NATIONAL DIOXIN STUDY
PRIORITY POLLUTANT
SAMPLING AT
INDUSTRIAL SITES
REGIONAL SUPPORT
REGION I
FINAL REPORT
OF
FIELD SAMPLING ACTIVITIES
prepared for:
S. ENVIRONMENTAL PROTECTION AGENCY
REGION I
LEXINGTON, MASSACHUSETTS
FEBRUARY 1985
E.C. JORDAN CO.
ONSl TIN'. NGINFERS

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NATIONAL DIOXIN STUDY
PRIORITY POLLUTANT SAMPLING
AT INDUSTRIAL SITES
REGIONAL SUPPORT
REGION I
FINAL REPORT OF FIELD SAMPLING ACTIVITIES
Prepared for:
U.S. Environmental Protection Agency
Region I
Lexington, Massachusetts
Prepared by:
E.C. Jordan Co.
Portland, Maine
February 1985
Contract No. 68-01-6700
E.C. Jordan No. 4570-00
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TABLE OF CONTENTS
SECTION	TITLE 		PAGE NO.
I. SUMMARY. 			1
II. INTRODUCTION 		2
PURPOSE			3
SCOPE OF WORK		4
III. SITE SELECTION AND DESCRIPTION		5
TIER 7 SITES
PITTSFIELD, MASSACHUSETTS 		5
HARTFORD, CONNECTICUT . . 			7
FITCHBURG, MASSACHUSETTS		7
TIER 5 SITES
LAKE ABENAKI - THETFORD, VERMONT		7
CLARA LAKE - WHITINGHAM, VERMONT		8
CENTRAL MAINE POWER CO. RIGHT-OF-WAY -
YARMOUTH, MAINE		8
BANGOR & AROOSTOOK RAILROAD RIGHT-OF-WAY -
GRINDSTONE, MAINE		9
TIER 3 SITES
J. HUBBARD CO. - NASHUA, NEW HAMPSHIRE. . .	9
CARROLL PRODUCTS, INC. - WOOD RIVER JUNC-
TION, RHODE ISLAND . . . 			10
IV. SAMPLING PROGRAM 		31
PRESAMPLING PROCEDURES 		31
SAMPLING EQUIPMENT AND SAMPLE CONTAINERS. .	34
GENERAL SAMPLING PROTOCOL 		35
SYNOPSIS OF SAMPLING EPISODES 		37
CHAIN-OF-CUSTODY PROCEDURES 		41
APPENDICES
A.	SITE DOCUMENTATION
B.	SAMPLE LOCATION PLANS
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LIST OF FIGURES
Figure No.	Title	Page No.
1	General Site Locations Region I. 		6
2	Location Plan Pittsfield Area Sites		12
3	Location Plan Pittsfield Area Sites		13
4	Location Plan Pittsfield Area Sites		14
5	Location Plan Pittsfield Area Sites		15
6	Location Plan Hartford Area Sites. . 			16
7	Location Plan Hartford Area Sites		17
8	Location Plan Hartford Area Sites		18
9	Location Plan Hartford Area Sites		19
10	Location Plan Hartford Area Sites		20
11	Location Plan Hartford Area Sites		21
12	Location Plan Fitchburg Area Sites		22
13	Location Plan Fitchburg Area Sites		23
14	Location Plan Fitchburg Area Sites		24
15	Location Plan Lake Abenaki			25
16	Location Plan Clara Lake		26
17	Location Plan Central Maine Power R-O-W		27
18	Location Plan Bangor and Aroostook Railroad R-O-W. .	28
19	Location Plan J. Hubbard, Inc		29
20	Location Plan Carroll Products 		30
21	Chain of Custody Form		43
B-l	Sample DA000301 Location Pittsfield, MA		B-l
B-2	Sample DA000302 Location Pittsfield, MA		B-2
B-3	Sample DA000303 Location Pittsfield, MA		B-3
B-4	Sample DA000304 Location Pittsfield, MA		B-4
B-5	Sample DA000304 Location Pittsfield, MA.		B-5
B-6	Sample DA000306 Location Pittsfield, MA		B-6
B-7	Sample DA000307 Location Pittsfield, MA		B-7
B-8	Sample DA000308 Location Dalton, MA		B-8
B-9	Sample DA000309 Location Lanesborough, MA		B-9
B-10	Sample DA000401 Location Hartford, CT		B-10
B-ll	Sample DA000402 Location Hartford, CT		B-ll
B-12	Sample DA000403 Location Hartford, CT		B-12
B-13	Sample DA000404 Location Hartford, CT		B-13
B-14	Sample DA000405 Location East Granby, CT 		B-14
B-15	Sample DA000406 Location Andover, CT 		B-15
B-16	Sample DA000407 Location Windsor, CT 		B-16
B-17	Sample DA000408 Location Windsor, CT 		B-17
B-18	Sample DA000501 Location Lunenburg, MA 		B-18
B-19	Sample DA000502 Location Fitchburg, MA 		B-19
B-20	Sample DA000503 Location Fitchburg, MA 		B-20
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LIST OF FIGURES (Cont.)
Figure No.	Title	Page No.
B-21 Sample DA000504 Location Fitchburg, MA 		B-21
B-22 Sample DA000505 Location Fitchburg, MA 		B-22
B-23 Sample DA000506 Location Fitchburg, MA 		B-23
B-24 Lake Abenaki Sample Locations		B-24
B-25 Clara Lake Sample Locations			B-25
B-26 Central Maine Power R-O-W Sample Locations 		B-26
B-27	Bangor and Aroostook Railroad R-O-W
Sample Locations			B-27
B-28 J. Hubbard, Inc. Sample Locations		B-28
B-29 Carroll Products Sample Locations. .........	B-29
LIST OF TABLES
Table No.	Title	Page No.
1	Population Sizes for Random Sample Size of 12	 33
2	Population Sizes for Random Sample Size of 24	 34
3	Sampling Site Locations	 38
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I. SUMMARY
As part of the national study investigating the presence of dioxin at specific
sites, EPA identified nine (9) candidate sites in EPA Region I for collection
of soil and sediment samples. Two of these were categorized as Tier 3 (sites
where 2,4,5-trichlorophenol was formulated into products), four were categor-
ized as Tier 5 (sites where products derived from 2,4,5-trichlorophenol have
been used), and three were categorized as Tier 7 background sites (sites where
contamination with dioxin was not suspected).
The nine sites were visited by representatives of EPA and its contractor, E.C.
Jordan Co., to verify background information and confirm the suitability of
each site for sample collection. Following initial site visits, E.C. Jordan
Co., prepared and submitted detailed sampling plans which were used by the
sampling team members during the collection of representative soil and sediment
samples. Site visit reports, prepared following each episode, were incorpor-
ated into the sampling plans. Tier 3 samples were sent to contract laboratory
program (CLP) laboratories; all other samples were sent to TROIKA.
In accordance with the requirements of the scope of work, no analytical data
results are included in this report.
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II. INTRODUCTION
On December 15, 1983, the U.S. Environmental Protection Agency (EPA) issued a
national strategy for investigating, identifying, and cleaning up sites con-
taminated by dioxin. The strategy focused primarily on 2,3,7,8-tetrachlorodi-
benzo-p-dioxin (2,3,7,8-TCDD) which is considered the most toxic of the 75
dioxin isomers. As part of the strategy, the Office of Water Regulations and
Standards developed a two-year national study plan for investigating and
sampling for dioxin at specific processing sites where pesticides possibly
contaminated with dioxins were handled or disposed. The plan included addi-
tional sampling at sites where possibly contaminated pesticides have been or
are being used, and at sites that represent background conditions.
EPA has identified seven classes or "tier levels" based on decreasing potential
for 2,3,7,8-TCDD contamination as follows:
Tier 1 - Locations or sites where 2,4,5-trichlorophenol was originally pro-
duced, including associated waste disposal areas.
Tier 2 - Sites where 2,4,5-trichlorophenol was used as a precursor to make
pesticidal products, including herbicides, germicides, pesticides, and other
related extractable organics.
Tier 3 - Sites, and associated waste disposal areas, where 2,4,5- trichloro-
phenol and its derivatives were formulated into pesticidal products. The
pesticidal products of concern include: 2,4,5-trichlorophenoxyacetic acid
(2,4,5-T); silvex (2,4,5-TC); erbon; ronnel; hexachlorophene; isobac 20; and
2,4,5-trichlorophenol.
Tier 4 - Combustion sources which either create or fail to destroy dioxins.
Sources to be studied are hazardous and municipal waste incinerators, internal
combustion engines, and accidental fires involving PCB-transformers.
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Tier 5 - Sites, such as right-of-ways and ranchlands, where pesticidal products
derived from 2,4,5-trichlorophenol have been and are being used on a commercial
basis.
Tier 6 - Certain organic chemical and pesticide manufacturing facilities where
improper quality control on certain production processes could have resulted in
2,3,7,8-TCDD contaminated product waste streams.
Tier 7 - Control sites where contamination from 2,3,7,8-TCDD is not suspected.
The dioxin study strategy calls for investigating and taking any necessary
response or enforcement actions at all Tier 1 sites and, eventually, at Tier 2
sites as part of the Superfund program. Sites in Tiers 3, 4, 5 and 6 are also
being studied through a separate sampling program to determine their prob-
ability of contamination. Concurrent with sampling these sites, other areas
identified as Tier 7 sites are being sampled to determine if background levels
of dioxin exist in the environment and, if so, how widespread they are. EPA's
current estimate is that more than 80 percent of the dioxin present in nature
occurs at Tier 1 and 2 sites. The remaining 10 to 20 percent is estimated to
be distributed between Tier 3,4,5, and 6 sites, with most at the Tier 3 sites.
The initial sampling necessary to evaluate the Tier 3, 4, 5, 6, and 7 sites
comprises of the National Dioxin Study.
PURPOSE
The purpose of the National Dioxin Study's sampling program in Region I is to
examine the nature of dioxin contamination in the environment and to assess the
degree of contamination in Tier 3, 5, and 7 sites. Specifically, the objective
of the Tier 3 study is to determine at what percentage of the facilities in
this tier have concentrations of dioxin in the soil at levels above one part
per billion (ppb). The goal of the Tier 5 study is to evaluate the extent and
severity of dioxin contamination in those areas where the herbicides 2,4,5-T
and silvex have been used. At Tier 7 sites, the purpose for sampling is to
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assess whether background levels of dioxin exist in the environment, as well as
to provide a basis for comparison for other tiers.
The purpose of this report is to summarize the sampling program conducted as
part of the national study on the Tier 3, 5 and 7 sites in EPA's Region I. No
analytical results are included.
SCOPE OF WORK
The sampling program in Region I was comprised of the following five subtasks:
1.	Initiate contact with site owners or their representatives to obtain the
necessary clearance for gaining site access.
2.	Conduct a reconnaissance visit to each site to verify background infor-
mation and to identify relevant site characteristics.
3.	Prepare a sampling plan for each site which details collection procedures
and number of samples to be taken.
4.	Collect representative samples of soil and/or sediment from identified
locations in Tiers 3, 5 and 7.
5.	Prepare and submit a report detailing the field sampling activities.
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III. SITE SELECTION AND DESCRIPTION
The initial step in the sampling program entailed identifying and selecting
sample locations. Representative sites of each tier were selected by EPA from
all regions within the United States as part of the National Dioxin Study.
Within Region I, nine sample locations were chosen to be sampled as part of the
program. Two of the sites were designated as Tier 3 sites, four as Tier 5, and
the remaining three as Tier 7, or background sites. Figure 1 depicts the
general location of the nine sites and identifies each by name and tier. Site
specific location plans are presented at the end of this section beginning on
page 12.
The Tier 3 and Tier 5 sites were selected by EPA based on consultation with
state regulatory agency personnel from those states within the region.
Region I Tier 3 sites were located in New Hampshire and Rhode Island; the Tier
5 sites were located in Maine and Vermont. Tier 7 sites were selected randomly
from areas which had previously been identified and sampled as part of the
Office of Pesticide's National Soil Monitoring Program (NSMP). In Region I,
the Tier 7 sites were part of three standard metropolitan statistical areas
(SMSA) located in Hartford, Connecticut; and Fitchburg and Pittsfield,
Massachusetts. A brief summary and history of each site is included as part of
the next section of this report. Documentation of pesticide usage at each site
is included in Appendix A.
TIER 7 SITES
Pittsfield, Massachusetts
Nine individual sites were included within this sampling area. Seven locations
were within the city limits of Pittsfield with the remaining two sampling
points located in Dalton and Lanesborough, Massachusetts. Figures 2 through 5
depict the locations of the nine sampling sites which ranged from privately-
owned landscaped lawns to remote, wooded state forest areas. However, in all
cases, the sampling points were vegetated with either grass or weeds. No
records or evidence exist that a herbicide was used on these sites in the past.
5
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FIGURE 1
GENERAL SITE LOCATIONS
REGION I
NATIONAL DIOXIN STUDY
	EC JORDAN CQ

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Hartford, Connecticut
Eight sites were randomly selected from a network of locations in the Hartford
standard metropolitan statistical area. Three of these sites were within the
city limits of Hartford, while the remaining five locations were situated
within Hartford County, in the towns of Andover, E. Granby, and Windsor, Con-
necticut. The general locations of these sampling areas are shown on Figures 6
through 11. The individual sites included residential lawns, a church and
courthouse lawn, and several rural sites which were, at the time, predominantly
wooded. None of these sites showed evidence or are suspected of having been
sprayed with any herbicide which might have contained dioxin.
Fitchburg, Massachusetts
Six discrete sample sites were selected in this area. Five of the sites were
within the Fitchburg city limits and the remaining one was located in the town
of Lunenburg. Figures 12 through 14 show the general location of these six
sites. Two of the sample areas were in residential lawns, and the other four
were in unimproved, wooded areas. Like the other Tier 7 sites, there was no
indication that these areas contained dioxin.
TIER 5 SITES
Lake Abenaki, Vermont
This site was located northeast of the village of Thetford Center, Vermont, as
shown on Figure 15. Primary access to the lake is through Camp Farnsworth, a
girl scout camp which surrounds the lake and which is located off Route 114.
The lake shore, in general, was heavily wooded and stable with no evidence of
recent erosion. Even though the lake was quite shallow (maximum depth of
approximately 10 feet), it was used extensively by the camp for water recrea-
tion (swimming, canoeing, etc.) and by the public for fishing. As a result of
its shallowness, the lake has experienced periods of increased vegetative
growth. Because of this, approximately 15 acres of the lake (southern third)
were sprayed with 2,4-D and silvex in June 1975. According to the caretaker at
7
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the camp, this application appeared to have been effective in controlling
vegetative growth in the lake.
Clara Lake, Vermont
The Clara Lake site, as shown on Figure 16, is located north of the village of
Whitingham, Vermont. Access to the site is from a gravel road (causeway) which
traverses the lake. The lake was partially drained in 1982 and much of the
former lake bed has reverted to grass, weeds, and shrubs. The existing pond was
about one third the size of the original lake (4 acres versus 13 acres) and
quite shallow (4 to 5 feet deep except near an existing dam) at the time of the
sampling. The lake was sprayed three times in the early 1970's in an effort to
control weed growth. A portion of the spray mix used during this period of
time included the herbicide silvex. Even though the lake had been partially
drained, it was still being used for water recreation (swimming and fishing).
Consequently, EPA personnel decided that this site should continue to be
considered a Tier 5 location for this study.
Central Maine Power Co. Right-of-Vay, Yarmouth, Maine
Central Maine Power Co. (CMP) maintains a right-of-way for a 115 kv transmis-
sion line between its steam electric power generating facility in Yarmouth,
Maine, and Mosher substation in Gorham, Maine. In 1978, to control vegetative
growth, CMP sprayed selected plants within 75 feet of the tower centerline in
the Yarmouth area with Tordon 155, which contains 2,4,5-T. The herbicide was
applied only at the base of selected plants. Following site reconnaissance,
two areas along the right-of-way in Yarmouth were selected for sampling. The
first of these areas was a 150-ft by 800-ft strip located within the right-
of-way about 300 feet east of Interstate Highway 95. The second was a 150-ft
by 800-ft strip located within the right-of-way between Portland Street and
U.S. Route 1. The second area was about 1,000 feet west of the first. Figure
17 shows the location of the site.
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Bangor & Aroostook Railroad Right-of-Way, Grindstone, Maine
The Bangor & Aroostook Railroad (B&A) serves northern Maine by providing rail
freight service to several small towns and cities as well as to the timber and
agricultural related businesses of the region. Most of the B&A track is
bordered by forested, uninhabited land. In June 1977, the B&A conducted a
spraying program using mixtures containing 2,4,5-T for control of vegetative
growth along its right-of-way north of Millinocket, Maine. Following a
reconnaissance of the area and consultation with Region I personnel, an 1,800-
foot section of right-of-way between Mile Posts 111 and 112 was selected for
sampling as part of the National Dioxin Study. The location of this section of
right-of-way is shown on Figure 18.
TIER 3 SITES
J. Hubbard, Inc., Nashua, New Hampshire
J. Hubbard, Inc., located in Nashua, New Hampshire (see Figure 19), is opera-
ted, in part, as a formulator and distributor of a scented isopropal rubbing
alcohol solution called Dr. Hubbard's Red Cross Nurse. At the time of purchase
by current owners in 1975, and for the following two years, hexachlorophene was
mixed with the alcohol and scented oil at the J. Hubbard facility, but has not
been used since then. Current owners have no knowledge of how long the pre-
vious owners used hexachlorophene.
Hexachlorophene was purchased in a dry form and stored on site in small drums.
Only one container, which held about 25 pounds of substance, was on site at any
given time. Water, oil, and hexachlorophene were mixed together in a bucket
sitting in a sink. The blended mixture was then poured into two 275-gallon
vats containing alcohol. These vats were moved to the location shown in B-28,
Appendix B. They were cleaned once, about two years later; wash water was
flushed down the drain to the city sewer. According to J. Hubbard personnel,
no leakage has occurred during their ownership. Hexachlorophene use at the
site has been estimated between 50 and 100 pounds per year based on J. Hubbard
records showing an annual production rate of 2,000 to 4,000 gallons of Red
9
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Cross Nurse and a mixing ratio of 0.024 pounds of hexachlorophene per gallon of
alcohol.
Carroll Products, Inc., Wood River Junction, Rhode Island
Carroll Products, Inc., is located on Route 91 in Wood River Junction, Rhode
Island (see Figure 20). In 1976, Carroll Products, Inc., purchased for resale
1,800 pounds of purified grade 2,4,5-T from Dow Chemical Company. According to
analytical results provided by Dow Chemical Co., the 2,4,5-T contained no more
than 0.01 parts per million (ppm) of dioxin. Shipped via common carrier
(truck), the chemical, in dry form, was contained in plastic liner bags inside
three 55-gallon metal drums (600 pounds each) with clamp type lids.
Following receipt by Carroll Products, 1,190 pounds, the entire contents of one
drum and most of another, were repackaged for shipment to Polaroid Corporation.
The repackaging occurred on the first floor of Building 2 as shown on Figure
B-29 of Appendix B. The chemical was scooped from the 55-gallon drums into
smaller fiber drums which were picked up by Polaroid personnel on two separate
occasions. Carroll Products personnel could not verify which loading dock was
used, but assumed it was the main dock in Building 4 (Figure B-29, Appendix B).
Following repackaging, all floor sweepings, gloves, bag liners, scoops, pro-
tective clothing, etc., were placed in two fiber drums and hauled via a Carroll
Products company truck to an incinerator in Saugus, Massachusetts.
In 1976, all floor drains emptied into an on-site lagoon (Figure B-29, Appendix
B); however, there were no reported or known spillages during storage or
shipment of 2,4,5-T. According to company personnel, the lagoon has not been
used since Carroll Products purchased the property in October 1971.
The remaining unopened drum, along with 75 pounds remaining from the shipment
to Polaroid Corporation and repackaged in a plastic liner in a 41-gallon fiber
drum, were stored on-site on the second floor of Building 2 from 1976 to 1984.
In April 1984, Dow Chemical provided two steel drums to overpack the stored
drums, and they were shipped to Full Fertilizer Service, Floresville, Texas.
10
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EHA *b eng #e rda *c EHA
EPA 901-R-85-007
EPA 901-R-85-007
EHAD
Priority pollutant sampling at industrial sites regional support, Region I: *b final report of field
sampling activities / #c prepared for U.S. Environmental Protection Agency, Region I; prepared by:
E C. Jordan Co.
*i At head of title: #a National dioxin study
Portland, Maine : *b E.C. Jordan Co., +c 1985.
1 volume (various pagings): *b figures (some folded in pockets), forms ; *c 28 cm
text *b txt *2 rdacontent
unmediated *b n +2 rdamedia
volume *b nc +2 rdacarrier
"February 1985."
"Contract no. 68-01-6700, E.C. Jordan no. 4570-00."
Dioxins.
Factory and trade waste tx Environmental aspects *z New England.
E.C. Jordan Co.. *e author.
United States. *b Environmental Protection Agency. *b Region I. #e sponsor.
Delete Holdings- Export- Label-
Source-Derived
Submit- Replace- Report Error- Update Holdings-C Validate-C
Workflow-In Process
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No record of what happened to the remaining 35 pounds of the chemical exists,
but company officials believe it became part of the floor sweepings at the time
of initial repacking.
11
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1v-. J a ^ \ ! >^0™
/"^Bravel
AMPLE NO. DA000304
: mm / wr^W?
.^co
_ . ..^ •: ,¦ 'Si - Thomas - /?: H'iijx.::
•/O^yffgfr: Island r-'$=r
'	 *• -l$s •
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' ^/jj^tawentin * *•
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Sta>..f" 'si; • ,'r ' : ;
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3|p^""'Com m unity Cojle
Cem:
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^N ,i>t;
' ' J	^ ~'{c" /r*	"" * *" *	, * ,/t* '	' ''¦
SOURCE1. OSGS-PITTSFIELD WEST, MA
2000
4000 FEET
FIGURE 4
LOCATION PLAN
NATIONAL DIOXIN STUDY
PITTSFKLD AREA SITES
	EC JORDAN CQ
14

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Pontaosu
•,^lv Gardep
SAMPLE NO. DA000309
nter/il
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h
SAMPLE NO. DA000306
a\-m;rUyj / i j
ntoostic
i010%:_:J^bV
Is
doll/Course.
umping

St Franci* ,
- -'-(Cr?. • /-
BerKsnire Hcjis ; • ; . i • \
f** • • r» ~ r. - C' i. H* •; •	I \ '
Co-jntry C!ub\ ,
Water-.-', f	y
tank'—¦%	• \
Sewage I
Disposal/^ ||
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SPRINGSIDE
Coltsvilld-
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-	/ ' - A
;$». >'Pi»ygSSty>d
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North	PARK l)
JrHiehS^h	K
Drive
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SAMPLE NO.

SAMPLE NO:
DA000401
tvi; Jl#P>
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i'i/ If	/•;	";<-
1 [GREEljriELcjl ' II
S|n ii l.ii o^:	/j /; ' SJ *. II / •£.
fine	ji ¦ CemtUMy	/ V'5 Vk ••¦ 7
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7	//A?
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firunc
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Betnwood
iHospital*
&
V
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;
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ch
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£
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Sch off La
Si JotwylL /J \, §1
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ij
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SAMPLE NO.'
. 8ULKZLEY
^SfflBSSTf
Gaging /
I Sta I
U . t 1
/f« '. * ^ f	'¦ : fai-Vij/ "
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a
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'r"H ^
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idp"


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al
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i Bumping SU
(N'fEPCHA
source-uses-
11000
2000
14000 FEET
FIGURE 6
NATIONAL OIOXIN STUDY
LOCATION PLAN
HARTFORD AREA SITES
ECJORDANCQ

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$?brth
P-mid"

HM.J Shea Corner

^".Rising ^orfierlk "•
^r"
ill ! Stony
1 ( fnoll
MASSACHUSETT
CONNECTICUT
f.f
///:!.'
Enlt? Corner
VoW //
V \
..
*	^ SAMPLE NO. DA000404
).. '
/¦//i^"/1 j j I i y
I i • ' -Q/ / 6 «. • / I
1 "7 S;-'
V
/ I. ^ 'I Rattlesnake
${ Swamp
/.S c
SOURCE: USQS - WEST SPRINGFIELD, MA
2000
14000 FEET
FIGURE 7
LOCATION PLAN
NATIONAL DIOXIN STUDY
HARTFORD AREA SITES
EC JORDAN CQ ¦
17

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Taiiritor
HALE
SAMPLE NO. DA000405
East Granbv •/
BRADLEY
I N T/E R N A T I 0 N A L AIRPORT
Hitfh Sch
' Sewage
T? Disocsa'
SOURCE* USGS-WINOSOR LOCKS,CT
FIGURE 8
		 ___	LOCATION PLAN
^nooo	NATIONAL DIOXIN STUDY
O ¦¦¦¦¦2000	14000 FEET	HARTFORD AREA SITES
	>	EC JORDAN CQ
18

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I |	"nE>"'L. 		 WPlKE . ?«
A \»it> < 6 23
' \
juarryville
Siwer Street-(?iJ' L&
Cem
5M M
- \
* ¦
II . LOVE_- „
;i658 '

: - \
\ W '
iGaging
Sta tion
\ 'V , \
..•y.
•». !--t" • South Street
x-\
„at*ooS

z
cn Center
, -	SAMPLE NO. DA000406
v~		 —__
Bolton
^KtRh Sch

. :6?s
.
dr.
v
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o
J
£
; ftO*0-. . '

A N. D 0. V E. R
*V. 's	\
V
e6 .
".x
¦?p
¦*>
n
SOURCE' USSS - ROCKVILLE, CT

2000
14000 FEET
FIGURE 9
LOCATION PLAN
NATIONAL DIOXIN STUDY
HARTFORD AREA SITES
	EC JORDAN CQ
19

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/ O
"I . \r~ moosl 1 * ~	)f s
&¦ % vy.,• . # - s: x
% v"r p ^ - ,_j 1;.
J . -4 * ^pv* ^ *"	¦; ..gg-^SN> ';^~N '-~^BB '-±=*=^=zf'
•	Grove
( •»- j: ' Cem
/•) - ,W .-:. i: sr
96 i

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V.. ._^;
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O
WATERWORKS t
c
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• " vv - ftyid- X
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rc	/ -/">¦' '
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V
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j
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no
V <¦



Hayden
SOURCE: USSS -WINDSOR LOCKS, CT
2000
4000 FEET
FIGURE 10
LOCATION PLAN
NATIONAL DIOXIN STUDY
HARTFORD AREA SITES
	EC JORDAN CQ
20

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V-
'Water Tanlj*
v.,.
Sandpit
SAMPLE NO. DA000408
\ (iy4/5
Vvsr


'.o '
• I	<
"K-	I;;
1
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; ./ f	r-i
N/ffv, ' / /
i h-/u^7 w
& m:
/
l
D M>-F I E 1^ D
i4y V /./
/' :• l/" ¦¦ ! .—,
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•i	• -

s-r^Vj
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* "7.. > r * t I
; •"•v;Lr'U
		.A;* •]
:. .'V- ••
jtei ,V *
Piirk Ave.'/-	- f.
Sch '
• ¦ .v.- :: •¦ : • :
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: •	: :: i *.
: :/• : "• •. : • • •
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... :U '. i a
Pine'HirtN
W^.'Goffciu^
•^r~7 \.
¦***> \ SuB ¦'
'r^ v l ' %* ¦
SOURCE: USG3- HARTFORO NORTH, CT
11000
2000
4000 FEET
FIGURE 11
LOCATION PLAN
NATIONAL DIOXIN STUDY
HARTFORD AREA SITES
	EC. JORDAN CQ
21

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aJS^TX
E N I
;?M • w-'F -
f ' lr P ' v .- ¦: " J: r\ '
|>W" Hickory Hills*." Lake
SAMPLE NO. DA000501
v 'x ¦(/:¦.
\-f:\ • v.^
/ •Jf"Sr ~\ ^Sr-vf35 •	. Goodrichtdlg
J
Hiffh <5*4

K...••;>• LunenbupgX
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f £;2
SOURCE: USOS - SHIRLEY,MA
11000
2000
14000 FEET
FIGURE 12
LOCATION PLAN
NATIONAL DIOXIN STUDY
FITCHBURG AREA SITES
	EC. JORDAN CO
22

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SAMPLE NO. DA000S02
\ \ I ) 'w
\Z',5. 	„
IttneKvtHr
.-.Can-*.	XI \. \ \	• .	\ iV'V! '	g
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S££?y ¦¦¦*¦«-;££ _¦	> Vwi	j;:-rW*X- J \jf
• ••• I • \- \ \ h	v.-	x • ••« i'v«	IV -y- v	y rb J /
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: UA HAAAAKA4 : ",\\ \ X.	V	': .
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SAMPLE NO. DA000503

*>'OAn
'heldott


(Hn'itim
tuner mu
la l.u lurter
weiMj
a if una
SOURCE: US6S- F1TCHBU8G, MA
2000

N	s
\ '.I HM
> -I'-w
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A1-,# ^
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I,	\\ T„. ,v .
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5"Hosp«t'i
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f " :
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•; ^^4	
:m;»%l'
4000 FEET
6

y I'otuL-
	*?
" ^ SAMPLE NO. 0A000504
I
V;..: V
••. •»•
. j! /'Ni,.!,

FIGURE 13
NATIONAL DIOXIN STUDY
LOCATION PLAN
FITCHBURG AREA SITES
EC JORDAN CQ

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i'onu\ UJOyw
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v
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& I'il l l'C ¦ '.	' -- U
I'oitll

soimce: uses-fitch burg, ma
11000
12000
14000 FEET
FIGURE 14
NATIONAL DIOXIN STUDY
LOCATION PLAN
FITCHBURG AREA SITES
	EC. JORDAN CQ

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r
' V,/ . A1'

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:	~ X •'
" -«^sm
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v *r
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I.Vllie <_	'BE
B M
7$' ,
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SOURCE: uses-MT. CUBE, NH
APPROXIMATE SCALE
5200
10,400
FIGURE 15
NATIONAL DIOXIN STUDY
LOCATION PLAN
LAKE ABENAKI
THETFORD, VT.
	EC JORDAN CQ
25

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.1

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*•*65
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Hill
V / . •»^95"S;

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SOURCE. US6S-WILMIN8T0N.VT
APPROXIMATE SCALE
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- " I V - V
" "90 : , ^ -* f
}:> 1 -> ;
15200
10,400
FIGURE 16
NATIONAL DIOXIN STUDY
LOCATION PLAN
CLARA LAKE
LAKE WHITINGHAM, VT.
EC JORDAN CQ
7fi

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—. . .Pme 3ve
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X .j> Crockett v^; r
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O&T-, 9
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Island
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c&i;^T>f
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T H
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/
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/
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The Nu
Madelon *
Point.»; -. 's /'•
Cm	•*
\

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SOURCE'.USOS- FREEPORT, ME
x..
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Point * • /.Subitaficjrt.&¦¦•¦• » * Po>nt
Littlejohn

Island . .
CUMBEI
Chebeague
Pomt
. v V Great
^"-jfchebeag
Island
V
APPROXIMATE SCALE
10,400 FEET
FIGURE 17
NATIONAL DIOXIN STUDY
LOCATION PLAN
CENTRAL MAINE POWER R-O-W
YARMOUTH, ME.
EC JORDAN CQ
27

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•J ' L
¦ ^371
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>•* i- 4 1 ..
BANGOR AND AROOSTOOK
« SAMPLING SITE
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FIGURE 19
NATIONAL DIOXIN STUDY
LOCATION PLAN
J. HUBBARD, INC.
NASHUA, N.H.
EC. JORDAN CQ
29

-------
\JZJ


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FIGURE 20
NATIONAL DIOXIN STUDY
LOCATION PLAN
CARROLL PRODUCTS
WOOD RIVER JCT., R.I.
EC.JORDANCQ
30

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IV. SAMPLING PROGRAM
The purpose of the National Dioxin Study sampling program is to collect soil,
sediment, fish, and shellfish samples from various sites in Tiers 3, 5, 6, and
7. In a nationwide sampling effort, samples collected in any area or region
must be not only representative of the sample site, but also be consistent with
and comparable to those collected in all other regions. To ensure this, a
standard protocol, Sampling Guidelines Manual for the National Dioxin Study,
was developed by EPA. Specific methodologies developed for collecting, hand-
ling, and shipping of samples are included in the manual. The sampling program
described in this report included only soil and sediment collection and was
conducted in conformance with the specified methodologies. The following
sections summarize those procedures; any variations which occurred during the
sampling episodes are specifically identified.
PRESAMPLING PROCEDURES
Site Contacts
Initially special emphasis was given to contacting the owners and/or represen-
tatives of the various sites selected for sampling. Telephone contact was made
with those individuals responsible for the Tier 3 and 5 sites to explain the
purpose of the program and to obtain permission for gaining access to their
property. For the Tier 7 sites, personal contact was made during the initial
site visits, since telephone numbers were not available for several of the
sampling sites. Furthermore, town officials were notified for the Tier 7 sites
and for the two lake sites in Tier 5. In all cases, the individuals contacted
were invited to be present, if they desired, during the sampling episodes.
Site Reconnaissance
Once contact had been made with the respective individuals, a site recon-
naissance visit was conducted. During the visit, a site history was obtained
and the specific site conditions were observed. At that time, the general
sampling area was identified, and it was determined whether a random or di-
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rected sampling approach would be used. A site visit report was then prepared
for each site.
Sampling Plan Preparation
Following the reconnaissance visit, a sampling plan, with a site visit report
appended was prepared for each site. The sampling plan included the procedure
to be followed in collecting the samples; the number of samples to be col-
lected; the specific identification number of each sample; and the location of
each sample point on a site plan.
Selection of Sampling Points
A direct approach was used in selecting the individual.sample points for the
Tier 3 sites and a random approach was used for the Tier 5 sites. At the
direction of EPA, the sample locations for the Tier 7 sites were the same as
those used during the initial pesticides study (NSMP). In an effort to obtain
statistically valid random samples on Tier 5 sites, the following approach was
used:
Determination of the size of the population, from which the random samples of
size n=12 and n=24 were taken, was made to ensure that the sample would provide
representative and useful information about the geographic area. If population
size were not considered, the samples could possibly have been restricted to a
geographic portion of the area which is too small to provide results which
reflect true characteristics of the desired region.
Population sizes were determined by specifying an acceptable relative error in
the estimates, apart from a 1 in 20 chance. The method makes use of the sample
size equation for simple random samples:
n = t2 (cv)2 / fl + t2 (cv)21
r2	N r2
32
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where t = abscissa of the normal curve that cuts off an area a at the
tails. For a 1 in 20 chance of having a larger than specified
error, t=2.
cv = coefficient of variation, a dimensionless measure of
variability desired from the sample estimate, i.e., cv=s/y
r = relative error in the estimated population mean.
N = population size,
n = sample size.
Note that solving the above equation for N yields:
N = [nt2 (cv)2]/[t2 (cv)2-r2n]
Tables 1 and 2 show population sizes resulting from fixing the sample sizes at
12 and 24, respectively, and varying the values of r and cv.



TABLE 1



POPULATION
SIZES
FOR RANDOM
SAMPLE
OF SIZE



cv



0.10
0.15
0.20
0.25
0.30
0.025
15
14
13
13
13
0.05
48
18
15
14
14
0.10
--
--
48
24
18
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TABLE 2

POPULATION
SIZES
FOR RANDOM
SAMPLE
OF SIZE 24



cv



0.10
0.15
0.20
0.25
0.30
0.025
39
29
27
26
26
r 0.05
—
72
39
32
29
0.10
--
—
--
600
72
0.15
m —
~ ""
• —

m —
Because advance estimates of coefficient of variation and relative error were
not available, relatively conservative values were considered when determining
the population size. For a sample of size n=12, a population of size N=48 was
used (see Table 1). The interpretation is as follows: from a population of 48
plots, sampling 12 plots will result in an estimate of the mean which is within
10 percent of the true value (apart from a 1 chance in 20), if variability in
the data is around 20 percent. If variability is greater (e.g., 30 percent),
then the population size of 48 and sample size of 12 will result in an estimate
of the mean which is within 15 percent (apart from a 1 chance in 20) of the
true mean.
Similarly, for a sample of size 24, a population of size 72 was used (see
Table 2). Then for a sample size of 24, the estimate of the mean was within 5
percent of the true value, if variability is only 15 percent (apart from a 1
chance in 20). If greater variation were present, for example, say 30 percent,
then the estimate of the mean would be within 10 percent of the true mean,
apart from a 1 chance in 20.
SAMPLING EQUIPMENT AND SAMPLE CONTAINER PREPARATION
Soil sampling kits, which contained a tulip bulb planter and a one-quart wide
mouth glass jar for each sample, were suppled by Versar, Inc., a subcontractor
to EPA. All sample containers and tulip bulb planters were cleaned by Versar,
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Inc., prior to shipment to the sampling personnel. According to dioxin proto-
col, the cleaning procedure for sample containers was as follows:
1.	Tap water rinse,
2.	Deionized water rinse,
3.	Pesticide-grade acetone rinse,
4.	Pesticide-grade hexane rinse,
5.	Air dried, and
6.	Glassware baked at 150°C for at least two hours.
A similar cleaning method was followed for the sediment core sampler and the
stainless steel spoons and tongs. However, they were not baked at 150° C.
Subsequent to the air drying operations, the tulip bulb planters, spoons, and
tongs were all wrapped in aluminum foil for transport to the field.
GENERAL SAMPLING PROTOCOL
Collection of Soil Samples
The procedures followed in obtaining soil and sediment samples are summarized
below.
1.	For randomly selected samples, the midpoint of each 50-foot by
50-foot randomly selected plot at the site was located using a 100-
foot cloth tape.
2.	At each sampling location, either directly or randomly selected, any
grass covered areas were clipped (if necessary) prior to sampling.
All sampling equipment was checked for cleanliness. A soil sample
was collected by forcing a tulip bulb planter into the soil to a
depth of 4 inches, using a clean planter at each sample location. A
sufficient quantity of sample to fill a one-quart wide mouth sample
container half full was obtained at each location.
3.	The sample from each sample location was placed into a large clean,
unused, disposable aluminum foil pan. Stones, roots, twigs, grass,
35
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and other debris were discarded with a clean pair of tweezers. The
"screened" sample was placed into the appropriate sample container.
4.	One duplicate sample was obtained for every 12 samples collected.
5.	All necessary field data forms were completed for the sample and
identifying labels were attached to the container. Duplicate samples
were labeled with an individual sample code, but not identified as a
duplicate. All sample transport containers were sealed in the field
with a tamper-proof seal. Jar lids were taped securely. A chain-
of-custody record was initiated for the sample set. The samples were
then packed for shipment, along with the required field blanks and
performance evaluation samples.
6.	Once a sample was collected, steps were taken to preserve the chem-
ical and physical integrity of the sample during transport and
storage prior to analysis. Soil samples were shipped to the labora-
tory at ambient temperature and kept away from direct sunlight until
they were prepared for laboratory analysis. No other preservation
was necessary.
7.	The EPA Sample Control Center was contacted and provided the pertin-
ent information on the samples collected.
8.	The samples were shipped to the designated laboratory. Soil and
sediment samples from Tier 3 sites were shipped to a Contract Labora-
tory Program (CLP) laboratory; samples from the Tier 5 and 7 sites
were shipped to EPA's TROIKA laboratories. Samples shipped to the
CLP laboratories will be analyzed to 1 part per billion; samples sent
to TROIKA will be analyzed to 10 parts per trillion.
Collection of Sediment Samples
1.	The midpoint of each 50-foot by 50-foot randomly selected grid at the
site was located, using an electronic distance meter (EDM).
2.	All sampling equipment was checked for cleanliness. The gravity core
sampler was washed with lake water and wiped with a clean cloth
between use at each sample point. The sediment sample was collected
by dropping the corer from a near surface position into the lake
bottom. A minimum of 500 grams of sediment (enough to fill the
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one-quart wide mouth containers half full) was obtained at each
sample location.
3. The sediment sample was discharged from the corer into a large clean,
unused, disposable aluminum foil pan. Following settling of the
sediment, the water was poured off the sample and any stones or other
foreign materials were removed using a clean stainless steel spoon.
The remaining sediment was then placed into the appropriate sample
containers.
The subsequent steps were the same as those for collecting soil samples,
which are itemized in Nos. 4 through 8, in the previous section.
SYNOPSIS OF SAMPLING EPISODES
The sample collection episodes were conducted during September 1984 at all
sites. Table 3 shows the latitude and longitude coordinates for each site and
also indicates the number of samples collected per site.
A total of 116 soil samples and 31 sediment samples was collected in Region I
as part of this program. Each sample location is shown in Appendix B. A brief
summary of each episode is presented below. Any variances from the general
sampling protocol or any deviations from the sampling plans have been incorpor-
ated into these summaries.
Pittsfield, Massachusetts Area
One soil sample from each of nine sites was collected during the sampling
episode in this area. Figures B-l through B-9 in Appendix B show each sample
location. During the reconnaissance visit, the previous pesticide sample
locations (NSMP) were identified at all sites except those located in the State
Forest, and were used as sample points for this episode. The sample location
in the State Forest could not be accurately determined; therefore, a
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TABLE 3
SAMPLING SITE LOCATIONS




Site

No.
No.
Total

Type

Potential



Coordinates
Sampling
Duplicate
No. of
Episode
of
Sample No.(s)
Dioxin
Tier Site Name
Location
Lat.
Long.
Points
Samples
Samples
Case No.
Sample
Source
7
Sewage Treatment Plant
Pittsfield, MA
42°23
22"
73°14
54"
1
0
1
2261
Soil
DA000301
Background

198 Union St.
Pittsfield, MA
42°27
14"
73°15
22"
1
0
1
2261
Soil
DA000302
Background

Sykes Mountain Rd.
Pittsfield, MA
42°24
05"
73°11
50"
1
0
1
2261
Soil
DA000303
Background

Berry Pond Circuit Rd.
Pittsfield, MA
42°29
28"
73°19
13"
1
0
1
2261
Soil
DA000304
Background

255-257 Merrill Rd.
Pittsfield, MA
42°27
23"
73°13
03"
1
0
1
2261
Soil
DA000305
Background

53 Yarmouth St.
Pittsfield, MA
42°29
32"
73°l4
21"

0
1
2261
Soil
DA000306
Background

44 Dexter Ave.
Pittsfield, MA
42°26
17"
73°14
20"
1
0
1
2261
Soil
DA000307
Background

57 Winter St.
Dalton, MA
42°27
06"
73°11
27"
1
0
1
2261
Soil
DA000308
Background

Swamp Rd.
Lanesborough, MA
42°29
29"
73°12
27"

0
1
2261
Soil
DA000309
Background
7
205 Scarborough St.
Hartford, CN
4l°47
05*'
72°42
30"
1
0
1
2262
Soil
DA000401
Background

Jennings Rd.
Hartford, CN
41°47
09"
72°39
13"
1
0
1
2262
Soil
DA000402
Background

Washington St.
Hartford, CN
41°45
39"
72°40
59"
1
0
1
2262
Soil
DA000403
Background

Copper Hill Rd.
Hartford, CN
42°01
07"
72°44
53"
1
0
1
2262
Soil
DA000404
Background

Russell Rd.
E. Granby, CN
41°56
40"
72°42
13"
1
0
1
2262
Soil
DA000405
Background

Longhill Rd.
Andover, CN
4l°45
50"
72°22
38"
1
0
1
2262
Soil
DA000406
Background

Hayden Station Rd.
Windsor, CN
41°53
27"
72°37
50"
1
0
1
2262
Soil
DA000407
Background

Old Poqunock Rd.
Windsor, CN
4l°53
17"
72°4l
42"
1
0
1
2262
Soil
DA000408
Background
7
Route 2A
Lunenburg, MA
42°35
50"
71°41
55"
1
0
1
2263
Soil
DA000501
Background

Billings/Richardson Rds.
Fitchburg, MA
42°37
28"
71°48
29"
1
0
1
2263
Soil
DA000502
Background

112 Sheldon Rd.
Fitchburg, MA
42°36
10"
71°50
20"
1
0
1
2263
Soil
DA000503
Background

Klondike Ave.
Fitchburg, MA
42°35
25"
71"46
40"
1
0
1
2263
Soil
DA000504
Background

South St.
Fitchburg, MA
42°34
40"
71°48
00"
1
0
1
2263
Soil
DA000505
Background

29 Vine St.
Fitchburg, MA
42°33
50"
71°49
08"
1
0
1
2263
Soil
DA000506
Background
5
Lake Abenaki
Thetford, VT
43°50
00"
72°14
11"
21
2
23
2270
Sediment .
DA000901-DA000923
Silvex
5
Clara Lake
Whitingham, VT
42°47
52"
72°52
40"
21
2
23
2271
8 Sediment
DA001001-Da001023
Silvex
5
CMP R-O-W
Yarmouth, ME
43°47
08"
70° 11
46"
21
2
23
2331
13 OOll
Soil
DA001101-DA001123
2,4,5-T
5
B&A R-O-W
Grindstone, ME
45°42
39"
68°36
43"
21
2
23
2332
Soil
DA001201-DA001223
2,4,5-T
3
J. Hubbard
Nashua, NH
42°45
16"
71°28
05"
8
1
9
3331
Soil
DA001301-DA001309
Hexachlorophene
3
Carroll Products
Wood River Jet., RI
41°26
21"
71°41
27"
21
2
23
3332
Soil
DA001401-Da00l423
2,4,5-T
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sampling point located at the Berry Pond Circuit Road was selected (see
Figure B-4). No variance from the general sampling protocol was required
during this sampling episode.
Hartford, Connecticut Area
Eight soil samples were collected from this area during the sampling episode.
During the reconnaissance visit, the previous pesticide sampling (NSMP) locat-
ions were identified as shown in Figures B-10 through B-17 for sampling during
this effort. Since no extenuating field circumstances were encountered, the
general sampling protocol was followed on these sites.
Fitchburg, Massachusetts Area
Six soil samples were collected from points in this area sampled during the
former pesticide study (NSMP). The locations were identified as shown in
Figures B-18 through B-23 during the reconnaissance visit. No variance from to
the general sampling protocol occurred.
Lake Abenaki
Field locations of specific sampling points at this site were determined by
using an electronic distance meter (EDM) placed on the shore as shown in Figure
B-24. Using a two-way radio, the EDM operator directed the sampling crew to
each of 21 sample points. The 23 sediment samples (including two duplicate
samples) were collected according to the required sampling protocol.
Clara Lake
Because the water level in Clara Lake had been lowered in 1982, both sediment
and soil (former lake bottom) samples were collected on this site. The number
of each type of sample was based on the proportion of existing lake area to
former lake area. As a result, eight sediment and 15 soil samples, as shown in
Figure B-25 were collected. The collection of these samples was in conformance
with the required sampling protocol outlined above.
39
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Central Maine Power Co. Right-of-Way
The 23 soil samples on this site were collected following the steps outlined in
the general sampling protocol. The location of four sample points (Samples
DA001107, DA001108, DA001115, DA001117 shown in Figure B-26 of Appendix B) had
to be altered due to specific site conditions. The sampling location of Sample
DA001107 was moved 10 feet north from the center of the grid due to a bedrock
outcrop in the area. Sample DA001108 was collected in a suspected spray
location which was 6 feet north and 2 feet west of the center of the grid. The
location of Samples DA001115 and DA001117 were changed since the center of
their respective grids fell within a maintenance roadway on the site.
Bangor and Aroostook Railroad Right-of-tfay
Twenty-three soil samples were also collected at this site. The locations of
two sampling points were moved beyond the railroad ballast to native soil.
Samples DA001203 and DA001211 were collected 13 feet from the center of the
track rather than six feet as intended prior to sampling. The revised locat-
ions for these two samples are shown in Figure B-27. The remaining 21 samples
were all collected within the ballast or subgrade. Due to the large number of
stones in this area, samples were collected from the upper 4 inches of material
by using large stainless steel spoons rather than the tulop bulb planters. No
other modifications to the sampling procedures were necessary at this site.
J. Hubbard, Inc.
Nine soil samples as shown in Figure B-28 were collected at this site following
sampling protocol. Fewer samples were collected at J. Hubbard than the other
sites in this program due to the limited open soil areas available for samp-
ling. The limited size of the alcohol operation conducted on this site was
also a determining factor in reducing the number of samples. Sampling crew
members and EPA personnel agreed that samples should be collected from areas
which were potentially impacted due to spills or disposal operations.
40
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Carroll Products, Inc.
Twenty-three samples were collected at this site. Eighteen soil samples were
collected following the guidelines of the general sampling protocol. Five soil
samples were obtained in the area designated as the former wet lagoon using a
modified procedure. The sample locations are shown in Figure B-29. The lagoon
area functioned as a disposal area from 1976 until 1983. The amount of sediment
collected in that area between 1976 (when the 2,4,5-T was repackaged at the
site) and now cannot be accurately predicted. Therefore, soil (dried lagoon
bottom materials) was collected from two depths; 0 to 4 inches and 4 to 8
inches. A clean tulip bulb planter was used in collecting each sample.
CHAIN-OF-CUSTODY PROCEDURES
To ensure the integrity of the samples, once they were collected, an accurate
written record of possession, a chain-of custody, was maintained. The chain-of-
custody traces possession of the sample from the moment of its collection until
its analysis. Three types of chain-of-custody documents were used during this
program: sample labels, chain-of-custody records, and custody seals.
A sample label was completed and securely attached to each sampling container.
The information recorded on the label included:
o Sample Number - The unique identification number used to document
that sample.
o Episode Number - The unique number assigned by SCC to that sampling
event.
o Date - A six-digit number indicating the month, day and year of
collection,
o Preservation - Type used, if any.
o Analytical Parameters - Listed as dioxin.
After attaching sample labels to and packaging each container, samples were
shipped with an accompanying Chain-of-Custody Record in accordance with Agency
enforcement requirements. For Agency purposes, a sample is considered to be in
41
11.84.154
0045.0.0

-------
an individual's custody if the following criteria are met: if it is in your
possession or it is in your view after being in your possession; or if it was
in your possession and then locked up or transferred to a designated secure
area. The sampler is responsible for the care and custody of the samples
collected until they are shipped.
A separate Chain-of-Custody Record (Figure 21) signed and dated by the sampler
accompanied each sample shipment to the laboratory. The custody record was
enclosed in plastic (with the Dioxin Shipment Record) and taped to the under-
side of the cooler lid. Shipping coolers were secured and sealed with a
custody seal for shipment to the laboratory. Custody seals were placed across
the cooler opening so that the cooler could not be opened without breaking the
seal. At the laboratory, the representative accepting the incoming sample
shipment signed and dated the Chain-of-Custody Record to acknowledge receipt of
the samples, completing the sample transfer process. From that point on, the
laboratory maintained its own internal records.
11.84.154
0046.0.0
42

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CHAIN OF CUSTODY RECORD
PROJECT NO.
PROJECT NAME
NO.
OF
CON-
TAINERS
SAMPLE TYPE
REMARKS
INDICATE
SOIL/WATER/AIR
SEDIMENT/ SLUDGE












SAMPLERS (SIGNATURE)
STA. NO.
DATE
TIME
CO MP.
GRAB
STATION LOCATION












































































































































































































































































































4>
00
RELINQUISHED BY: (SIGNATURE)
DATE/TIME
RECEIVED BY= (signature)
RELINQUISHED BY-(SIGNATURE)
DATE/TIME
RECEIVED BY; (SIGNATURE)
RELINQUISHED BY: (SIGNATURE)
DATE/TIME
RECEIVED BY- (Signature!
RELINQUISHED BY: (SIGNATURE)
DATE /TIME
RECEIVED BY'(SIGNATURE)
RELINQUISHED BY: (SIGNATURE)
DATE/TIME
RECEIVED FOR DISPOSAL BY
(SIGNATURE)
= I DATE/T
I I
IME REMARKS
FIGURE 21
E.C.JQRDANCQ

-------
APPENDIX A
SITE DOCUMENTATION

-------
LAKE ABENAKI
SITE DOCUMENTATION

-------
P N"
Permit Number 	
PElUlIT" FOR APPLICATION OF CHEMICALS
INFORMATION RETURN FORM
In order for the Department of Water Resources to
maintain records of the amount of chemicals placed in the
waters of the State, the applicant must fill out the
following form and return it to the Department.
Name of Applicant	\Al7=iht*r
Address of Applicator	W In J?* \ajo/A (U
Body of Water Receiving Chemical
Please fill out:
I
Name of Chemical Applied nl ^hT) ~t~ ^i I 	 j
Amount of Chemical Applied (.S	£ **(—¦3s* T**	( <, Si/v&X
Chemical was applied on the following
date \a y. \Q		
/
Chemical was not applied.
Check one:
&
Q
WR-51-2

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PERMIT
PERMIT NO. AN 18 75
PERMIT TO APPLY CHEMICALS FOR THE CONTROL OF AQUATIC NUISANCES IN WATERS
OF THE STATE
Permission is granted Swift Water Girl Scout Council, Inc.	(its)
agent, or agents, to apply the listed chemicals to the waters
Lake Abenaki	, located in 	Orange	county,
Thetford	town, in conformance with all statements,
agreements and restrictions imposed, made, or accepted by the
applicant ana/or applicator, in the application signed by
Jennifer Plourde	 and	,
respective addresses P.O. Box 632. Clarmont. ana 	
		•	N.H.
This permit is issued subject to the following conditions:
1.	Chemical will be employed on or about (date, year) June, 197*=;
2.	Chemical used (name of chemical) 	Silvex	
3.	Number of pounds 	 or volume of chemicals 	
to be used. Percent or weight of active ingredient 	
4.	Area to be treated 	15	and average aep-
	feet.
5.	Use of the treated waters and those waters affected by the
treatment will be prohibited during the chemical treatment
and for	thereafter.
Additional Restrictions
This permit shall be invalid and the application of chemicals
will be held a violation, if the applicant fails to comply with
the permit terms, or fails to notify the permit issuing official
and the following offices at least (7) days before the time of the
chemical treatment.
FOR THE BOARD, DEPARTMENT OF WATER RESOURCES
Dated June 17, 1975	 Name	^
Title	Aquatic Biologist
A-3

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Permit No.
APPLICATION FOR PERMIT 70 APPLY CHEMICALS
FOR THE CONTROL OF AQUATIC NUISANCES
IN THE WATERS OF THE STATE OF VERMONT.
INSTRUCTIONS
Permit for application of chemicals to water for control of aquatic nuisances
must be obtained from the Board of the Department of Water Resources except:
--When treatment of water supply waters is to be made by a duly constituted
water supply agency, or,
—Those private waters which do not combine or effect a junction with natural
surface waters.
Application should be completed accurately and submitted to the Department of
Water Resources at least 30 days prior to proposed date of application of
chemicals.
The Department of Water Resources has personnel available to assist in filling
out an application.
DATE: Mav 28.1975
Tc: Vermont Water Resources Board
State House,-Montpelier, Vermont
Application is hereby made under the provisions of Title 10,-SecrTorr—910'. of
the Vermont Statutes Annotated and the policies issued pursuant thereto for
approval to apply chemicals for the control of aquatic nuisances.
* * ***************************
* ***********
Applicant	Date
(.ft Water Girl Scout Council, Inc. May 28,1975
Check one.or more
Owner(s)	Riparian Owner (s)_
Abutter(s) .
Official Address
''£5 Merrill St.
fichester, H.H. 03103
Name of waters
Lake Abenaki
Location (city, town,^village)
TVipffnrd
County r ~*** c-: ^	
Describe specific location of waters and parts thereof to be treated (attach sketch)
|rea south of main dock area, approximately 15 acres
Is there a regular
flowing outlet?
Yes i/ No	
Can applicant control
levels in body of water?
Yes ; No ^
If yes, how?	n,
^ ¦¦ '>'
Proposed dates of treatment
Between June 9, and June 11.
Tote Cr€t	cJ s, r
-------
Tvpe of nuisancs td be controlled: scun;	Chemical ~.o be used:
emergent or submergent weeds aJ.gae, bLooms.
etc. Fotanoeeton species, Nyrphea odornta, nupnar,	Silvex
and Tyoha 		
Name and Address of Applicator
Northeast Weed Control , Co., Inc.
J.47 Whitewood Rd.
¦estwood, Mass. 02090
Check uses of body of water to be treated
Boating XX , bathing XX .private water
supply XX livestock watering
other 	.
Are these waters stocked with trout by
the State? Yes 	 No i/
Don't know 	
In waters which may be affected by
the treatment, name all known fish
(3w	rc
Are other riparian owners, both in the vicinity of the treated area and	along
the outlet stream who may be required to restrict their water usages as	a
result of the treatment, familiar with your plans? Yes X No 	,	agreed
to restrictions?- Yes x No 	.
Will the riparian owners be alerted in advance of the treat-
ment? Yes X No 	 Are you prepared to adequately
post the shore line of the area to be treated with suitable
IF REQUIRED: warning signs? Yes X No 	 Will you submit water
for chemical analyses, both before and after treatment?
Yes X No 	.
The applicant and applicator guarantee that they will employ chemicals in con-
formance with all the conditions of the permit. In addition, the applicant
and applicator agree to accept the following conditions as a prerequisite to
the issuance of a permit; That 'the issuance of the permit is based on the
assumed accuracy of all statements presented by the applicant. Damage resulting
from the inaccuracy of any computations, improper application of the chemical,
or legal responsibility for the representations made in obtaining approvals or
releases, or failure to obtain approvals or releases from the riparian owners
likely to be affected is the joint and several responsibility of the applicant
and applicator. Applicant and applicator in consideration of the issuance of
the permit hereby applied for, hereby guarantee to hold the State harmless
from all suits, claims or causes of action arising out of the use of chemicals
pursuant to or occasioned by such permit.
Signature (Applicator)	Title	Mailing Address
'c-j	' <\	(O QO	15 Beaver Pond Road
Proctor, Vt. 05765
David A. Couehlin	Applicator
Signature (Applicant)	Title	Mailing Address
P-°- Box 632
* Clarmont, N. H.
Jennifer Plourde	Director. Camp Farnsvorth	
A-5

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°rt/
W.
/
/
\
\
\
\
\
\
5
*V
4~t
2>V

-------
PROJECT DET/.ILC
t— v 1_ . V—- 'd.v\0	AaL<_(' ':-•,•
(1)	I'asie of Applicant 0	v ^
(2)	Location of Dody of Uater 'T'iv.tt.-jcv.
(3)	Name of Body of Water
(i)	Number of Surface Acres to be Treated /^
(5)	Volume of Uater to be Treated	.
(6)	Aquatic Vegetation Present \Pb"Tq
(7)	Name of Chenical to be Used ^/IVc'X'
(C) Application Date	^7^"
(9) "unber of Pounds of Active Ingredient
(10)	Total Hunter Pounds of Chemical
(11)	Application Method
icir AA J*it1rKirk ,'.UAAUa A.1 krrkirJx A A 'A A A*.'. 'A'A^ r^Er'A A A A* A A A A rank A A A A A A A A A A A* A A A A X A A A A 'A .'. A A A'/, aAA'A A A 'A'
FCH DEPARTMENT USE ONLY
(12)	Chemical Data
pH		 Color		
Total Alkalinity		 Turbidity 	
Total Acidity		-
Hardness		
(13)	Name of Applicator
(14)	Proposed Date of Treataent
(15)	r.ecoimandations	<_>u2j5^Sj3 ctjJnsv,-^^
(16)	Permit Number
(17)	Control Obtained
I7R- 50
A-7

-------
Department Routing:
1. Department of Agriculture
Remarks:
& -2.
U r-L »
V.
2. Department of Forests L Parks
Renarks:
'(c-fw;,k-- . , C'c~ i .

f APPROVED
DISAPPROVED
/J/1,,
~1

(Signature & Title) J
i	/U $<¦ '<	£-7;
3. Department of Fish and Game
Remarkz:
APPROVED
DISAPPROVED
in
I (Signature ^.Xltl-ft.)-^- ?
A-8

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CLARA LAKE
SITE DOCUMENTATION
9.84.6
0027.0.
A-9

-------
?IT-HI KO. A'v 2 72
to apply chehzcals fox tks co::i?jdl or aquatic nuisances in waters of the state
Pemission is £T.-nted	jQgy-ptg n.	(its) agent,
or events, to c??ly the listed chesicals to the waters Laice Clara
located in Windham	county. Whit Inchon	town, in
coruorr.ar.ce with ail statements, a^reerLents and restrictions imposed, made,
or...accepted by the Applicant and/or applicator, in the application signed by
Joseph O. Procter	end		. respective
addresses 1053 Brush Hill Road and	.
Milton, MA
This permit is issued subject to the following conditions:
1.	Cheraical will be employed on or about (dace, year) Summer 1972
2.	Chenical used (:-.ame of chcnicaU Aouathol Plus
3. Kumbc: of pounds 1.0 PPITI	or volur.e of chemicals
to be used. Percent or wai~/.t of active ingredient^
4.	Area to be treated ___	18	acres) and averse depth
feet.
5.	Use of the treated waters and those waters effected by the treatment will
be prohibited during the chosical treatment and for 	
thereafter.
Additional Restrictions
Acuathol Plus contains Encothall (22.1%) which is a Class A
pesticide and requires a licensed applicator.
This perir.it shall be invalid and the application of chemicals will be held
a violation, if the applicant fails to comply with the permit terras, or fails
to notify the permit issuing official and the following offices^it le^sp
days before the tine of the chcsical treatment.	4 *
,,yj / /
Dated October 7 / 1971
"OR THZ ECARD, DZ?ARTI£E:rr OF WATS RESOURCES	f
/ /'
? i t lc COTTlTTlis
V.
7^
ifieucr of ¦
TCn-htar T)r
-------
PERMIT
PERMIT NO. AN 20 73
PERMIT TO APPLY CHEMICALS FOR THE CONTROL OF AQUATIC NUISANCES IN WATERS OF THE STATE
Permission is granted Allied Biological Control Corporations) agent,
or agents, to apply the listed chemicals to the waters Lake Clara
located in 	Windham	county. Whitinaham	town, in
conformance with all statements, agreements and restrictions imposed, made,
or..accepted by the applicant and/or applicator, in the application signed by
Jason Cortell, Cons. Biologi&t	, respective
addresses Allied Biological Controid	.
Corporation, Wellesley Hills, Mass. 02181
This permit is issued subject to the following conditions:
1.	Chemical will be employed on or about (date, year) July 11, 1973
2.	Chemical used (name of chemical) Sllvex		.
3.	Number of pounds 5 gallons	or volume of chemicals 	
to be used. Percent or weight of active ingredient	.
4.	Area to be treated (Spot treatment) (sq. ft. acres) and average depth
	feet. Follow-up of 19*72 application.
5.	Use of the treated waters and those waters affected by the treatment will
be prohibited during the chemical treatment and for 		
thereafter.
Additional Restrictions
This permit shall be invalid and the application of chemicals will be held
a violation, if the applicant fails to comply with the permit terms, or fails
to notify the permit issuing official and the following offices at least (7)
days before the time of the chemical treatment.
FOR THE BOARD, DEPARTMENT OF WATER RESOURCES
Dated 		July Id, 1973	 Name	[^
f yO
i
Title Acting Commissioner of
Water Resources
WR-51
A-ll

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CENTRAL MINE POWER CO.
SITE DOCUMENTATION
9.84.151
0025.0.0
A-12

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CMP I Central Maine Power Company
GENERAL OFFICE. EDISON DRIVE. AUGUSTA. MAINE 04336
(TWX NUMBER, CMP-AGUA 710-226-0195)
(207) 623-3521
June 25, 1984
Mr. David Courtemanch
State Environmental Protection Agency
State House
Augusta, Maine 04333
Dear Mr. Courtemanch:
SPRAYING COMPLETED ON SECTION 164 § 165 IN YARMOUTH f RT
Poles
Date
Application
Chemical
Gallons
Used
2-6
11/6/78
Stump
Spray
Tordon
101R
3
6-9
11/7/78
Stump
Spray
Tordon
101R
4
9-14
11/8/78
Stump
Spray
Tordon
101R
8
18-26
11/2/78
Basal
Spray
*Tordon
155
200
26-29
11/1/78
Basal
Spray
*Tordon
155
150
29-31
10/31/78
Basal
Spray
*Tordon
155
200
31-35
10/30/78
Basal
Spray
*Tordon
155
250
*Mixture for Tordon 155 = 5 qts. Tordon 155 to 100 gals.
kerosene.
Very truly yours,
rush Control Coordinator
LJK/ed
A-13

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BANGOR AND AROOSTOOK RAILROAD
SITE DOCUMENTATION
9.84.118
0026.0.0
A-14

-------
STATE OF MAINE
Inter-Departmental Memorandum n,,. August 14. iqra
Tc Robert L. Penny. Dirertor
From M. Dawn Charest. Secretary
Debt. Board of Pes.ticidesControl. AFRR
Dept.	II	"	'*	
Subject 1975-1983 Sprav Reports re Maine Railroad's R-O-W Spraying
The following chemicals (herbicides) were used by "Railroad Weed Control, Inc.
during the spray seasons June through September 1975-1983 at various locations in
Maine for brush/weed control for Maine railroads:
1975
Amdon 101
atratol 80W
atrazine
Banvel 720
Dicamba
MSMA
Picloram
Princep
Simazine
Tordon 101
2,4 D
1979
accutrol
atrazine
Banvel 720
Dicamba
Evik 80W
Lo-Drift
Princep
Simazine
2,4 D
1976
Amdon 101
atratol 80W
atrazine
Banvel 720
Dicamba
picloram
Princep
Simazine
2,4 D
1977
atratol 80W
atrazine
Banvel 720
Di camba
Lo-Drift
MSMA
Princep
Simazine
2,4 D
*2,4,5 - T (See attached)
1978
ametryn
atratol 80W
atrazine
Banvel 720
Dicamba
Evik 80W
Princep 80W
Simazine
2,4 D Amine
1960
atratol 80W
Banvel 720 (also 4WS)
Dicamba
diuron (Karmex) 80W
Evik SOW
Lo-Drift
Princep
Spike 80W (tebuthiuron)
Surflan 75W (oryzalin)
2,4 D Amine
Weedar 64 (2,4 D)
1SS3
atratol 90%
atrazine
Banvel 720
Bromacil
Dicamba
Diquat dibromide
Diuron
Garlon
glyphosate (Roundup)
Ontrack 8E (metolachlor)
Princep 90%
Simazine
2,4 D Amine
Weedar 64
1981
atratol 80W
atrazine
Banvel 720
dalapon (Dowpon M)
Dicamba
Diquat
DMA 4
Evik 80W
glyphosate
Lo-Drift
Ontrack 8E
Princep 80W
Simazine
Triclopyr (Garlon 3A)
X 77 (surfactant)
1982
atratol 90:
Banvel 720
Diquat
Ontrack 8E
Princep
Weedar 64
X-77
(Roundup)
(metolachlor)
A-15

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REPORT OF PESTICIDE APPLICATION
TO: HoAtin oi- I'i si inin s Conihoi., Statu Officii Bi.ik:.. Homi fiOl, Augusta, Maine 04330
Applieation Date(s		
..Town 	 Company
Operators Name		_Contratling
Kxaet Locatioi	(Z&kt/itJ)					
Size of area (Aires, road mileage. N'o. of shade trees, etc.
Pesticide*	ion applied	applied
JfC£ &?#&>?
Method of application
J/lurgct organism
Disposition of mimed material, empty containers, etc.;
Difficulties encountered (equipment trouble, spillage, spray stream problem, leaks, ^atjietIp/lCMArl
jUdZtehdJSavUba
y.nifCfl	vO, s£3Z $(5tts3£bau&/2k
"MS,-
* Cive rominon name of the* actual chemical (s) and not some trade or mannfactnrer's name for it.
t 11(1(1

-------
Ra
RAILROAD WEED CONTROL, INC.
SUMMARY OF DAILY \PPLICAT10N
	Division			 0..	Spray Truck \VS s ^
Type Applicaiioi	$/L


9sa
¦f? r /¦'



/// ^

7T. ;^ y'/^^///3r, ?r fl
U-J3 I
1 -•S.ZXfl	?f

367

¦-apis?



2£i^Z

^52



^£22
4to£
^ / .< ¦
I-/.35 --

. s/V'sSifj&S>Vs=2p- 'S,
<&/c3V ; >7-;
/&>
£11
7
G*t% 3?Oh
4<5d
75 J
1CA 9+.>+' s*	"Jj£ jfrJ St
&L
h/2+
y/y	& C

¦•/;
xw~
|'/v/°-j YSG/vs* i/s2r^



„	rzp^c^}	




\mi
J?J>X
Molt: Inst-M Mjnii- of cfiema"*! in column heading
PRINTED IN
A-17

-------
J. HUBBARD, INC.
SITE DOCUMENTATION
A-18

-------
form 1479-A
—(KEV. DEC. 1»70)
department of the treasury - internal revenue service
Formula for Article Mad* with Specially Denatured Alcohol or Rum
(See Instruction* en back)		
*1* NAME (Also atare former name, if changed recently)
J. Ru*bartt Canpan/, Inc.
2. DATE
0-26-73
%. AOOAESS (Number and Street, City* State, and'ZIP Code)
,\ih St., >• aHuua, H.H. 0?0t»u
«. INDUSTRIAL USE PERMIT
NUMBER
L». TYPE OF OPERATION (Check applicable boxes)
•i Q MANUFACTURER	Q DISTRIBUTOR Q BOTTLER
6. IS SPECIALLY DENATURED ALCOHOL OR RUM TO BE
RECOVEREB FROM THE MANUFACTURING PROCESS'
	~ YES	O NO
Vi
7. NAME OF ARTICLE, OR USE OF ALCOHOL OR RUM IF AN ARTICLE IS NOT TO BE MANUFACTURED
3r. Wusa* rfl **nrfae«» 'in rra I e 1 da nr.d Air Pcoticf Iter
8. CODE NUMBER
h I r-
». SPECIALLY DENATURED ALCOHOL OR RUM FORMULA USED (Specify denaturants in these formulas
„ p.,.,..,,.....	JW	, t<1[^
10. PROOF
rZUVE
T012-^Mi
1 b>0
11. FORMULA
..NOTE: Formula must total one gallon or multiple thereof
and quantity of each ingredient in one gallon of
the finished product should be stated, as In the
following type of formula:
Any action taken on this formula is in conjunction with the sample bearing same laboratory
number as is stamped hereon, and the finished product manuiactured under this-formula
must be in all respects exactly like the sample submitted for approval.
lQEW£08M/ng
PflOT fti,	-
Oil of rose ------ : 01.
SD Alcohol ------72 oi.
Water---- q. s. 1 gallon
Color------------ q.s.
Submit original, revised or
additional labels for approval.
ACTION fTkis jpacr reserved)
^ '
1
I
:i
r *
-11a. FORMULA IS
^ Q NEW
~ REVISED
Q RESUBMITTED

^1 lb, STATE FORMULA (Describe process when required by regulations) t /
*&¦	f I «02«	IVOI «
S 2A A1coho\
Vater
* U » ! s •
Hexaciilorophetie
To to I *
t P!4 K «»c#totc
26
2
( .02*»//q*t .)
23.as
u.30
1 ?.3

r
ioox loot,
c
Ui
h-
H
o
o
b
2
c
—J
<
£
<
-J
X
u
<
\
j. 11. SIZES OF COMMERCIAL PACKAGES
ft*;. J O*. 0* ., 1:» 0: . ,
32 OZ • |l)'l iiZ < ! 1 1
14. signature of applicant or authorized agent
J.Huot^rd Ct>T4i.*aAJ^x
3 ''do NOT WRITE BELOW THIS LINE ^
' IABOMTORY NUMBEI) sample
f- 41a d ft *
ACTION
rFr'j'r""^
v /• ^ 4 /-
^ For T:;K hthfctor ' Chsalat
BjbLSORATORY NUMBER OIL
¦r
jjiaj^ffiana fiurabau^ii
llSps ' '~
nA V
"*s-*
A-19

-------
ATTACHMENT 1
Questionnaire #_
1. Person to be contacted for Information pertaining to this questionnaire:
Name
Donald Torres
2.	Plant Name:
3.	Plant Address:
Title
President
J. Hubbard, Inc.
94 Ash Street
Telephone
(,n£W-Wa3^e)
Street
Nashua, New Hampshire 030fl
City
State
*ip
Latitude/Longitude of Plant: 40 x 60
(If unknown, a full description of location for the purpose of. plotting
on U.S.G.S. maps.)
Wama.	J- Hubbard, Inc.
5. Company Address:
94 Ash
Street



Street


Nashua
New Hampshire
030f 1
City
State
Zip
6. If this plant was acquired or leased from another owner, Identify date and
lessor or former owner below.
Name_
Month
J. Hubbard Company
¦^v	y¥I7	~~~VTTC~
7. Is your company currently, or ever been, Involved 1n formulating (blending),
repackaging, or otherwise handling prior
to distribution any pesticides
containing the following compounds?

a) 2,4,5-T, salts & esters
Yes
No
b) sllvex, salts & esters
Yes
No
c) erbon, salts & esters
Yes
No
d) ronnel, salts & esters
Yes
No
e) hexachlorophene, salts &
Yes X
No
esters


f) Isobac 20, salts i esters
Yes
No
g) 2,4,5-TCP, salts & esters
Yes
NO
Note: Actual chemical names for these seven compounds are listed In Table 1.
If "NO" FOR 7a THRU 7g, CHECK THE ITEM BELOW WHICH BEST OESCRIBES YOUR FACILITY,
AND STOP HERE. DETACH AND RETURN PAGE 1 ONLY.
1	)	Sales Office
2)	Warehouse
3)	x Other Mdentlfvl FormuJ a* inp- Plendinc.	
IF "YES" TO ANY OF 7a THRU 7g PROCEED to the NEXT QUEST ION.
A-20

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-2-
NOTE: For Questions 8 through 17, add additional pages H necessary.
8a. Provide year(s) for these activities. (If plant was previously owned by
another company Include these years 1f known.)
	1	2	3

ComDound*
• Formulatlnq ' Reoackaolnq ' Other
' (Blendlna) •
a.
2.4.5-T
1 1 1
b.
s11 vex
1 1 *
c.
erbon
1 1 1
d.
ronnel
1 l »
e.
hexachloroDhene
1 1975-1979 '
f.
Isobac 20
* i i
9-
2.4.5-TCP
¦ i i
~Include salts & esters.
8b. Provide total quantities (1n pounds) for any of the seven compounds
(listed below) used 1n the activities Identified above 1n 8a.
		1	2	3

Compound*
' Formulatlnq ' ReDackaoInq '
' (Blendlnq) ' 1
Other
a.
2.4.5-T
t 1 I

b.
s11 vex
1 1 I

c.
erbon
1 1 1

d.
ronnel
1 1 I

e.
hexachloroDhene
• lbs 1 1

f.
Isobac 20
I « i

q-
2.4.5-TCP
1 l »

~Include salts & esters.
9. Check the Items that best describe the formulating (blending) operatlngs at
the plant at the end of 1982. If none. Indicate by NA, where appropriate.


' 'Temporarily or1


ComDOunci*
' lit u^icra 11un ' Scoso.-al iy
rirrsarisrtly Csased


1 ' Inactive 1
(Month/Year^
a.
2.4.5-T
1 ( 1

b.
s11 vex
% t 1

c.
erbon
1 1 1

d.
ronnel
1 1 1

e.
hexachloroDhene
l I I
Au pu s t i y / y
f.
Isobac 20
1 1 l

9-
2.4.5-TCP
i 1 l

Mnclude salts & esters.
10.	Plant age: ^ years
11.	a. Does this plant generate waste (excluding sanitary waste)?
Yes	 No v
IF NO. PLEASE STOP HERE AND RETURN PAGES 1 & 2 ONLY
A-21

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CARROLL PRODUCTS, INC.
SITE DOCUMENTATION
9.84.60
0025.0.0
A-22

-------
Lawrence W. Bierlein, P.C
LAW OFFICES
CANAL SQUARE
10)4 THIRTY-FIRST STREET, N.W.
WASHINGTON, D.C. 20007
(202) *42- 5250
May 1,1984
CABLE: OBJECTIVE
TELEX 19 2)10 (WU)
440297 (ITT)
Mr. William J. Walsh
U.S. Environmental Protection Agency
60 Westview Street
Lexington, MA 02173
Dear Mr. Walsh:
Attached is the Carroll Products, Inc., response to your letter
and the enclosed questionnaire of April 17.
As indicated in my enclosed letter of November 22, 1983, to
Barbara McAllister, the company was not engaged in formulating or
otherwise producing 2,4,5-TCP. The company bought the purified grade
product from Dow and repackaged it into smaller units on two occasions
Your questions 11-16 pertain to wastes, and these have been
answered from the perspective of this limited 2,4,5-TCP operation.
Please let me know if you have any questions on the enclosure.
in 1976
Sincerely, ^ y
Lawrence W. Bierlein
Enc,
A-23

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ATTACHMENT 1
Questionnaire #	
1.	Person to be contacted for Information pertaining to this questionnaire:
Name	Title	Telephone
(Include area code)
Arthur Schwartz	Dir. of Chemical Opera- (401) 364-7731
tions
2.	Plant Name:	Carroll Products, Inc.	
3. Plant Address: 	P. 0. Box 66
Street
	Route 91	
	Wood River Junction, RI 02894
City	State	Zip
latitude/Longitude of Plant: 	;	
(If unknown, a full description of location for the purpose of^plottlng
on U.S.G.S. maps.)
4.	Company Name:	Carroll Products, Inc.	
5.	Company Address:	Route 91	
Street
Wood River Junction, RI 02894 	
City	State	Zip
6.	If this plant was acquired or leased from another owner, Identify date and
lessor or former owner below.
Name	Sun Chemical Corp.. Fifth Avenue. New York. NY	
Month October	 Year 1971	
7.	Is your company currently, or ever been. Involved In formulating (blending),
repackaging, or otherwise handling prior to distribution any pesticides
containing the following compounds?
a)
2,4,5-T, salts & esters
Yes
No
b)
sllvex, salts & esters
Yes
No
c)
erbon, salts & esters
Yes
NO
d)
ronnel, salts & esters
Yes
NO
e)
hexachlorophene, salts &
Yes
NO

esters


f)
Isobac 20, salts testers
Yes
No
9)
2,4,5-TCP, salts i esters
Yes x
NO
Note: Actual chemical names for these seven compounds are listed 1n Table 1.
IF "NO" FOR 7a THRU 7g, CHECK THE ITEM BELOW WHICH BEST DESCRIBES YOUR FACILITY,
AND STOP HERE. DETACH AND RETURN PAGE 1 ONLY.
1	)	Sales Office
2	)	Warehouse
3	)	Other (Identify)	
IF -YES" TO ANY Of 7a THRU 7g PROCEED to the NEXT QUE SI I ON.
A-24

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-2-
NOTE: For Questions 8 through 17, add additional pages 1f necessary.
Ba. Provide year(s) for these activities. (If plant was previously owned by
another company Include these years if known.)
.	T	I	3

Compound*
• Formulatlnq
' (Blendlnq)
ReDackaalna '
•
Other
a.
2.4.5-T

I

b.
sllvex



c.
erbon

«

d.
ronnel

1

e.
hexachloroohene

1

f.
Isobac 20

•

q-
2.4.5-TCP

1976

~Include salts & esters.
Bb. Provide total quantities (1n pounds) for any of the seven compounds
(listed below) used In the activities Identified above 1n 8a.
	1	2	3

Compound*
' Formulatlnq
' (Blendlnq}
Repackaqlnq •
1
Other
a.
2.4.5-T

1

b.
s1lvex

1

c.
erbon

(

d.
ronnel

1

e.
hexachloroohene

1

f.
Isobac 20
1


q.
2.4.5-TCP
1
1090

~Include salts & esters.
9. Check the Items that best describe the formulating (blending) operatlngs at
the plant at the end of 1982. If none. Indicate by NA, where appropriate.
Compound*
1 'Temporarily or'
• In Operation ' Seasonally 1
1 ' Inactive 1
Permanently Ceased
(Month/Year)
a. 2.4.5-T ' ' '
b. sllvex
1 1 1

c. erbon
1 • 1

d. ronnel ' ' 1
e. hexachloroohene
1 • I

f. Isobac 20 ' ' '
q. 2.4.5-TCP
N/A ' N/A •
1976*
~Facility was engaged in
~Include salts & esters.	repackaging only.
10. Plant age: +35 years
*11. a. Does this plant generate waste (excluding sanitary waste)?
Yes X No	
*See Cover Letter.
IF NO, PLEASE STOP HERE AND RETURN PAGES 1 & 2 ONLY
A-25

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-"3-
12. Is the waste generated a wastewater discharge? Yes	 No X
If NO, go to question 13.
a. What was the average dally total waste generated by this plant In
gallons per day (6PD) and gallons/pound of finished product. If pos-
sible 11st any waste generated for the compounds listed 1n question 7.
Process Waste-	Volume of Waste
water* Flow	per Pound of Finished
Year	Volume (GPD1	Product (Sal/Pound)
~Process wastewater means any water which, during formulating comes Into
dUect contact with or results from the production or use of any raw material.
Intermediate product, finished product, by-product, or waste product Including
rinsing and washing of equipment. Do not Include non-contact cooling water.
A-26

-------
-4-
12b. Provide type of waste disposed, the amount disposed of per year, the waste
hauler (when appropriate)* and the disposal location.
Type of Waste Disposed
(1)	direct discharger: Yes 	 No 	
Name of Receiving Water 	;	
(2)	Indirect discharger -
publicly owned treatment works (POTW) 	Yes 	No
(a) Municipal Authority Name: 		
Address: 	
POTW Name:
Address:
(3)	discharge to a privately owned treatment works 	Yes 	 No
Name: 	
Address: 	
(4)	Contract Hauled 	Yes 	No
Waste Hauler Name:	
Address:	
Disposal Location:
(5) Land Disposal: Yes	 No
Disposal Location: 	
A-27

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-5-
12b. (Continued)
Amount of Waste Disposed:
Fill 1n appropriate columns for amount of waste (gallons) disposed per year.
Year
Direct
Discharge
Indirect
Discharge
Deep Well
Disposal
Contract
Hauled
Land
lisposal
Evaporation
Surface
Iffpoundnent
Other
A-28

-------
-b-
12c. Does this plant have a National Pollutant Discharge elimination System
(NPDES) permit? Yes	 No	
If YES, 11st the permit number and expiration date, and check the Item
that characterizes the wastewater discharge covered by the permit.
Permit #	Expiration Date	Wastewater Discharge
				 	Formulating Process*
	 Non-Formulating Process
	 Non-process wastewater
~See Page 2 for definition of process wastewater.
12d. If the NPDES permit has expired and has not been renewed, provide the
NPDES number for your last permit and the plant's current NPDES
application number, and check the Items that characterized the wastewater
discharge.
Permit #	Expiration Date	Wastewater Discharge
				 	 Formulating Process*
	 Non-Formulating Process
	 Non-process wastewater
NPDES application $
*See Page 2 for definition of process wastewater
A-29

-------
-7-
* 13. Does this facility generate solid waste which requires disposal?
Yes _x	 No	
*See Cover Letter.
If YES, complete rest of 13.
Provide type of solid waste disposal, the amount disposed of per year,
the waste hauler (when appropriate)* & disposal location.
a) Contract Hauled:
1.	Waste Hauler Name: Carroll Products, Inc.	
Address: Route 91, Wood River Junction, RI 02894
2.	Disposal Location: Saugus, MA	
b)	Land Disposal:		
Disposal Location: 	
c)	Incinerator:	X	
1.	Incineration Location: Refuse Energy Systems Co.
100 Salem Turnpike
Saugus, MA	
2.	Disposal Location of 	
Incineration Ash:	Unknown	
Amount of Waste Olsposed
Year
(Lbs.)
Contract Hauled Ccais^
Land Disposed (gals)
1976
230
A-30

-------
Lawrence W. Bierlein, P.C
U® OFFICES
CANAL SQUAJII
10)4 THIRTY RRST STREET, N.W.
WASHINGTON, D.C. 10007
(I0J) J42- JIJO
November 22, 1983
CABLE: OBJICTTWE
TtlSl: » lilt fW)
«40»7(TTI)
Ms. Barbara McAllister
Environmental Protection Specialist
Compliance Section, Waste Management Div.
U.S. Environmental Protection Agency
John F. Kennedy Federal Building, Room 1903
Boston, MA 02203
Dear Ms. McAllister:
This is in response to the October 13 letter to Carroll Products
from Merrill S. Hohmsn, having to do with 2,4,5-TCP. Your questions
from Attachment I are answered in order:
1.	Mitchell Manufacturing Division of Carroll Products never
manufactured this product. They purchased purified grade
2,4,5-Triehlorophenol from the Dow Chemical Company, repackaged it,
and sold it on two occasions in 1976.
2.	Mitchell Manufacturing bought purified grade, not technical
grade, 2,4,5-TCP from Dow Chemical of Midland Michigan and sold it
on only two occasions to Polaroid Corporation, 119 Windsor Street,
Cambridge, MA 02139. No analyses were performed by this company.
3.	None was manufactured.
4.	There was no manufacturing done. Wastes were floor
sweepings, gloves, aprons and similar handling equipment used in the
repackaging of the material.
5.	The -wastes described above were not mixed with other
materials.
6.	The accumulated wastes were taken by the company on
their own vehicle to Refuse Energy Systems Co., 100 Salem Turnpike,
Saugus, MA 01906, for incineration.
7.	A total of 230 pounds of wastes were sent for incineration in
one trip, on 4/22/76. No wastes are in storage.
A-31

-------
8.	No tests were done.
9.	We have no other data relating to 2,3,7,8-TCDD.
Please let me know if you have any further questions on this
matter.
Sincerelv, -v ,4 .
tawrence W. Bierlein
Counsel to Carroll Products, Inc.
A-32

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APPENDIX B
SAMPLE LOCATION PLANS

-------
TREATMENT
PLANT
CONTROL
BUILDING
ft &
ROW OF PINES
BL06
oo
oo
AOMIN.
BLD6.
OO
FIGURE B-1
SAMPLE DA000301 LOCATION
SEWAGE TREATMENT PLANT
PITTSFELD, MA
NATIONAL DIOXIN STUDY
	ECJQRDANCQ

-------
\ f
uV

1 \
Stl' 2"^
HOUSE
NO.
I98

BRICK
APARTMENT
BUILDING
UNION	STREET
V)
o
z
<
X
FIGURE B-2
SAMPLE DA000302 LOCATION
198 UNION ST.
PITTSFELD, MA
NATIONAL DIOXIN STUDY
	— EC JORDAN CO

-------
$
CO
z
z
o
I
c
\ HILL BROOK
^RESERVOIR
ROAD

#•-22' z"
6" BIRCH
©
COUNTY LINE MONUMENT
A (=300' below sample location)
FIGURE B-3
SAMPLE DA000303 LOCATION
SYKES MOUNTAIN RD.
PITTSFIELD, MA
NATIONAL DIOXIN STUDY
	EC. JORDAN CO
B-3

-------
PITTSFIELD STATE PARK

x *
TILDEN SWAMP —
M.	iU
50'
.1.
BERRY POND
NOT TO SCALE
B-4
FIGURE B-4
SAMPLE DA000304 LOCATION
BERRY POND ORCUIT RD.
PITTSFELD, MA
NATIONAL DIOXIN STUDY
	EC JORDAN CQ

-------
a
<
o
or
_i
_i
£
a:
LJ
s
APARTMENT
HOUSE
NO. 255-257
GARAGE
13*
CHERRY
POOL
FIGURE B-5
SAMPLE DA0CX)305 LOCATION
255-257 MERRLL RD.
PITTSFELD, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
	EC JORDAN CQ
B-5

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Ill
U1
(K
H

4" 9" FROM CENTER
® OF STUMP
b,
4 STUMP
HOUSE
NO. 53
NOT TO SCALE
B-6
FIGURE B-6
SAMPLE DA000306 LOCATION
53 YARMOUTH ST.
PfTTSFELD, MA
NATIONAL DIOXIN STUDY
	EC JORDAN CQ

-------
•TELEPHONE POLE NO. 207
©
l&J
D
Z
Ui
§
MAPLE
42'2'
17' 10'
12 MAPLE
HOUSE
NO. 44
K
Ui
X
UJ
Q
FIGURE B-7
SAMPLE DA000307 LOCATION
44 DEXTER AVE.
PITTSFIELD, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
	—	EC JORDAN CQ

-------
0
H
Ui
UJ
QC
H
CO
CHAIN LINK FENCE
7.3"
®	7.5-
HOUSE
NO 57
HOUSE
NO. 86
x
z
<
m
cr
3
CO
• TELEPHONE POLE NO. 39
WINTER
STREET
FIGURE B-8
SAMPLE DA000308 LOCATION
57 WINTER ST.
DALTON, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
	—	— EC JORDAN CO
B-8

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HOUSE
TELEPHONE POLE NO. 16
HEAVILY WOODED
AREA
TELEPHONE POLE NO. 17
HOUSE
FIGURE B-9
SAMPLE DA000309 LOCATION
SWAMP RD.
LANESBOROUGH, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
	EC JORDAN CO
B-9

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©
DRIVEWAY
BUSH
8 BEECH
UJ
uj
a.
H

-------
24" POPLAR
24" POPLAR
BRUSH
PUBLIC
WORKS
DEPT.
o
<
o
cc
to
o
z
z
Hi
-3
HARTFORD
POLICE
DEPT
FIGURE B-11
SAMPLE DA000402 LOCATION
JENNINGS RO.
HARTFORD, CT
NOT TO SCALE	NATIONAL DIOXIN STUDY
	—	EC JORDAN CQ •

-------
©
Ui
a.

HARTFORD COUNTY COURTHOUSE
PARKING LOT
z
P
CO
z
X
tn
<
r
<
9
ui
o
V)
¦ 17"-
¦ 14' 2"-
13'll"
6.
10 MAPLE

MAPLE
0
FLAGPOLE
FIGURE B-12
SAMPLE DA000403 LOCATION
WASHINGTON ST.
HARTFORD, CT
NOT TO SCALE	NATIONAL DIOXIN STUDY
	—	EC JORDAN CO

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• TELEPHONE POLE NO. 98S
FIGURE B-13
SAMPLE DA000404 LOCATION
COPPER HILL RD.
HARTFORD, CT
NATIONAL DIOXIN STUDY
	EG JORDAN CO
4 STUMP
BARN
SHED
HOUSE NO. 424
B-13

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DEAD OAK
3" WHITE PINE
12" MAPLE
ROAD
PIPELINE
FIGURE B-14
SAMPLE DA000405 LOCATION
RUSSELL RD.
EAST GRANBY, CT
NATIONAL DIOXIN STUDY
	— EC JORDAN CQ

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©
DRIVEWAY
TELEPHONE POLE NO. S47
iz" apple£\

A'
y
s
12 MAPLE
HOUSE
a
<
o
o:
-I
z
o
z
o
-I
NOT TO SCALE
FIGURE B-15
SAMPLE DA000406 LOCATION
LONGHILL RD.
ANDOVER, CT
NATIONAL DIOXIN STUDY
	EC JORDAN CQ
B-15

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©
TELEPHONE POLE HO. I8T9
2' BIRCH
o
10'2"
6
2' MAPLE
O
<
o
IE
Z
o
4
H
O
>
<
z
BRICK
HOUSE
• TELEPHONE POLE NO. 3626
WHITE
WOOD
HOUSE
FIGURE B-16
SAMPLE DA000407 LOCATION
HAYDEN STATION RD.
WINDSOR, CT
NOT TO SCALE	NATIONAL DIOXIN STUDY
	——	EC JORDAN CO
B-l-6

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50*
KAMAN
AIRCRAFT

*
z
J
4
X
°
-X—*—X—
TELEPHONE POLE NO. 1802
OLD
POQUNOCK
ROAD
a
<
o
a.
>
ce

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	25' 10"	1
(FROM 6UAR0RAIL)
FIGURE B-18
SAMPLE DA000501 LOCATION
ROUTE 2A
LUNENBURG, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
			EC JORDAN CO
B-18

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CABIN
STONE	WALL
Ooccoooeooocoqaqpowjuu,
k;~
5-
2' PINE
O

-------
POND
SHELDON
AREA
BEACH
BS'
2' PINE
2' PINE
O
N
i
FIGURE B-20
SAMPLE DA000503 LOCATION
112 SHELDON RD.
FITCHBURG, MA
NOT TO SCALE	NATIONAL DIOXIN STUOY
	EC JORDAN CO
B-20

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UJ
CO
CO
tD
Ui
O
o
I
a:
z
UJ
Ui
Q.
Ui

ir


-------
SOUTH	STREET
HOUSE
0
0
0
0
0
©
FIGURE B-22
SAMPLE DA000505 LOCATION
SOUTH ST.
FITCHBURG, MA
NOT TO SCALE	NATIONAL DIOXIN STUDY
		EC JORDAN CO
B-22
CEMETERY
¦ 62'-
• 56'-
9"
"N3
OAK TREE (3')
BUILDING

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84" WILLOW
0
(E
h-
HOUSE
NO. 29
«f MAPLE
-33-9"
J&
24 WILLOW
11-10"
Ui
Z
>
0
30 WILLOW
NOT TO SCALE
FIGURE B-23
SAMPLE DA000506 LOCATION
29 VINE ST.
FITCHBURG, MA
NATIONAL DIOXIN STUDY
	EC JORDAN CQ
B-23

-------
PAGE NOT
AVAILABLE
DIGITALLY

-------
ASH STREET	TO KINSLEY ST
STONE WALL
axmxccQscoooooaraco^^
•02
STONE STEPS-
I
CO
oo
m.
mi
-STONE STEPS
08«
©

ORIGINAL

VAT AREA

WOOD J \

FLOOR I J
03,09
WOODEN STAIRS^*
~r
|
E
04#
I 0SINK
LOADING DOCK-i-
05*
07# 06*-
I
j CONCRETE FLOOR
	CURRENT

/ \ VAT AREA
L/
STORAGE AREA ADDED
TO ORIGINAL BUILDING
BLOCK PART OF

BUILDING ADDED

•01
NO
SCALE
NOTE: SEE FOLLOWING PAGE FOR SAMPLE
LOCATION DETAILS
FIGURE B-28
SAMPLES DAO01301 -DAO01309
NATIONAL DIOXIN STUDY
SAMPLE LOCATION PLAN
J. HUBBARD, INC.
NASHUA, N.H.
	EC. JORDAN CQ

-------
J. HUBBARD, INC.
SAMPLE LOCATION DESCRIPTIONS
SAMPLE NO.
LOCATION
DA001301
DA001302
DA001303
DA001304
DA001305
DA001306
DA001307
DA001308
DA001309
2 feet from building foundation
33.5 feet from east (Ash Street) corner
of building
5.7 feet from stone wall
2.7 feet from northeast steps
3.7 feet from southeast steps
2.5 feet from building foundation
1.4	feet from cement at bottom of steps
1.0 foot from building foundation
20.2	feet from block building
1.5	feet from dock
14.7 feet from block building
1.0 foot from dock
9.2 feet from block building
4.0 feet from block building foundation
15.3	feet from corner where block building,
storage area, and original building meet
2.5 feet from block building foundation
13.3 feet from west corner of block building
2.5 feet from building foundation
1.4 feet from cement at bottom of steps
B-28a

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PROPERTY LINE
LOADING DOCK
NOTE: SEE FOLLOWING PAGE FOR SAMPLE
LOCATION DETAILS.
f
LA0OON
•12,17
WIRE FENCE
FIGURE B-29
SAMPLES DAO01401 -DAOO1423
NATIONAL DIOXIN STUDY
SAMPLE LOCATION PLAN
CARROLL PRODUCTS
WOOD RIVER JCT., R.I.
	E.C. JORDAN CO.

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CARROLL PRODUCTS
SAMPLE LOCATION DESCRIPTIONS
SAMPLE NO.
DA001401
LOCATION
0.8 foot in front of loading dock
4.5 feet from east end of dock
29.6 feet from west end of dock
DA001402, 03
0.8 foot in front of loading dock
16.4 feet from east end of dock
17 feet from west end of dock
DA001404
1.6 feet in front of loading dock
13.3 feet from north corner of Building 2
DA001405
Located approximately as shown in old
well lagoon area
DA001406
2.7 feet in front of loading dock
6.5 feet from east end of dock
DA001407
2.6 feet in front of loading dock
6.4 feet from east end of dock
DA001408-23
Locations approximately as shown on
preceeding page
B-29a

-------