound field logbook All field observations field-generated forms and labels will be entered into the logbook

8

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

51 OAOC Samples

One duplicate sludgesoil sample will be collected during the sampling visit at the NHP Company facility This sample will be collected to enable duplicate analysis for the sample matrix and analytical parameters This duplicate analysis will help providea measure of laboratory precision

52 Data Validation

US EPA NERL will conduct an internal data validation review prior to releasing sample results A data quality review will be performed by Weston TAT upon receipt of results from the EPA These results will be incorporated into a site assessment reportto be delivered to EPA EPRB following the completion of all sampling and analysis activities

53 Sample Documentation

Immediately upon collecting a sample the sampling team will complete all labeling and chain-of-custody records Once the samples have been collected and placed in appropriate containers a signed chain of custody seal will be placed on the top of each container A sample card will then be completed with a uniquesample identification number for each station location Each container from a particular sample location will (1) be labeled with the unique identification number and (2) possess a sample tagidentifying the sample location date time and analyses to be performed All sample cards will be provided to the US EPA as part of the sample documentation In addition all field observations will be recorded in a bound field logbook

54 Chain of Custody and Sample Transport

Once a sample is collected containerized and labeled the sampling team will enter the appropriateinformation on a standard field chain-of-custody record This -custody record will (1)provide the information necessary to cross-reference the samplenumber to the specific sampling location (2) provide the date and time of collection and (3) document sample possession This form will be provided to the US EPA and will accompany the samples to the laboratory Until shipment or delivery to the laboratory all samples will be kept in view or in a locked vehicle at all times

Samples will be packaged in paint cans and coolers marked as hazardous material samples in compliance with Roy F Weston corporate policy for sample transport The paint cans will be placed in a cooler and packed in a manner that transport minimizes the chances of breakage or cross-contamination of samples Ice will be placed in a plastic bag and packed in the cooler with the paint cans Vermiculite (or equivalent) will be used to cushion the contents of the cooler and act as an absorbent in case of

9

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

spillage The cooler will be secured with strapping tape Custodyseals will be placed on the cooler during shipment to ensure custody is maintained until laboratory receipt The cooler will be delivered by Weston TAT to the US EPA New England RegionalLaboratory scheduled to perform the analyses

60 HEALTH AND SAFETY CONSIDERATIONS

To ensure the safety of all field personnel a Weston TAT Health and Safety Plan has been completed as part of the samplingplan All field personnel will thoroughly review and understand each component of the Health and Safety Plan and complete sections on emergency procedures prior to any sampling activities

All personnel will be enrolled in an active medical surveillance program and will have received a complete annual physical examination within the past year All personnel will be authorized to use respiratory protection before any on-site work The level of protection will be determined through ambient air monitoring using an organic vapor analyzer (or a photoionizationanalyzer)and cyanide monitor The standard criteria that are to assign the appropriate level of respiratory protection are summarized below

Level D lt0 ppm above off-site ambient and nuisance odors Level C 0 to 5 ppm above off-site ambient Level B 5 ppm to 99 ppmLeave Site gt99 ppm

All measurements will be taken at the breathing zone

While working around waste materials the immediate hazard is skin contact andor inhalation Coveralls or Tyvek suits should be worn for general dermal protection Gloves (nitrile or equivalent) should be worn during sample collection and handlingAn air purifying respirator (Level C) should be worn during samplecollection as part of minimal personal protective equipment -when site conditions warrant Other appropriate standard minimum protection gear include steel-toe boots a hard hat and safetyglasses

Sampling personnel will be equipped with safety belts and safety lines whenever collecting samples at the edges of lagoonsor impoundments

No eating drinking or smoking will be allowed on-site exceptin designated areas and after proper decontamination

10

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

ATTACHMENT B

Chain-of-Custody and Analytical Results for Samples Collected at

New Hampshire Plating CompanyMerrimack New Hampshire

March 24 1989

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

ON1

Office of Enforcement JFK Federal BuildingRm22Q3 CHAIN OFCUSTODYRECORD BostonMassachusetts 02203

PROJNO PROJECTNAME

Zffl NH P1o^-t rg CppfQw NO SAMPLERS(Signature -v

OF

CONshyTAINERS

STA NO DATE TIME STATION LOCATION

kJHP-i CWgt

MKP-fo CfiHo 1 sc1^1lt-S

|CTP 5ZW jopoundgtM-S 18HT0

MHf-H (030 Wll jjtVP-T loSS bullV Tmi

X XX X

X XRelinquished bySignature) DateTime Received by(Signature) Relinquished by(Signature) DateTime Received by )Signature)

Relinquished by (Signature) Date Time Received by (Signature) Relinquished by (Signature) DateTime Received by(Signature)

Relinquished by (Signature) DateTime Received for Laboratoryby Date Time Remarks (Signature)

ltft chTV Q Kplusmn amp(raquozff=4bffi- u r Distribution Original Accompanies Shipment Copy to Coordinator Field Filesr tor I A

1- 3461 i

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

c

US ENVIRONMENTAL PROTECTION AGENCY REGION I

PROJECT ftjVl Co STATE

GxsknraquofoUeltCOLLECTOR

FIELD OBSERVATIONS CLEA^OVERCASlO^AIN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B ac t i N H 3 C O D B OU N 0 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r ga n i c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb [2 Cu Hg

Sdeg -7Cr (T) M n Z n Z bdquo v

^Cr ( + 6) N i Other CJj

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCY REGION I

KM HcAir^Co STATE tWrWaokPROJECT

COLLECTOR Qt JLJSW FIELD OBSERVATIONS CLEAj 5VERCAST]gtAIN SNOW FOG

PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c ti N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _ O rgani c s O amp G V O A s

M E T A L S Dissolved

Cd Fe Pb (Z Cu Hg Sn -r Cr (T) 7 M n Zn J_ Cr ( + 6) N i Other

Unpreserved SampleEPA R-1 7500-30

LAB CODE N9 78471

PROJECT

STATION manacii

Y Y M M D D

DATE aaaBHEi

COLLECTION TIME nrn-ia

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY J - D (micromhoscm)

SALINITY (000) |_

TOTAL DEPTH (ft) [

SAMPLING DEPTH (ft)[ 1shy

LAB CODE N9 78472

PROJECT r STATION

Y Y M M D D

DATE bullkiraciBbJ

COLLECTION TIME

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU m - n

CONDUCTIVITY m - n (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft) m

SAMPLING DEPTH (ft)I TS1

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

US ENVIRONMENTALPROTECTION AGENCY REGION I

PROJECT STATE PUrTtmadc

6t o s W M U r y COLLECTOR

FIELD OBSERVATIONS CLEAFt OVERCASl AlN SNOW FOG PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b O rg a n i c s

T - P O ampG

Other _

V O A s

M E T A L S Dissolved

Cd Fe Pb nCu SnHfl Cr (T) -i M n Zn 7 Cr ( + 6) N i ~7 Otherc

EPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYC REGION I

PROJECT M Co STATE tWrimampclc kM

COLLECTOR SV-OO- fcl^r

FIELD OBSERVATIONS CLEAR OVERCAST^AIN SNOW FOG PARTIAL CLOUDS ^ mdash (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOOD

PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O D B O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _O r g an i c s O ampG V O A s

METALS Dissolved

Cd Pb2 Cu SnyCr (T) Zn Cr ( + 6) 7 Other^CkT

EPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78469

PROJECT | | | M | |

STATION JfiiUaE3l Y Y M M D D

DATE ITWIOiaiXff

COLLECTION TIME|T

SAMPLE TEMP degC bull

PROBE-DO (mgl)

pH - SU m-n

CONDUCTIVITY (micromhoscm)

nr-n

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft) j SI- [oj

LAB CODE N9 78470

PROJECT | III | | |

STATION QOriBHI

Y Y M M D D

DATE RciauFci

COLLECTION TIMEbullBUS

SAMPLE TEMP C

PROBE-DO (mgl)

pH - SU m - n

CONDUCTIVITY hq-D(micromhoscm)

SALINITY (000) no-n

TOTAL DEPTH (ft) m SAMPLING DEPTH(ft)|~51f l

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

US ENVIRONMENTAL PROTECTION AGENCYI REGION I

PROJECT IJH fuhq Co STATE Fkj-rtmzcJt fJHI

COLLECTOR Mkv

FIELD OBSERVATIONS CLEA^OVERCASJ) RAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

IB a c t i N H 3 C O D B O D N02 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g a n i c s 0 ampG V O A s

I METALS Dissolved

Cd p5 Fe Pb 71I Cu Hg Sn |

Cr (T) M n Zn F Cr ( + 6) N i Other cIEPA R-1 7500-30 Unpreserved Sample

US ENVIRONMENTAL PROTECTION AGENCYI C REGION I

PROJECT MU Co- STATE (WNMACKI

COLLECTOR ltl

FIELD OBSERVATIONS CLEAiy6vERCAsectpoundtAIN SNOW FOGI PARTIAL CLOUDS (CIRCLE ONE)

AIR TEMP degC TIDE HIGH EBB LOW FLOODI PARAMETERS (CHECK APPROPRIATE)

B a c t i N H 3 C O DIB O D N O 2 + 3 P C B T S S T K N X - R a y T u r b T - P Other _IO r g an i c s 0 amp G V O A s

M E T A L S J o t a D i s s o l v e d

Cd Fe Pb CuI Hg Sn ~t Cr (T) 5 Mn Zn z Cr ( + 6) Ni Other CjO

IEPA R-1 7500-30 Unpreserved Sample

LAB CODE N9 78467

PROJECT

STATION rninrjBDB

Y Y M M D D

DATE

COLLECTION TIME fcLILTJE SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)[ [3I [O]

LAB CODE N9 78468

PROJECT

STATION Fararjona

Y Y M M D D

DATE

COLLECTION TIME BK1C1E]

SAMPLE TEMP degC

PROBE-DO (mg1)

pH - SU

CONDUCTIVITY (micromhoscm)

SALINITY (000)

TOTAL DEPTH (ft)

SAMPLING DEPTH (ft)njl

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I

60 WESTVIEW STREET LEXINGTON MASSACHUSETTS 02173

MEMORANDUM

DATE April 26 1989

SUBJ NH Plating

FROM Kathleen M PolgarChemist

TO Alex Sherrin Oil amp Hazardous Materials Section

THRU Dr William J Andrade J Chief Chemistry Section fJ J J

Analytical Procedure

Total cyanide and pH were determined in 6 samples of soil Four parameters of metal concentration were also determined in 3 of the samples

Methods Used

Method 3050 for digestion Method 9045 for pH Method 9010 for cyanide determination and Method 6010 for determination of metals Test Methods for Evaluating Solid Waste SW-846 1986 OSWER EPA Washington DC

Date Samples Received by Laboratory 32489

Date Samples Analyzed by Laboratory 44 - 42589

Reference Books CN Book IX Metals 76

PN 890095SOCN

I

I

I

I Resuits

I Samnlfts

I 77 8 4 6 7

I1 8 4 6 8 SSpk

I8 4 6 9

8 4 7 0

i8 4 7 1 Spk

I8 4 7 2

I

I

I

I

I

I

I

I

I

t pHIn Water

6 5 5

6 5 0

6 4 0

6 4 0

6 7 0

7 4 0

-2shy

Total Cyanide Chromium Cadmium ugg Sample As Is

Tin Zinc

710

880 99

9 9 0 2000 1 4 0 0 7 4 0 0 10000

810 1 9 0 0 9 8 0 5 5 0 0 10000

1280 1600120

1 3 0 0 99

5 2 0 0 9 0

9 6 0 0 106

9 9 0

DATE 41739 XRF-24

RE XRF screening -for metals in sample 78467 - 72 r cr

FROM Dr T M Spitt

TO Site Manager for N H Plating

The sample was analysed as received by placing about 2 grams in a mylar film cup and exposing the sample to x-ray excitation for 60 seconds See accompanying note -for limitations o-f analysis

Samp1e No Zn (7) Gr (ppm) Cd (ppm) Sn Cppm)

78467 1 2 1000 1800 2400 78468 10 800 1600 5000 78469 1 2 1400raquo 2500 4000 78470 20 2400 2000 2400 78471 12 1400 1800 1700 78472 07 800 1200 1400

(

J )

res Geoeral Comments onon Arr atrfXRF Screening Analysis

bullfroms Dr T M Spittl^

to Site Managers

Screening -for heavy metals is interpreted to mean that the site manager wishes to know if any of the eight metals on the drinkingwater list (As Cr Cd Hg Pb Se Ag or Bagt were present at levels significantly higher than background soil Because the XRF instrument simultaneously indicates the presence of all metals within an energy range Other elements can also be analysed for These other elements include Ni Mn Zn V SbSn Tl and Co The table below indicates XRF detection limits and normal abundance in the earths crust for these heavy metals

Element Detection Natural Limit (ppmgt Level (ppm)

Chromium (Cr) 50 200

Bariurn (Bagt 25 390

Cobalt (Co) 40 40

Copper (Cu) 30 200

Nickel (Ni) 40 100

Manganese (Mh) 50 930

Zinc (Zn) 30 40

Vanadium (V) 50 150

Silver (Ag) 30

Arsenic (As) 50 5

Antimony (Sb) 30

Selenium (Se) 20

Thallium (Tl) 25

Mercury (Hg) 25 05

Tin (Sn) 30

Cadmium (Cd) 30 05

Lead (Pb) 20 20

APPENDIX C

A BIOASSESSMENT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1- ESD BIOLOGY SECTION

60 Westview Street Lexington Massachusetts 02173

MEMORANDUM

DATE June 15 1989

SUBJ New Hampshire PlatingmdashPreliminary Site Assessment

FROM Celeste Philbrick Barr Aquatic Biology

TO Alex Sherrin Oil amp Hazardous Materials

A site visit was conducted May 19 1989 Photographs show three adjacentlagoon areas located behind facility The lagoon system exhibited a gradationfrom no vegetation in lagoon I to slightly increased vegetation with distance from the influent pipe No surface water was present at the site The main concerns from an ecological standpoint are sediment toxicity infiltration of toxicants to groundwater consequent contamination of Horseshoe Pond and access to toxic sediments by terrestrial organisms The lagoon area is fenced in its entirety This restricts access by medium and large size mammals There is little attraction for birds within the fenced area although it is still possiblethey could land within the area

Metal analyses of soil dated April 26 1989 as well as earlier chemical analyses performed in 1981 1982 and 1987 were provided Only the 1989 data were evaluated since current risks are the concern

A search through the Chemical Information System database provided little information on the effects of cyanide tin chromium cadmium and zinc on terrestrial biota Many of the toxicological effects listed occur at levels higher than those present at this site Only those that have potential at this site will be mentioned

Chromium Plant damage may result from levels above 05 ppm free chromate solution (See samples 78469 78470 78471) An apparentthreshold effect has been noted but not quantified All speciesthreatened by chromium in hexavalent form

Cadmium Highly bioaccumulated by most species Unfortunatelybioaccumulation factors for terrestrial organisms and plantsare not contained in the database Teratogenicityof 25-32 of chick embryos occurs with 1 ppm of cadmium Phytotoxicity evidenced when soil water contains 100 ppb cadmium and soil itself 25 ppm See sample sites 78469 78470 78471

Zinc Exchangeable zinc concentrations present in soil greater than 10 ppm may be injurious to plants See sample sites 78469 and 78470

PLEASE RECYCLE THIS PAPER

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

DATE 41739 XRF-24

RE XRF screening -for metals in sample 78467 - 72 r cr

FROM Dr T M Spitt

TO Site Manager for N H Plating

The sample was analysed as received by placing about 2 grams in a mylar film cup and exposing the sample to x-ray excitation for 60 seconds See accompanying note -for limitations o-f analysis

Samp1e No Zn (7) Gr (ppm) Cd (ppm) Sn Cppm)

78467 1 2 1000 1800 2400 78468 10 800 1600 5000 78469 1 2 1400raquo 2500 4000 78470 20 2400 2000 2400 78471 12 1400 1800 1700 78472 07 800 1200 1400

(

J )

res Geoeral Comments onon Arr atrfXRF Screening Analysis

bullfroms Dr T M Spittl^

to Site Managers

Screening -for heavy metals is interpreted to mean that the site manager wishes to know if any of the eight metals on the drinkingwater list (As Cr Cd Hg Pb Se Ag or Bagt were present at levels significantly higher than background soil Because the XRF instrument simultaneously indicates the presence of all metals within an energy range Other elements can also be analysed for These other elements include Ni Mn Zn V SbSn Tl and Co The table below indicates XRF detection limits and normal abundance in the earths crust for these heavy metals

Element Detection Natural Limit (ppmgt Level (ppm)

Chromium (Cr) 50 200

Bariurn (Bagt 25 390

Cobalt (Co) 40 40

Copper (Cu) 30 200

Nickel (Ni) 40 100

Manganese (Mh) 50 930

Zinc (Zn) 30 40

Vanadium (V) 50 150

Silver (Ag) 30

Arsenic (As) 50 5

Antimony (Sb) 30

Selenium (Se) 20

Thallium (Tl) 25

Mercury (Hg) 25 05

Tin (Sn) 30

Cadmium (Cd) 30 05

Lead (Pb) 20 20

APPENDIX C

A BIOASSESSMENT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1- ESD BIOLOGY SECTION

60 Westview Street Lexington Massachusetts 02173

MEMORANDUM

DATE June 15 1989

SUBJ New Hampshire PlatingmdashPreliminary Site Assessment

FROM Celeste Philbrick Barr Aquatic Biology

TO Alex Sherrin Oil amp Hazardous Materials

A site visit was conducted May 19 1989 Photographs show three adjacentlagoon areas located behind facility The lagoon system exhibited a gradationfrom no vegetation in lagoon I to slightly increased vegetation with distance from the influent pipe No surface water was present at the site The main concerns from an ecological standpoint are sediment toxicity infiltration of toxicants to groundwater consequent contamination of Horseshoe Pond and access to toxic sediments by terrestrial organisms The lagoon area is fenced in its entirety This restricts access by medium and large size mammals There is little attraction for birds within the fenced area although it is still possiblethey could land within the area

Metal analyses of soil dated April 26 1989 as well as earlier chemical analyses performed in 1981 1982 and 1987 were provided Only the 1989 data were evaluated since current risks are the concern

A search through the Chemical Information System database provided little information on the effects of cyanide tin chromium cadmium and zinc on terrestrial biota Many of the toxicological effects listed occur at levels higher than those present at this site Only those that have potential at this site will be mentioned

Chromium Plant damage may result from levels above 05 ppm free chromate solution (See samples 78469 78470 78471) An apparentthreshold effect has been noted but not quantified All speciesthreatened by chromium in hexavalent form

Cadmium Highly bioaccumulated by most species Unfortunatelybioaccumulation factors for terrestrial organisms and plantsare not contained in the database Teratogenicityof 25-32 of chick embryos occurs with 1 ppm of cadmium Phytotoxicity evidenced when soil water contains 100 ppb cadmium and soil itself 25 ppm See sample sites 78469 78470 78471

Zinc Exchangeable zinc concentrations present in soil greater than 10 ppm may be injurious to plants See sample sites 78469 and 78470

PLEASE RECYCLE THIS PAPER

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

(

J )

res Geoeral Comments onon Arr atrfXRF Screening Analysis

bullfroms Dr T M Spittl^

to Site Managers

Screening -for heavy metals is interpreted to mean that the site manager wishes to know if any of the eight metals on the drinkingwater list (As Cr Cd Hg Pb Se Ag or Bagt were present at levels significantly higher than background soil Because the XRF instrument simultaneously indicates the presence of all metals within an energy range Other elements can also be analysed for These other elements include Ni Mn Zn V SbSn Tl and Co The table below indicates XRF detection limits and normal abundance in the earths crust for these heavy metals

Element Detection Natural Limit (ppmgt Level (ppm)

Chromium (Cr) 50 200

Bariurn (Bagt 25 390

Cobalt (Co) 40 40

Copper (Cu) 30 200

Nickel (Ni) 40 100

Manganese (Mh) 50 930

Zinc (Zn) 30 40

Vanadium (V) 50 150

Silver (Ag) 30

Arsenic (As) 50 5

Antimony (Sb) 30

Selenium (Se) 20

Thallium (Tl) 25

Mercury (Hg) 25 05

Tin (Sn) 30

Cadmium (Cd) 30 05

Lead (Pb) 20 20

APPENDIX C

A BIOASSESSMENT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1- ESD BIOLOGY SECTION

60 Westview Street Lexington Massachusetts 02173

MEMORANDUM

DATE June 15 1989

SUBJ New Hampshire PlatingmdashPreliminary Site Assessment

FROM Celeste Philbrick Barr Aquatic Biology

TO Alex Sherrin Oil amp Hazardous Materials

A site visit was conducted May 19 1989 Photographs show three adjacentlagoon areas located behind facility The lagoon system exhibited a gradationfrom no vegetation in lagoon I to slightly increased vegetation with distance from the influent pipe No surface water was present at the site The main concerns from an ecological standpoint are sediment toxicity infiltration of toxicants to groundwater consequent contamination of Horseshoe Pond and access to toxic sediments by terrestrial organisms The lagoon area is fenced in its entirety This restricts access by medium and large size mammals There is little attraction for birds within the fenced area although it is still possiblethey could land within the area

Metal analyses of soil dated April 26 1989 as well as earlier chemical analyses performed in 1981 1982 and 1987 were provided Only the 1989 data were evaluated since current risks are the concern

A search through the Chemical Information System database provided little information on the effects of cyanide tin chromium cadmium and zinc on terrestrial biota Many of the toxicological effects listed occur at levels higher than those present at this site Only those that have potential at this site will be mentioned

Chromium Plant damage may result from levels above 05 ppm free chromate solution (See samples 78469 78470 78471) An apparentthreshold effect has been noted but not quantified All speciesthreatened by chromium in hexavalent form

Cadmium Highly bioaccumulated by most species Unfortunatelybioaccumulation factors for terrestrial organisms and plantsare not contained in the database Teratogenicityof 25-32 of chick embryos occurs with 1 ppm of cadmium Phytotoxicity evidenced when soil water contains 100 ppb cadmium and soil itself 25 ppm See sample sites 78469 78470 78471

Zinc Exchangeable zinc concentrations present in soil greater than 10 ppm may be injurious to plants See sample sites 78469 and 78470

PLEASE RECYCLE THIS PAPER

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

APPENDIX C

A BIOASSESSMENT

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1- ESD BIOLOGY SECTION

60 Westview Street Lexington Massachusetts 02173

MEMORANDUM

DATE June 15 1989

SUBJ New Hampshire PlatingmdashPreliminary Site Assessment

FROM Celeste Philbrick Barr Aquatic Biology

TO Alex Sherrin Oil amp Hazardous Materials

A site visit was conducted May 19 1989 Photographs show three adjacentlagoon areas located behind facility The lagoon system exhibited a gradationfrom no vegetation in lagoon I to slightly increased vegetation with distance from the influent pipe No surface water was present at the site The main concerns from an ecological standpoint are sediment toxicity infiltration of toxicants to groundwater consequent contamination of Horseshoe Pond and access to toxic sediments by terrestrial organisms The lagoon area is fenced in its entirety This restricts access by medium and large size mammals There is little attraction for birds within the fenced area although it is still possiblethey could land within the area

Metal analyses of soil dated April 26 1989 as well as earlier chemical analyses performed in 1981 1982 and 1987 were provided Only the 1989 data were evaluated since current risks are the concern

A search through the Chemical Information System database provided little information on the effects of cyanide tin chromium cadmium and zinc on terrestrial biota Many of the toxicological effects listed occur at levels higher than those present at this site Only those that have potential at this site will be mentioned

Chromium Plant damage may result from levels above 05 ppm free chromate solution (See samples 78469 78470 78471) An apparentthreshold effect has been noted but not quantified All speciesthreatened by chromium in hexavalent form

Cadmium Highly bioaccumulated by most species Unfortunatelybioaccumulation factors for terrestrial organisms and plantsare not contained in the database Teratogenicityof 25-32 of chick embryos occurs with 1 ppm of cadmium Phytotoxicity evidenced when soil water contains 100 ppb cadmium and soil itself 25 ppm See sample sites 78469 78470 78471

Zinc Exchangeable zinc concentrations present in soil greater than 10 ppm may be injurious to plants See sample sites 78469 and 78470

PLEASE RECYCLE THIS PAPER

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1- ESD BIOLOGY SECTION

60 Westview Street Lexington Massachusetts 02173

MEMORANDUM

DATE June 15 1989

SUBJ New Hampshire PlatingmdashPreliminary Site Assessment

FROM Celeste Philbrick Barr Aquatic Biology

TO Alex Sherrin Oil amp Hazardous Materials

A site visit was conducted May 19 1989 Photographs show three adjacentlagoon areas located behind facility The lagoon system exhibited a gradationfrom no vegetation in lagoon I to slightly increased vegetation with distance from the influent pipe No surface water was present at the site The main concerns from an ecological standpoint are sediment toxicity infiltration of toxicants to groundwater consequent contamination of Horseshoe Pond and access to toxic sediments by terrestrial organisms The lagoon area is fenced in its entirety This restricts access by medium and large size mammals There is little attraction for birds within the fenced area although it is still possiblethey could land within the area

Metal analyses of soil dated April 26 1989 as well as earlier chemical analyses performed in 1981 1982 and 1987 were provided Only the 1989 data were evaluated since current risks are the concern

A search through the Chemical Information System database provided little information on the effects of cyanide tin chromium cadmium and zinc on terrestrial biota Many of the toxicological effects listed occur at levels higher than those present at this site Only those that have potential at this site will be mentioned

Chromium Plant damage may result from levels above 05 ppm free chromate solution (See samples 78469 78470 78471) An apparentthreshold effect has been noted but not quantified All speciesthreatened by chromium in hexavalent form

Cadmium Highly bioaccumulated by most species Unfortunatelybioaccumulation factors for terrestrial organisms and plantsare not contained in the database Teratogenicityof 25-32 of chick embryos occurs with 1 ppm of cadmium Phytotoxicity evidenced when soil water contains 100 ppb cadmium and soil itself 25 ppm See sample sites 78469 78470 78471

Zinc Exchangeable zinc concentrations present in soil greater than 10 ppm may be injurious to plants See sample sites 78469 and 78470

PLEASE RECYCLE THIS PAPER

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

Sediment toxicity testing is possible using test plants and animals if the the risk is considered to warrant this I would judge the area to be of low immediate risk to living organisms Groundwater contamination seems as though it could carry a much higher risk Aquatic toxicity tests can be conducted using samples from groundwater monitoring wells

PLEASE RECYCLE THIS PAPER

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

New Hampshire Plating Co Lagoon I May 1989

Lagoon III

Lagoon III