502043

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY _ REGION I SiraquorrfHnd Records renter

^r f- t^^^rlt^ TJltilaquo-Vt-

IN THE MATTER OF OTHER

Cannons Engineering Corporation US EPA Docket No Superfund Site 1-88-1020 First Street Bridgewater Massachusetts

PROCEEDINGS UNDER SECTION 106(a) OF THE COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION AND LIABILITY ACT OF 1980 42 USC SEC 9606(a)

ADMINISTRATIVE ORDER BY CONSENT

I JURISDICTION

1 This Administrative Order by Consent (Consent Order) is

entered into voluntarily by and between the United States

Environmental Protection Agency (EPA) and Acushnet Company American

Cyanamid Company American National Can Corporation ATampT

Technologies Inc (Western Electric) Bostik Division of Emhart

Industries Inc Chamerlain Manufacturing Corporation Ciba-Geigy

Corporation Earthline Company (SCA Group) Fairchild Semiconductor

Corporation Franklin Pumping Service Inc General Dynamics

Corporation General Electric Company Hoechst Celanese Corporation

Hoffmann-La Roche Inc ICI Americas Inc (Beatrice Group) Interex

Corporation Millipore Corporation Monsanto Company Pfizer Inc

Polaroid Corporation Recycling Industries Inc and Tech Etch Inc

(hereinafter the Respondents) The Consent Order concerns the

SDMS DocID 259602

performance of a certain removal action at a Superfjnd Site formerly

operated by the Cannons Engineering Corporation (CEC) in Bridgewater

Massachusetts (the Site)

This Consent Order is issued pursuant to the authority vested in

the President of the United States by Section 106(a) of the

Comprehensive Environmental Response Compensation and Liability Act

of 1980 (CERCLA) 42 USC $ 9606(A) as amended and delegated to

the Regional Administrator EPA Region I by EPA delegation No 14-14

A signed en April 16 1984 Without admitting liability or the

accuracy of any factual allegations or determinations set forth

nerein Respondents agree to undertake all actions required by the

terrs cf this Consert Order Moreover Respondents agree and submit

to the jurisdiction asserted in this Consent Order for the purpose of

any subcerruort proc--virgs for the implementation or enforcement of

this Censer Order J-G furtrer agree not to contest this jurisdiction

n such prcceedires

II PARTIES BOUND

2 This Consent Order shall apply to and be binding upcn the

following parties

a The United States Environmental Protection Agency and

b Each Respondent its agents employees representatives

contractors consultants successors and assigns

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performance of a certain removal action at a Superfjnd Site formerly

operated by the Cannons Engineering Corporation (CEC) in Bridgewater

Massachusetts (the Site)

This Consent Order is issued pursuant to the authority vested in

the President of the United States by Section 106(a) of the

Comprehensive Environmental Response Compensation and Liability Act

of 1980 (CERCLA) 42 USC $ 9606(A) as amended and delegated to

the Regional Administrator EPA Region I by EPA delegation No 14-14

A signed en April 16 1984 Without admitting liability or the

accuracy of any factual allegations or determinations set forth

nerein Respondents agree to undertake all actions required by the

terrs cf this Consert Order Moreover Respondents agree and submit

to the jurisdiction asserted in this Consent Order for the purpose of

any subcerruort proc--virgs for the implementation or enforcement of

this Censer Order J-G furtrer agree not to contest this jurisdiction

n such prcceedires

II PARTIES BOUND

2 This Consent Order shall apply to and be binding upcn the

following parties

a The United States Environmental Protection Agency and

b Each Respondent its agents employees representatives

contractors consultants successors and assigns

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3 Any change or changes in the ownership or corporate status

of a Respondent shall in no way alter that Respondents

responsibilities under this Consent Order Each Respondent shall

provide a copy of this Consent Order to any subsequent owners or

successors

4 Respondents shall provide a copy of this Consent Order to

all contractors subcontractors laboratories and consultants

retained to conduct any portion of the work performed pursuant to

this Ccnsent Order within seven (7) days of the effective date of

this Consent Order or the date of such retention Any reference

rerein to the Consent Order shall mean the Consent Order and the Work

Plan annexed hereto as Attachment A as either nay be gt rerced from

me t z me hereafter

STATEMENT OF PURPOSE

5 In enter irs -_ o this Consent Order the mutual cbjectives

UFA -rd Pespcrcc--bull ire bull re removal of the hazarcru^ uostances

pollutants or centum i-t5 from the Bridgewater Massachusetts site

and the prevention cr mitigation of the migration off-site or the

release of hazardous substances pollutants or contaminants from the

site in accordance with Attachment A The activities conducted

pursuant to this Consent Order are subject to approval by EPA and

shall be performed consistent with the National Oil and Hazardous

Materials Contingency Plan (NCP) 40 CFR Part 300 50 Fed Reg

47912 (November 20 1985) effective February 18 1986

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IV STATEMENT OF FACTS

6 The Cannons Engineering Corporation Bridgewater Site

consists of approximately 4 acres of land located in the Bridgewater

Industrial Park in the western part of the Town of Bridgewater

Plymouth County Massachusetts The site is bordered to the north

and south by lots owned by the Bridgewater Industrial Park Inc to

the west by Route 24 and to the east by First Street

7 The site consists of the following facilities the Tank

Farm Building containing 11 tanks with total storage capacity of

approximately 165000 gallons the Ready Building (used to store the

waste before processing in the incinerator) containing four tanks

with a total storace capacity of approximately 50000 gallons the

IrcirTatcr Buildirc arc adjacent fuel tank the Equipment Building

corainirg the CIC ljocrjtraquory and other facilities two box trailers

contain ira Anchor 7anlt Lir ira Inc materials three tankers two of

wnicr contain waste iquics an office trailer five grouped 30000

sailzr outdoor above- -rc--d inks underground storage tar-s arc a

septc system an urcc crounc storm drain system and an underground

drainage sump and otrer above ground debris

8 CEC purchased the property in 1974 During the period from

1974 to 1980 CEC constructed and operated the facility to handle

store and incinerate chemical wastes In 1978 and 1979 CEC applied

for and received a license from the Massachusetts Department of

Environmental Quality Engineering (DEQE) to operate a Hazardous Waste

Collection and Disposal Facility In June 1980 CECs 1979 hazardous

waste license was revoked by the Massachusetts Executive Office of

Environmental Affairs for hazardous waste reporting violations

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Following revocation of CECs license the court appointed a Special

Receiver to oversee the operations at the facility Because of

financial and legal difficulties CEC was unable to continue

incinerating the remaining chemical wastes stored on site On

November 28 1980 CEC stopped all operations at the site

9 An EPA investigation at the site in July 1987 found Picric

Acid and Sodium Azide present on the site Both are shock sensitive

materials and presented an explosion hazard

10 laboratory reagerts stored in bottles on shelves inside the

laboratory inside the Equipment Building include toxic substances

(carbon tetrachlorce) acids (nitric acid) oxidizers (sodium

perci-lcrate) cyanide ccrpc-rds (sodium cyanide) and f lamables

(toljcnc) Waste carpl es -ere also stored inside the laboratory

11 Anchor TarK Lrir- irc brought and left en site two box

trailers c-rcairirg r rcirecs five (illon containers cf abandoned

parts pa- remove ^ arc ctrer tank lining material These

joa-dzro-J -aterial- lt TO Ancrraquor Tank materials) were c eked in the

trailers ra precarizjs rarrer Some containers had filler to the

floor spilling their contents while others showed signs cf

deterioration and lcalaquoage

12 Also on site are several underground tanks containing waste

materials and above ground tankers also containing waste materials

13 Based on the results of his investigations on July 16

1987 EPAs On-Scene Coordinator recommended authorization of a

removal action and on this date the Regional Administrator approved

$74745700 dollars to perform the removal action On July 29 1987

site security was established by the presence of a 24 hour guard at

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IV STATEMENT OF FACTS

6 The Cannons Engineering Corporation Bridgewater Site

consists of approximately 4 acres of land located in the Bridgewater

Industrial Park in the western part of the Town of Bridgewater

Plymouth County Massachusetts The site is bordered to the north

and south by lots owned by the Bridgewater Industrial Park Inc to

the west by Route 24 and to the east by First Street

7 The site consists of the following facilities the Tank

Farm Building containing 11 tanks with total storage capacity of

approximately 165000 gallons the Ready Building (used to store the

waste before processing in the incinerator) containing four tanks

with a total storace capacity of approximately 50000 gallons the

IrcirTatcr Buildirc arc adjacent fuel tank the Equipment Building

corainirg the CIC ljocrjtraquory and other facilities two box trailers

contain ira Anchor 7anlt Lir ira Inc materials three tankers two of

wnicr contain waste iquics an office trailer five grouped 30000

sailzr outdoor above- -rc--d inks underground storage tar-s arc a

septc system an urcc crounc storm drain system and an underground

drainage sump and otrer above ground debris

8 CEC purchased the property in 1974 During the period from

1974 to 1980 CEC constructed and operated the facility to handle

store and incinerate chemical wastes In 1978 and 1979 CEC applied

for and received a license from the Massachusetts Department of

Environmental Quality Engineering (DEQE) to operate a Hazardous Waste

Collection and Disposal Facility In June 1980 CECs 1979 hazardous

waste license was revoked by the Massachusetts Executive Office of

Environmental Affairs for hazardous waste reporting violations

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Following revocation of CECs license the court appointed a Special

Receiver to oversee the operations at the facility Because of

financial and legal difficulties CEC was unable to continue

incinerating the remaining chemical wastes stored on site On

November 28 1980 CEC stopped all operations at the site

9 An EPA investigation at the site in July 1987 found Picric

Acid and Sodium Azide present on the site Both are shock sensitive

materials and presented an explosion hazard

10 laboratory reagerts stored in bottles on shelves inside the

laboratory inside the Equipment Building include toxic substances

(carbon tetrachlorce) acids (nitric acid) oxidizers (sodium

perci-lcrate) cyanide ccrpc-rds (sodium cyanide) and f lamables

(toljcnc) Waste carpl es -ere also stored inside the laboratory

11 Anchor TarK Lrir- irc brought and left en site two box

trailers c-rcairirg r rcirecs five (illon containers cf abandoned

parts pa- remove ^ arc ctrer tank lining material These

joa-dzro-J -aterial- lt TO Ancrraquor Tank materials) were c eked in the

trailers ra precarizjs rarrer Some containers had filler to the

floor spilling their contents while others showed signs cf

deterioration and lcalaquoage

12 Also on site are several underground tanks containing waste

materials and above ground tankers also containing waste materials

13 Based on the results of his investigations on July 16

1987 EPAs On-Scene Coordinator recommended authorization of a

removal action and on this date the Regional Administrator approved

$74745700 dollars to perform the removal action On July 29 1987

site security was established by the presence of a 24 hour guard at

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Following revocation of CECs license the court appointed a Special

Receiver to oversee the operations at the facility Because of

financial and legal difficulties CEC was unable to continue

incinerating the remaining chemical wastes stored on site On

November 28 1980 CEC stopped all operations at the site

9 An EPA investigation at the site in July 1987 found Picric

Acid and Sodium Azide present on the site Both are shock sensitive

materials and presented an explosion hazard

10 laboratory reagerts stored in bottles on shelves inside the

laboratory inside the Equipment Building include toxic substances

(carbon tetrachlorce) acids (nitric acid) oxidizers (sodium

perci-lcrate) cyanide ccrpc-rds (sodium cyanide) and f lamables

(toljcnc) Waste carpl es -ere also stored inside the laboratory

11 Anchor TarK Lrir- irc brought and left en site two box

trailers c-rcairirg r rcirecs five (illon containers cf abandoned

parts pa- remove ^ arc ctrer tank lining material These

joa-dzro-J -aterial- lt TO Ancrraquor Tank materials) were c eked in the

trailers ra precarizjs rarrer Some containers had filler to the

floor spilling their contents while others showed signs cf

deterioration and lcalaquoage

12 Also on site are several underground tanks containing waste

materials and above ground tankers also containing waste materials

13 Based on the results of his investigations on July 16

1987 EPAs On-Scene Coordinator recommended authorization of a

removal action and on this date the Regional Administrator approved

$74745700 dollars to perform the removal action On July 29 1987

site security was established by the presence of a 24 hour guard at

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the site During August a response manager and chemist under

contract with EPA arrived en site The shock sensitive materials

were desensitized and removed from the site The EPA contractors

assembled a decontamination area cleared the equipment building of

miscellaneous debris compacted together small containers into two 55

gallon drums and collected various containers and lab samples The

containers in the Ancnor tank trailer were removed to the Equipment

building opened and screened for compatibility

V ENDANGERMENT

14 A hazard exists at the site due to the presence of

chemicals abandoned in the laboratory A threat of reaction and

release s presented ry =torpoundge in the laboratory of non-compatible

rjrpfjrj ojch as acJ= gticizers cyanide ccrrpc-rcs and fllaquorrables

n close proximity The storage in structurally deteriorating

containers of Anchor an- Linings waste materials also creates a

-rreat f fire and r-lc-are An additional threat of release arises

from the sbardcrmont - s~e cf other liquid wastes and waste

materials

VI DETERMINATIONS

15 On the basis of the findings of fact and reports cited

therein EPA has determined that

a Each Respondent is a person within the meaning of

Section 101(21) of CERCLA 42 USC 9601(21)

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b Each Respondent is a potentially responsible party with

respect to some response costs incurred in connection with the site

within the meaning of Section 107(a) of CERCLA as amended 42 USC

$9607

c Many of the chemicals found on the site are hazardous

substances within the meaning of Section 101(14) of CERCLA 42

USC 9601(14)

d The past present or potential future migration of

hazardous substances it or from the Site constitutes an actual or

substantial threat of a release into the environment as those

terns are defined in Sections 101(8) and 101(22) of CERCLA as

amended

e The actu-1 releases cr threatened releases of a

naz-ror- -ubstsnco frrT the cite nay be an irmirer and substantial

encirscrrent to the rue-lie rc-alth or welfare cr the environment

w i t h i n -he rearing f 106(c) of CERCLA 42 USC sect 960G(a)

It is -c--ssary in order to protect the -ublic health

r welfare or the env rorncnt that actions be taken to abate such

cancers and threats that ray be caused by actual or threatened

release of hazardous substances from the Site For the purpose of

this Consent Order only such actions consist of the removal

activities described in the Work Plan set forth in Attachment A

hereto

g Respondents by undertaking the work activities pursuant

to this Consent Order and Attachment A will not have owned cr

possessed the Anchor Tank materials within the meaning of Section

107(a)(3) of CERLCLA as amended accordingly Respondents are not

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responsible parties within the meaning of Section 107 of CERCLA

with respect to the Anchor Tank materials and any response costs

which have been or may hereafter be incurred in connection with said

materials at any disposal or treatment facility to which Respondents

deliver said materials pursuant to this Consent Order s

VII ORDER

16 EPA hereby orders and agrees and Respondents without

admission of any issue of fact or law and in accordance with

Respondents Reservation of Rights as provided in paragraph 43

heresy agree that Respondents shall perform the activities set

forth in Attachment A These activities shall be conducted

pursuit o this Consent Or-Jer and shall be consistent with

CERCLA pound ar-erdec ry SARA ard the XCP If any inconsistencies

between ary cf the uocve laws cr regulations CERCLA as amended

shall 73VCTT Resp bull Jer-rG ncrce that they will conduct all

jct~s cescribec h s Ccnreit Order properly and accc rdirCj to

its terns ad the screcjlcs ^et forth herein

17 EPA Over siST1 It is hereby further ordered and

Respondents further agree that the Respondents shall reimburse the

Hazardous Substances Superfund for any cost consistent with CERCLA

and the NCP incurred by EPA including analytic cost under or in

connection with a contract or arrangement between EPA and a

qualified person to assist EPA in overseeing and reviewing the work

activities set forth in Attachment A to be performed by_ Respondents

provided however that Respondents shall not be obliltited pursuant

to this consent order to reimburse EPA for such rversight coss in

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excess cf S [to be 15 of bid price for the removal work excluding

activities in connection with the Anchor Tank materials] cr fifteen

percent (15) of Respondents costs incurred in the performance of

the removal activities unrelated to the Anchor Tank Materials

whichever is greater EPA agrees to notify Respondents of its

intention to enlarge or materially change the scope andor costs of

EPAs planned oversight activities and to provide Respondents with an

opportunity to discuss with EPA any such changes At the conclusion

cf the activities to be conducted under this Order ZPA will submit

to Respondents an accc-rtirc cf all oversight costs incurred by the

US government with respect to this Consent Order Subject to the

dispute resolution prcvisicn as provided in paragraph 30 herein

espc-dc-- shall bull-bull-r n 20 calendar days of receipt of that

jcc-nt bull= remit ^ co t ic-j c eck for the amount of those costs

-ade ray-cle to the bullbullbullJr~z r-bstance Superfunu Checks shall

pecif itally ref erc-nco bull ne identity of tie Site and be addressed to

US r-v r-crtul Protection Agency Hazardous S-ostances Supcrfurd PO Box 2710C3 V Pittsburg- PA 15251

A copy cf the transmittal letter shall be provided to the EPA Project

Coordinator

18 Observation of Respondents Field Activities Subject to

Respondents right to access to the Site as provided in paragraph 21

herein Respondents shall allow EPAs Project Coordinator and other

EPA employees agents consultants contractors and authorized

representatives to enter and move about the Site at allreasonable

times including but not limited to any time that work is being

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excess cf S [to be 15 of bid price for the removal work excluding

activities in connection with the Anchor Tank materials] cr fifteen

percent (15) of Respondents costs incurred in the performance of

the removal activities unrelated to the Anchor Tank Materials

whichever is greater EPA agrees to notify Respondents of its

intention to enlarge or materially change the scope andor costs of

EPAs planned oversight activities and to provide Respondents with an

opportunity to discuss with EPA any such changes At the conclusion

cf the activities to be conducted under this Order ZPA will submit

to Respondents an accc-rtirc cf all oversight costs incurred by the

US government with respect to this Consent Order Subject to the

dispute resolution prcvisicn as provided in paragraph 30 herein

espc-dc-- shall bull-bull-r n 20 calendar days of receipt of that

jcc-nt bull= remit ^ co t ic-j c eck for the amount of those costs

-ade ray-cle to the bullbullbullJr~z r-bstance Superfunu Checks shall

pecif itally ref erc-nco bull ne identity of tie Site and be addressed to

US r-v r-crtul Protection Agency Hazardous S-ostances Supcrfurd PO Box 2710C3 V Pittsburg- PA 15251

A copy cf the transmittal letter shall be provided to the EPA Project

Coordinator

18 Observation of Respondents Field Activities Subject to

Respondents right to access to the Site as provided in paragraph 21

herein Respondents shall allow EPAs Project Coordinator and other

EPA employees agents consultants contractors and authorized

representatives to enter and move about the Site at allreasonable

times including but not limited to any time that work is being

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carried out pursuant to this Consent Order for the purpose of

inspecting and observing progress in implementing the activities

pursuant to this Concent Order and for the purpose cf verifying the

data submitted to EPA Respondents shall permit such persons to

record ail field activities by means of photographic or other

recording equipment and to inspect and copy all records documents

and other writings which in any way pertain to work undertaken

pursuant to this Consent Order

19 Engagement cf a Response Action Contractor Within seven

(7) cays of the effective date of this Consent Order Respondents

shall engage a qualified and experienced Response Action Contractor

(Contractor) to perform the removal activities set forth in the

Sccce cf Acr (Attac--r-rt A) All work performed by said Contractor

pur-_jrt bull this Ccrj bullbullbull-_ Orcic- shall be under the general direction

and cpervision of a bull_ lificc professional with expertise in

raz^rdc-js waste site -vest ijjtion and clean-up The contractual

lt=G- -r-ert etween bull-bullc-J-ib ^nd the Contractor shall require the

Ccr-ractcr as a cere it r- successful performance of the contract

to perform the Work Activities consistent with the provisions cf this

Consent Order Written notice of the engagement of the Contractor

shall be provided to EPA within five (5) days of such engagement and

a copy of the Respondents contract with the Contractor including a

statement of qualifications and identification of project personnel

shall be provided to EPA at that time Respondents shall notify EPA

regarding the identity and qualifications of any additioial

subcontractors and their key personnel at least fcurteen (14) days

prior to the Subcontractors commencement of Site work EPA shall

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have the right to disapprove based upon professional qualification

any Contractor or person engaged by Respondents to conduct Activities

under this Consent Order

20 Designation of Project Coordinator Seven (7) days after

the effective date of this Consent Order EPA and Respondents shall

each designate their own respective Project Coordinator Each

Project Coordinator shall be responsible for overseeing the

implementation of this Consent Order Any permanent change in the

designated Project Coordinator of either EPA or Respondents shall be

accomplished by sendiro written notice to either party The absence

of the EPA Project Coordinator from the Site shall not be the cause

for the stoppage of worlt unless the EPA Project Coordinator specifies

wcrlt o be jcccrpiiir--i inly when he or she is present

21 Site Accr- To -he extent that this Consent Order

requrr-- access to p~rerty ether than that already owned by the

esc-Jc-t j the Peso- ientc shall use their best efforts to obtain

ste jccoiis agreeron - rrcrr -he owners cf the Site ard any other

property wnich is ncccr-ry to successfully perform the activities

described ir this Consent Order within ten (10) cays after the

execution of this Consent Order by all parties Such agreements

shall provide to EPA its designated coordinator and its agents

employees authorized representatives and contractors reasonable

access to the Site for the purpose of overseeing Respondents

implementation of this Consent Order In the event that Respondents

conclude they are unable to obtain a necessary site access agreement

within the referenced time Respondents shall immediately notify EPA

in writing and shall include in such notification a description of

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che efforts made by Respondents to obtain the necessary access and

the reasons for their inability to obtain such access A delay in

performance of the Removal Activities which results from the

inability to secure such site access shall constitute an excusable

delay for the purposes of paragraph 32 if the cause of such inability

is not within the control of Respondents

22 Creation of Danger Upon obtaining information concerning

the occurrence of any event during the Removal Activities that causes

or threatens a release of hazardous substances from the Site or that

threatens public health welfare or the environment Respondents

snail notify within twenty-four (24) hours the EPA Project

Coordinator or in the event of his or her unavailability shall

notify wthin the sarro -werty-f cur (24) hour period the Ererccncy

Sest-orDe rit 3egr United States Environmental Protection

Agency -etting forth bull re events that occurred and the measures taken

and 10 bo -^ken if appr - pr e to mitigate any harrr caused or

nreat-bullo-j by the event raquo-d to prevent the reoccurrence cf such an

event Respondents crall have no obligations under this Order to

jndertake reasures to rritigate any such event not related to their

performance of the Removal Activities Regardless of whether or not

such a report is made to EPA if EPA determines that activities

undertaken in connection with this Consent Order have caused or may

cause a threat to on-site personnel or to the public health or

welfare or to the environment EPA may (a) order Respondents to stop

further implementation of this Consent Order for such period of time

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as may be needed to abate any such release or threat anderr (b)

undertake any actions which EPA determines are necessary to abate

such threat

23 Availability of Data Respondents shall submit to EPA the

results of all sampling andor tests and all other data generated by

Respondents by the Contractor or on Respondents behalf in the

course of implementing this Consent Order in its Progress Reports or

other Reports as described in the Work Plan or in this Consent Order

24 Record Preservation Respondents shall preserve during

tre pendency of this Consent Order and for a period of net less than

six (6) years after ecrrpletirg the work required by this Consent

Order all records arc icc--erts in their possession cr in the

c jsres rr f their ccucrse Action Contractor which relate in any

-ay z -bullbullgt --rfcrrar -ltbull i-e vork Plan cr this Consent Crccr

rotw irct-rcirg any cc-rc-i retention policy to the contrary After

bull nis - bull bullbull= perirj Pospc- Jc-its nay request in writing perrrisjion

bull jeer_y -ry sucr bullbull-bullgtrcc r docurrcr^3 This requort shall be

accrc-rci by a eery iris Consent Order and shall be rent by

certified rail return receipt requested to the following address

Robert A DiBiccaro Acting Regional Counsel (or the current Regional Counsel) US Environmental Protection Agency JFK Federal Building Rm 2203 Boston Massachusetts 02203

Within sixty (60) days of receipt of a request by Respondents to

destroy any or all such records or documents EPA will notify

Respondents whether such request has been granted or denied If EPA

denies such request Respondents shall make available to EPA such

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records and documents or copies of any such records and documents and

all obligations of Respondents to preserve records pursuant to this

Consent Order shall cease EPAs failure to respond to Respondents

request within the time period specified herein shall be deemed an

approval of said request and all obligations of Respondents to

preserve records pursuant to this Consent Order shall cease

Notwithstanding the terms of this paragraph Respondents do not waive

their rights to assert any privileges which may be applicable to such

records and documents

25 Place and Varrer of Notice Communications between

Respondents and EPA and all documents including reports approvals

disapprovals written rctices and other correspondence to be

suomitted- pursuant - rris Ccrsent Order shall be sent by certified

raI return receipt bull queste-J or by courier to the Project

Coordinator at the ll_wirg address or such other addresses as

Respcrde-gt13 cr EPA gtro-fttr ray designate in writing

a Docurc--j three ccpies) to be submitted to EPA should

oe cct to

Ricnard Haworth EPA On-Scene Coordinator US Environmental Protection Agency New England Regional Laboratory 60 Westview Street Lexington MA 02173

and one copy to

Wayne M Robinson EPA Remedial Project Manager US Environmental Protection Agency Waste Management Division JFK Federal Building HSN Boston MA 02203

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b Documents (three copies) to be submitted to Respondents

should be sent to

(name and addresses of Respondents contractors)

26 Necessity of Formal Approval No informal advice

guidance suggestions or commerts by EPA regarding reports plans

specifications schedules or any other writing submitted by

Respondents shall be construed as relieving Respondents of their

obligation to obtain such formal approvals as may be required by this

Consent Order

27 Procedure for Sbrssicn of Deliverables to EPA All

deiiveraoles identified in Attachment A for submittal to EPA shall be

so delivered to EPA in accordance with the Schedule set forth in the

Scope -f Work Prior -0 receipt of final EPA approval any report

bullbullJDTbullbullbullbull to EPA for ipprvl shall be rarked Draft on each page

arc jr-all include n a prc~irent location in the document the

follcwir- isciarcr Thib Document is a DRAFT which has not

recebullbullbullbull-bull iral EPA -ppr --I EPA will review Reports in accordance

wtn pa-rcpns 28 ne Consent Order

28 Procedure fr Review Revision and Fiial Approval of

Reports All deliverables identified in the Scope of Worn

(Attachment A) and this Consent Order for delivery to EPA (Reports)

shall be so delivered to EPA in accordance with the schedules set

forth in the Scope of Work and this Consent Order EPA will review

the Reports to determine whether they are consistent with the

requirements of the Scope of Work and Work Schedule and this Consent

Order If EPA determines that revisions to a Report are necessary

EPA will notify Respondents of EPAs requested revisions and the

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parties will expeditiously confer to discuss such requested

revisions Respondents shall thereafter submit a draft of the

revised Report in accordance with a schedule for revision set by EPA

which is reasonable considering the nature and extent of the proposed

revisions and the time period which was initially available for

Respondent to produce an acceptable report If Respondents fail to

submit such a revised Report within the specified schedule the

provisions of paragraph 30 may be invoked by any party to this

Consent Order

29 Xodificatinn ~pound Consent Order and Scooe of Wrrk This

Consent Order may only oe -edified upon the written agreement of both

EPA by signature cf Seniorsal Administrator and the Respondents

The jpprcvec ork l^r -ay to -edified by Respondents eriy upon

written crc-orent rT ~y tre signature of the Massachusetts

Section Chief and ltbullrdc-rt3 except that if CERCLA or the NCP are

ane~Jed prur to trlt bull-bullbullbullr t f c t ion of the Respondents worlt

a c t i v i t i e s is prcvij- 3 - paragraph 39 EPA nay request a

modi f icaticr to the -bullbull lax cr develop new Work Plans but only to

the extent expressly rec-jired pursuant to said amencrents of CERCLA

or the NCP Respondents assent to such a request for modification

shall not be unreasonably withheld

30 Dispute Resolution If the Respondents object to any EPA

notice of disapproval or decision made pursuant to this Consent

Order the Respondents shall notify EPA in writing of its objections

within ten (10) days of receipt of the decision EPA and the

Respondents have seven (7) days from the receipt by EPA-of the

notification of objection to reach agreement If agreement cannot be

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parties will expeditiously confer to discuss such requested

revisions Respondents shall thereafter submit a draft of the

revised Report in accordance with a schedule for revision set by EPA

which is reasonable considering the nature and extent of the proposed

revisions and the time period which was initially available for

Respondent to produce an acceptable report If Respondents fail to

submit such a revised Report within the specified schedule the

provisions of paragraph 30 may be invoked by any party to this

Consent Order

29 Xodificatinn ~pound Consent Order and Scooe of Wrrk This

Consent Order may only oe -edified upon the written agreement of both

EPA by signature cf Seniorsal Administrator and the Respondents

The jpprcvec ork l^r -ay to -edified by Respondents eriy upon

written crc-orent rT ~y tre signature of the Massachusetts

Section Chief and ltbullrdc-rt3 except that if CERCLA or the NCP are

ane~Jed prur to trlt bull-bullbullbullr t f c t ion of the Respondents worlt

a c t i v i t i e s is prcvij- 3 - paragraph 39 EPA nay request a

modi f icaticr to the -bullbull lax cr develop new Work Plans but only to

the extent expressly rec-jired pursuant to said amencrents of CERCLA

or the NCP Respondents assent to such a request for modification

shall not be unreasonably withheld

30 Dispute Resolution If the Respondents object to any EPA

notice of disapproval or decision made pursuant to this Consent

Order the Respondents shall notify EPA in writing of its objections

within ten (10) days of receipt of the decision EPA and the

Respondents have seven (7) days from the receipt by EPA-of the

notification of objection to reach agreement If agreement cannot be

-16shy

reached on any issue within this seven (7) day period EPA shall

provide a written statement of its decision to the Respondents

Respondents shall commence implementation of the activities required

by the EPA decision within five (5) days of receipt of the decision

In the event that the Respondents do not implement the activities

required by the EPA dt-ision the EPA Regional Administrator may take

such civil enforcement action against Respondents as may be provided

by statutory or equitable authorities including but not limited to

the assessment of such civil penalties or damages as are authorized

oy Sections 106(b)(l) and 107 (c) (3) of CERCLA as amended

31 Delav in Perf^rmancStipulated Penalties For each day

that the Respondents fail to comply with any time deadline estashy

oiioned pursuant to TS Consent Order the Respondent shall pay the

jjrrs -ot rtn belcw _ -t_ted penalties

Per cf Fail rraquo ~- Ct-plv Penalty Per Dav

1st - 7th bull-- $ 2500 8th - 15th y lOOOGi eacr ~ay th--r- -rr 400000

Any pound-cn -enalty sn^ll lt Jj- and payable within ten ilO) cays cf the

receipt cf a written demand by EPA Payment of any such penalty

shall be made by certified crecK payable to the Hazardous Substances

Superfund and mailed to the following address with a notation of the

docket number of this Consent Order

US Environmental Protection Agency Hazardous Substance Superfund P 0 Box 371003 M Pittsburgh PA 15251

-17shy

Notice that such payment has been made shall be provided in writing

to the EPA Project Coordinator The stipulated penalties set forth

in this section do not preclude EPA from electing to pursue any other

remedies or sanctions which may be available to EPA by reason of the

Respondents violation of this Consent Order or the Respondents1

failure or refusal to comply with any of the requirements of this

Order except that EPA agrees that all civil penalties for failure to

comply with the time requirements established pursuant to this

Consent Order shall be limited to the amounts calculated under this

paragraph If Resporccrtr pay stipulated penalties for a specified

period of time for late ccrpliance and EPA subsequently recovers

additional fines cr penalties for the same period of late compliance

r court the fines ard pe- 11 es shall be reduced by the arount of

tre 5tp l-iec peral c-s r~- -degr that period of late corrpliamprce

32 Excuses fr ~lpoundv~ n Perfornaree With respect to

Sespcrcc-tc corcpli -ce wit jny interim or final time deadline set

fcrtr - tris Consent ltpoundbullbull including any iTpierrentatior scnecjles

ccr cai eo in plans ^prvcJ Lv EPA pursuant to paragraph 28 and with

respect to the penalty provisions of paragraph 31 no stipulated

penalties or other sanctions will be imposed for delay directly

caused by the following which could not have been overcome by

Respondents due care (i) any act of God (ii) any Order issued to

Respondents by EPA under the provisions of paragraph 22 provided

that such delay did not arise as the result of the performance of the

Removal Activities (iii) any delay which results from failure to

secure access to the Site if the cause of such failure is not within

the control of Respondents (iv) any delays caused by EPAs failure

-18shy

to complete in a timely manner its review of plans and reports (v)

any delay experienced by the operation of the dispute resolution

procedure set forth herein and (vi) any other cause beyond the

control of Respondents provided however that increases in the cost

of performance of the removal activities shall not excuse such

performance nor affect the applicability of the penalty provisions

andor other sanctions which are provided for under this Order Such

penalties and sanctions shall be avoided only if and only to the

extcrt that such delays rratcrially interfered with or prevented

Respondents executor of their responsibilities during the period of

sucr delay Respondents shall notify EPA within twenty-four (24)

hours ir the event -hat circumstances occur which Respondents assert

snc-lu rccr the -xcu-e provisions cf this paragraph and shall

oert fy bullraquo vr spec y -bull cause or causes of such delay and the

estrat-jj J-jratior -cr Jc-liy Failure to notify EPA shall result

r - waivo Resp- j- -t right to assert that the delay should be

egtcbullbullbull L -ccr -he bullbullbullbull-- -ris paragraph Jpon receipt cf such

rot ic^i cr EPA wll -iotc-rTiie whether the delay is appropriately

exc-icd jrcer this parucraph and shall soon notify Respondents

Respondents further agree to use their best efforts to minimize any

delay which may result Respondents acknowledge that they will have

the burden of justifying excuses for delay in performance under this

paragraph

-19shy

33 Waiver of Settlement Conference In consideration of the

conununi cat ions between EPA and Respondents prior to the issuance of

this Consent Order concerning its terms Respondents hereby agree

that there is no need for a settlement conference prior to the

effective date of the Consent Order

34 Civil Penalties for Non-Compliance Respondents are

advised that except as provided by paragraph 32 of this Order if

Respondents violate or fail or refuse to comply with this Consent

Order or any portion tf-oreof EPA reserves its rights pursuant to

Sections 106(b)(l) and 107(c)(3) of CERCLA as amended with respect

to the imposition of civil penalties and punitive damages

35 Confidentiality Clairs Respondents may assert a

confidentiality clair if appropriate covering all or part of the

nf crrat en request- J LY bull_- is Consent Order pursuant to 40 CFR

2203(L) Such an ace-er en shall be adequately substantiated when

bullhe deserticn is rrj-co eitr9r analytical data nor any information

poundccfc-j in Sectin 1 - lt- ) bull 7 ) ( F cf CERCLA as amended by SARA

snail oe claimed is c- ideniial by Respondent Information

determined to be confidential by EPA shall be afforded the protection

specified by 40 CFR Part 2 Subpart B and in Section 104(e)(7) of

CERCLA as amended by SARA If no such claim accompanies the

information when it is submitted to EPA it may be made available to

the public by EPA without further notice to Respondents

36 Liability of Respondents Response Action Contractor The

Response Action Contractor in connection with the activities set

forth in Attachment A hereto shall not be liable under -CERCLA or

under any other federal law to the United States Government for costs

-20shy

33 Waiver of Settlement Conference In consideration of the

conununi cat ions between EPA and Respondents prior to the issuance of

this Consent Order concerning its terms Respondents hereby agree

that there is no need for a settlement conference prior to the

effective date of the Consent Order

34 Civil Penalties for Non-Compliance Respondents are

advised that except as provided by paragraph 32 of this Order if

Respondents violate or fail or refuse to comply with this Consent

Order or any portion tf-oreof EPA reserves its rights pursuant to

Sections 106(b)(l) and 107(c)(3) of CERCLA as amended with respect

to the imposition of civil penalties and punitive damages

35 Confidentiality Clairs Respondents may assert a

confidentiality clair if appropriate covering all or part of the

nf crrat en request- J LY bull_- is Consent Order pursuant to 40 CFR

2203(L) Such an ace-er en shall be adequately substantiated when

bullhe deserticn is rrj-co eitr9r analytical data nor any information

poundccfc-j in Sectin 1 - lt- ) bull 7 ) ( F cf CERCLA as amended by SARA

snail oe claimed is c- ideniial by Respondent Information

determined to be confidential by EPA shall be afforded the protection

specified by 40 CFR Part 2 Subpart B and in Section 104(e)(7) of

CERCLA as amended by SARA If no such claim accompanies the

information when it is submitted to EPA it may be made available to

the public by EPA without further notice to Respondents

36 Liability of Respondents Response Action Contractor The

Response Action Contractor in connection with the activities set

forth in Attachment A hereto shall not be liable under -CERCLA or

under any other federal law to the United States Government for costs

-20shy

or damages which result from a release or threatened release of

hazardous substances or pollutants or contaminants provided that such

releases rr threatened release was not caused by conduct of the

Response Action Contractor which was negligent grossly negligent or

which constituted intentional misconduct Said Response Action

Contractor shall have the burden of demonstrating that such conduct

was not negligent grossly negligent or did not constitute

intentional misconduct Nothing in this paragraph shall affect the

liaoiiity of any person under any warranty under federal state or

corruTon law

37 Incernnif icat icn Respondents agree to indemnify and save

arc hole rarriess the Jrtec States Government its agencies

jep bull--bullbullbull z agens ffcerrgt employees and representatives from

jry -c ciairs r --bullbull_ f action arising from or cr account of

acts r -lesions z gtcc----z their officers employees agents

-bullco vo - bull r-jsteei i2s--_ r contractors in carrying cut the

-ct bullbullbull- L^rsuant bull bull rs -rpoundent Order

38 eccvery bull Cs ~ EPA reserves the right to bri-c an

action acairst Respcrcert pursuant to Section 107 of CERC1A for

recovery of costs incurred in oversight consistent with paragraph 17

herein administration and enforcement of this Consent Order and

any other past and future costs incurred by the United States

Government in connection with response activities conducted pursuant

to CERCLA at this Site

39 Certification of Respondents Performance of the Work

Activities Upon receipt by EPA of notice from Respondents that

they believe they have satisfied their obligations under the Work

-21shy

Plan and this Consent Order EPA shall determine if Respondents

have met all of their responsibilities under the Work Plan and

under the provisions cf this Consent Order Within twenty-one

(21) days after receipt of said notice EPA will either (a)

provide Respondents with a statement of all of their

responsibilities which EPA believes are still outstanding or (b)

certify to Respondents that their responsibilities under the Scope

or Work and under the provisions of this Consent Order have been

cotrpleteiy and successfully discharged and that the work performed

by Respondents pursuant to this Consent Order and the Scope cf

Aorlt is consistent with the NC

bull10 Covenant Sst to Sue and Contribution Protection In

ccroicerat cr of and pcr certification by EPA that Respondents have

ccTplc-toly Jird succ-r i^lly d5charged their responsibilities under

ti-e -or- Plan and j-J^r the provisions of this Consent Order as

provided -or in parr ph 33 herein EPA covenants not to s-e

Rerc rdct3 n any bdquobull v 1 cr viririst rat ive action for the performance

cf tre vcrK Plan bull v jec rcwcvcr such covenant not to sue does

not extend to any ether liabilities that may be associated with the

Site including but not limited to any other response actions that

have been or may be undertaken at the Site This covenant not to sue

becomes effective upon the issuance by EPA of the certification

provided in paragraph 39 Nothing in this paragraph shall preclude

EPA from enforcing the provisions of this Consent Order in any

judicial or administrative proceeding It is the intention and

understanding of the parties to this Consent Order that the

-22shy

protection from contribution claims as provided by Section 113(b)(2)

of CERC1A as amended applies to any claim with respect to

performance of the activities pursuant to the Work Plan

41 Credit for Expenditures made pursuant to this Order

A Upon certification that Respondents have discharged

their responsibilities pursuant to the Work Plan and under the

provisions of this Consent Order Respondents shall present EPA with

an accounting of (1) all costs incurred consistent with the NCP in

deveioprert of the Work Plan and in performance of the Work Plan and

the other activities required by this Consent Order those costs will

oe segregated into two categories costs specifically associated with

bullr-e Arcror Tank Materials and all other costs and (2) the amounts

paid by -acr Pespcrdc-rr n connection therewith EPA agrees that

bullaiJ gtbull_bullbull rall no rjt i bull--bull a penalty paid by the Respondents

3 With bull-bull_bull (20) cays of receipt of such accounting

~A w i l l approve all --sts jccr-nted for by Respondents which are

orr2-t with =uup jrapr -(I) (Approved Consent Order Costs)

per z^cr approval ~A ^are-_3 to reduc-3 the amount of response costs

wnich it will seek to recover from Respondents pursuant to CERCLA or

otherwise in connection with the Site according to the following

formula said response costs shall be reduced by the Approved

Consent Order costs incurred in performing the work activities

associated with the Anchor Tank materials and by the amount resulting

from multiplying the Approved Consent Order Costs other than those

associated with Anchor Tank Materials times the quantity one minus

the result of dividing the aggregate volume of the Respondents waste

by the total volume of waste sent to the Site The volumes for these

-23shy

calculations shall be taken from the Volumetric Sank List attached as

Appendix 3 to the Administrative Order by Consent Docket No

at the time of publication in the Federal Register

C In the event that any Respondent otherwise receives

credit for Approved Consent Order Costs through settlement or

litigation the credit amount calculated under subparagraph (b) for

all Respc-dents shall be reduced by the amount of the credit received

through these other channels Moreover this paragraph shall in no

way limit or affect EFAs right to seek joint and several liability

against Respondents in any court action for all damages arc ether

costs incurred or to be incurred by EPA at the Cannons Engineering

Corporation Site This reduction in EPAs response costs with

respect - the Site -rail affect only recovery of response costs from

-r-e rc-cp-T-i--nts arc r l iv -o way affect the right cf EPA to seek

cint and -everai l i a b i l i t y JPC recovery of all resporse costs from

potentially respcrciLlo parties other than Respondents

42 PAs Re-laquobullbullbullbullbullbull-bull -- -f Richts EPA expressly reserves all

tre right- and defevcvs tra- it may have including EPAs right to

disapprove of work prforrcd by Respondents and to request that

Respondents perform tasks in addition to those detailed in this

Consent Order In addition EPA reserves the right to undertake

removal andor remedial actions at any time and to perform any and

all portions of the Work Activities which Respondents have failed to

perform properly provided however that EPA agrees to use its best

efforts to avoid duplication of Respondents activitiesunder this

Order Except as otherwise limited by paragraphs 31 and 32 EPA

reserves any and all rights to take any enforcement action pursuant

-24shy

to CERCLA as amended by SARA andor any available legal authority

This Consent Orde- does not constitute any decision on the

preauthorization of funds under Section lll(a)(2) of CERCLA as

amended by SARA

43 Respondents Reservation of Rights The participation by

Respondents in entering into and carrying out the terms of this

Consent Order shall rct be considered an admission of liability for

any purpose Nor shall such actions or participation by Respondents

constitute a commitrort or agreement either express or ixpiied to

undertake further activities at the Site other than these necessary

to perferr the Remcvcl Activities in accordance with the Work Plan

and rris Ccnsent Order or to undertake any remedial actions at the

Site r-ctwi thstandir -ry finding conclusions or reccn-Terdat ions

-ace - crrecticn ~-- performance of the Work Plan Except as

exprezly ret fortr - trie Consent Order Respondents reserve all

rcr= -rey r-_ have- -o opprre or defend against any action or claim

o r c ~ r t j

bull ther Clbull mdash Nothirg in tris Consent Order snail

constitute or be ccrstrucd as a release or a covenant not to sue

regarding any claim cause of action or demand in law or equity

against any person firm trust joint venture partnership

corporation or other entity not a signatory to this Consent Order for

any liability it may have arising out of or relating in any way to

the generation storage treatment handling transportation

release or disposal of any hazardous substances hazardous wastes

pollutants or contaminants found at taken to or taken from the

Site EPA shall not be liable for any injuries or damages to persons

-25shy

or property resulting from actions or omissions of Respondents in

carryinc out the activities pursuant to this Consent Order nor shall

EPA be held as a party to or in any other way liable under any

contract entered into by Respondents or by the Response Action

Contractor in carrying out the activities pursuant to this Consent

Order Except as otherwise herein set forth or agreed this Consent

Order shall not estop or limit any legal or equitable claims of the

United States against Respondents their agents contractors or

assigns including but not limited to claims related to releases of

hazardous substances gtr other pollutants or contaminants

45 Other laws All actions required to be taken pursuant to

-his Consent Order snail be undertaken in accordance with the

recjirererts of all appi icabl-e state and federal laws and regulashy

ticrs rcl-cirg laws rolatira to occupational safety and health and

ctrer federal envi r rctul laws as defined in current EPA policy

Otfer agencies nclJc -he Occupational Safety and Health

-crir 12 ration lOSi- -rd bull e fish and Wildlife Service (FiWS) may

oe called jpon to rev-- rc ccndjct of work under this Consent

Order In the event ihat there is a conflict in the application of

federal or state laws cr regulations the more stringent of the

conflicting provisions shall apply

46 Notice to the State Pursuant to the requirements of

Section 121(f) and 104(b)(2) of CERCLA as amended by SARA EPA has

notified the Commonwealth of Massachusetts of the scope of the

Response Action the negotiations with the potentially responsible

parties and of the issuance of this Consent Order

-26shy

or property resulting from actions or omissions of Respondents in

carryinc out the activities pursuant to this Consent Order nor shall

EPA be held as a party to or in any other way liable under any

contract entered into by Respondents or by the Response Action

Contractor in carrying out the activities pursuant to this Consent

Order Except as otherwise herein set forth or agreed this Consent

Order shall not estop or limit any legal or equitable claims of the

United States against Respondents their agents contractors or

assigns including but not limited to claims related to releases of

hazardous substances gtr other pollutants or contaminants

45 Other laws All actions required to be taken pursuant to

-his Consent Order snail be undertaken in accordance with the

recjirererts of all appi icabl-e state and federal laws and regulashy

ticrs rcl-cirg laws rolatira to occupational safety and health and

ctrer federal envi r rctul laws as defined in current EPA policy

Otfer agencies nclJc -he Occupational Safety and Health

-crir 12 ration lOSi- -rd bull e fish and Wildlife Service (FiWS) may

oe called jpon to rev-- rc ccndjct of work under this Consent

Order In the event ihat there is a conflict in the application of

federal or state laws cr regulations the more stringent of the

conflicting provisions shall apply

46 Notice to the State Pursuant to the requirements of

Section 121(f) and 104(b)(2) of CERCLA as amended by SARA EPA has

notified the Commonwealth of Massachusetts of the scope of the

Response Action the negotiations with the potentially responsible

parties and of the issuance of this Consent Order

-26shy

47 Notice to the Federal Natural Resource Trustee Pursuant

to Sections 122(j) of SARA EPA has notified the Federal Natural

Resource Trustee of the scope of the Response Action the negotiation

with the potentially responsible parties and of the issuance of this

Consent Order

48 Separate Documents This Consent Order may be executed in

two or more counterparts each of which shall be deemed an original

but all of which together shall constitute one and the same

instrument

49 Effective Dare This Consent Order shall be effective upon

the date cf Respondents1 receipt of notice of signature by the

Seccrai Administrate- All times for performance of activities

jrcer -5 Consent Crder shall be calculated from that date

IT S SO AJPEID AND 3IRID iV

bullcr-e P leiarc Date

-27shy

IT IS SO AGREED

Name of Respondent ACUSHNET COMPANY

By Dale M Shenk Vice President and Controller

Title

January T 8 8 Date

-28shy

IT IS SO AGREED AMERICAN C^AMID COMPANY

Name of Respondent

By A JsJ Costello

Executive Vice President Title

bulljruary 1D3S Date

-28shy

IT IS SO AGREES

AMERICAN NATIONAL CAN CORPORATION Name cf Respondent

By S1U4uJ [ampJUULL~-~AT LAW

JAMES BALLS bull_

Title

JAMASY 7Date

198B

laquo By his signature hereon Janes Seller certifies that he has authority to bind Respondent to the terms of this agreement

-28shy

IT IS SO AGREED

ATampT Technologies Inc Name of Respondent

By ATampT-Engineering Vice President

Title

Date

-28shy

0 A

IT IS SO A G R E E D

Name of Respondent

By John L Fox

General Manager Title

January 6 T968 Date

-28shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED AMERICAN C^AMID COMPANY

Name of Respondent

By A JsJ Costello

Executive Vice President Title

bulljruary 1D3S Date

-28shy

IT IS SO AGREES

AMERICAN NATIONAL CAN CORPORATION Name cf Respondent

By S1U4uJ [ampJUULL~-~AT LAW

JAMES BALLS bull_

Title

JAMASY 7Date

198B

laquo By his signature hereon Janes Seller certifies that he has authority to bind Respondent to the terms of this agreement

-28shy

IT IS SO AGREED

ATampT Technologies Inc Name of Respondent

By ATampT-Engineering Vice President

Title

Date

-28shy

0 A

IT IS SO A G R E E D

Name of Respondent

By John L Fox

General Manager Title

January 6 T968 Date

-28shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREES

AMERICAN NATIONAL CAN CORPORATION Name cf Respondent

By S1U4uJ [ampJUULL~-~AT LAW

JAMES BALLS bull_

Title

JAMASY 7Date

198B

laquo By his signature hereon Janes Seller certifies that he has authority to bind Respondent to the terms of this agreement

-28shy

IT IS SO AGREED

ATampT Technologies Inc Name of Respondent

By ATampT-Engineering Vice President

Title

Date

-28shy

0 A

IT IS SO A G R E E D

Name of Respondent

By John L Fox

General Manager Title

January 6 T968 Date

-28shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

ATampT Technologies Inc Name of Respondent

By ATampT-Engineering Vice President

Title

Date

-28shy

0 A

IT IS SO A G R E E D

Name of Respondent

By John L Fox

General Manager Title

January 6 T968 Date

-28shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

0 A

IT IS SO A G R E E D

Name of Respondent

By John L Fox

General Manager Title

January 6 T968 Date

-28shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of R e s p o n d e n t ^-

CHAMBERLAIN MANUFACTURING CORPORATION

By

General Co Title

Jaruar- D a t e

1988

-28shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS 60 AGREED

Name of Respondent ^ t~poundr llS^eL

Byj Richard Barth

Preeident fc Chief Executive Officer Title

CIBA-GEIGY corporation January 6 1988

Date

-28shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent Earthline Company fsCA

By

Authorized Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent FAIRCHILD SEMICONDUCTOR CORPORATION

By C R Bostic

Its Representative Title

January 4 1986 Date

-28shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent Franklin Pumping Service Inc

By

J I J (President)

1788 Date

-28shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent General Dynamics Corporation

By

Daniel S Hapke Assistant General Counsel T i t l e

4 January 1988 Date

-28shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT 18 SO AGREED i

of Ropondtnt

By

-28shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

In the Matter of Cannons Engineering Corporation Administrative Order by Consent

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

Hoechst Celane^e Corporation

Heinz X HofmeistermdashVice President Title

-28shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent HoffaeM-La Bocht Inc

By EB Anderson Senior Viet Prttident

Title

-28shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

P3 ICIO UflWDGFT GO JMN 0 8

XT IS SO ACREEDi

of Respondent rrt

bullyi

Jlflua r v 7 shym

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent Interex^Corporation

By

Authorized Axteht Title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent

By

January 13 1988 Date

Millipore CorporationWaters Associates

Senior Vice President Title

-28shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

Cannons Engineering Corporation Administrative Order by Consent Bridgewater Removal Action

IT IS SO AGREED

Name of Respondent MONSANTO COMPANY iIs

Ishy t- r S S rr- -w ~

By

ff Title

Dote

-28shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

E00 3pound

IT IS SO AGREED

Name of Respondent

By

-IVCL

pound1

Title

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent

By

January 7 1988 Date

POLAROID CORPORATION

VICE PRESIDENT AND SECRETARY Title

-28shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent Re eyeling Industries Inc

By

Authorized Agent title

January 8 1988 Date

-28shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

IT IS SO AGREED

Name of Respondent TECH- gTCM

By

Title

Date

-28shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

ATTACHMENT A

BRIDGEWATER CANNONS ENGINEERING CORPORATION SITE CONSENT ORDER WORK PLAN

I Introduction and Purpose

The purpose of this Consent Order Work Plan is to identify

response actions to be taKen by Respondents of the Site pursuant to

the foregoing Consent Order

I1 Scooe of Work

1 The following are the removal activities required by the

Consent Order

a Renov3- cf XTas-cs The following waste materials shall

oe roTcvo^ frcn the jte poundrd properly disposed of in accordance with

ail applj^oie erv r crrort1 laws and regulations

apprcxirrateiy 400 five-gallon pails containing

waste -atoral from inside the Equipment Building

This -aterial was previously located irsice the box

trailers

approximately 400 less than five-gallon pails which

have had the contents removed into two 55-gallon

drums

approximately one drum full and one drum 34 full

which were generated from the emptying of the above

mentioned less than five-gallon containers

-29shy

approximately 350 containers of laboratory reagents

which were abandoned in the laboratory inside the

Equipment Building

a container approximately one pint in volume

containing an unknown liquid which is considered to

be shock sensitive and will be treated as such

one five-gallon pail of bulked laboratory samples

one three-gallon pail of bulked laboratory samples

approximately 1000 gallons of aqueous waste

material contained in above-ground storage

containers which include less than 10 partially

filled druTs one dumpster and one tank trailer

appr- xiTately 25000 gallons of aqueous waste

material crrtained in the underground tanks

app r bull IT -ic-ly 500 gallons of waste oil determined

to contain a CB content of less than 2 parts per

appr c bull irrately two 55 gallon drums of materials

scraped from trailer bottoms

approximately two 55 gallon drums of contaminated

sorbent material from the equipment building floor

contaminated soil from opening area not to exceed

20 cubic yards

one 55 gallon drum approximately three-quarters

full of contaminated lab water from on-site

laboratory used during initial EPA removal

activities and

-30shy

approximately seventy-five 30 gallon garbage bags

containing contaminated protective clothing and

sampling implements

b Transportation of Wastes All of the above-described

wastes will be transported in accordance with all applicaole laws and

regulations including but not limited to all Department of

Transportation (DOT) regulations Additionally all containers

shipped off site and all vehicles carrying these containers will be

properly and completely labeled and placarded in accordance with all

applicable laws and regulations

c Disposal cf Wastes The Respondents shall make all

arrangerents necessary 10 accomplish the proper disposal of all of

the ebcve-cescribed wastes This shall include making available

disprsol perscrrel frr- -e selected disposal facility as needed to

ass-re hat the pack- J-TC snipping methods used meet the disposal

f a c i l i t y specifications f~r acceptance of wastes For elt ch waste

r-aterial ~z oe rencve-j ircr tre site the Respondents shall indicate

befcrc the waste is rerrcved frcrr the site the method of disposal the

name(s) of the facilityiies) to be utilized the compliance status of

the facility(ies) to be utilized the name(s) of transporter(s) to be

utilized the method of transport for each waste and the packaging

to be utilized

d Record of Disposal The Respondents shall provide EPA

with all paperwork documenting the location of all wastes that leave

the site This shall include all temporary storage facilities that

may be utilized before the waste reaches its final destination for

disposal All wastes removed from the site will be pursuant to an

-31shy

approximately seventy-five 30 gallon garbage bags

containing contaminated protective clothing and

sampling implements

b Transportation of Wastes All of the above-described

wastes will be transported in accordance with all applicaole laws and

regulations including but not limited to all Department of

Transportation (DOT) regulations Additionally all containers

shipped off site and all vehicles carrying these containers will be

properly and completely labeled and placarded in accordance with all

applicable laws and regulations

c Disposal cf Wastes The Respondents shall make all

arrangerents necessary 10 accomplish the proper disposal of all of

the ebcve-cescribed wastes This shall include making available

disprsol perscrrel frr- -e selected disposal facility as needed to

ass-re hat the pack- J-TC snipping methods used meet the disposal

f a c i l i t y specifications f~r acceptance of wastes For elt ch waste

r-aterial ~z oe rencve-j ircr tre site the Respondents shall indicate

befcrc the waste is rerrcved frcrr the site the method of disposal the

name(s) of the facilityiies) to be utilized the compliance status of

the facility(ies) to be utilized the name(s) of transporter(s) to be

utilized the method of transport for each waste and the packaging

to be utilized

d Record of Disposal The Respondents shall provide EPA

with all paperwork documenting the location of all wastes that leave

the site This shall include all temporary storage facilities that

may be utilized before the waste reaches its final destination for

disposal All wastes removed from the site will be pursuant to an

-31shy

appropriate Hazardous Waste Manifest EPAs On-Scene Coordinator

will sign each manifest relating to the Anchor Tank material so as to

indicate that EPA is the generator of the Anchor Tank material being

removed from the site For all wastes that leave the site the

Respondents will supply information to include but not be limited

to the date of arrival and departure of each waste to or from each

facility a list of all wastes in question and the signature of the

company representative who accepted the wastes in question

Additionally for any waste that is incinerated or otherwise

destroyed the Respondents shall provide certification by a company

official of the facility destroying the waste that the waste was

ndeed destroyed ard by what nethod it was destroyed

e Site Postcraticn Before final demobilization the

^espcrv-- 3 shall restore the site to an acceptable degree This

-bullill ircl-de assur-rce tl-at no trash or waste materials or equipment

associated with any rf the removal activities is left on site Any

~aterjl including soil which has not been contaminated by site

rperatiors shall be returned to its original location

2 The following activities shall also be performed by

Respondents to fulfill the objectives of the Response Action

a Work Plan The Respondents shall prepare a Work Plan

consisting of all activities and subtasks The Work Plan shall

identify all deliverables to be produced during the Work Activities

including timetables for performance of the Work Activities and

production of the deliverables The Work Plan shall identify each

previously identified waste material to be removed from the site and

the Quality Assurance and Quality Control to be used during Work

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Activities The detailed scope of work shall identify for all waste

materials removed from the site the method of disposal of each waste

material The identification shall include at a minimum the exact

method of disposal the name(s) of facility(ies) to be utilized the

facilitys(ies) compliance status name(s) of transporter(s) to be

utilized method of transport and packaging to be utilized The

Work Plan shall specify the health and safety procedures to be

followed At a minirruT the health and safety plan shall include a

brief introduction identify by name and assign responsibilities to

both the person in charge ard a Site Safety Officer contain

emergency phone numbers and directions to the nearest hospital list

known contarrinants Known present on the site state general safety

rules deii-eate work rcres describe in detail protective clothing

-3 oe u t i l i z e d ard cr-era fcr use of such clothing establish

deccr tar rjt cn prcced-res for personnel and equipment address the

effects and treatrcn zf cclc exposure describe standard operating

or r rod u r bullbull fcr lasnc peciied in the Work Plan and contain an

erc ency plan

Respondents shall identify the specific tasks necessary to

perform each activity identified in the Work Plan The Work Plan

must be in conformance with EPA Quality Assurance and Quality Control

procedures as set forth in Interim Guidelines and Specifications for

Preparing Quality Assurance Project Plans QAMS -0058- EPA Office

of Research and Development December 1980 These procedures are

subject to review and approval by EPA Quality Assurance -personnel

EPA will review the Work Plan consistent with the provisions of

paragraph 28 of the Consent Order

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Activities The detailed scope of work shall identify for all waste

materials removed from the site the method of disposal of each waste

material The identification shall include at a minimum the exact

method of disposal the name(s) of facility(ies) to be utilized the

facilitys(ies) compliance status name(s) of transporter(s) to be

utilized method of transport and packaging to be utilized The

Work Plan shall specify the health and safety procedures to be

followed At a minirruT the health and safety plan shall include a

brief introduction identify by name and assign responsibilities to

both the person in charge ard a Site Safety Officer contain

emergency phone numbers and directions to the nearest hospital list

known contarrinants Known present on the site state general safety

rules deii-eate work rcres describe in detail protective clothing

-3 oe u t i l i z e d ard cr-era fcr use of such clothing establish

deccr tar rjt cn prcced-res for personnel and equipment address the

effects and treatrcn zf cclc exposure describe standard operating

or r rod u r bullbull fcr lasnc peciied in the Work Plan and contain an

erc ency plan

Respondents shall identify the specific tasks necessary to

perform each activity identified in the Work Plan The Work Plan

must be in conformance with EPA Quality Assurance and Quality Control

procedures as set forth in Interim Guidelines and Specifications for

Preparing Quality Assurance Project Plans QAMS -0058- EPA Office

of Research and Development December 1980 These procedures are

subject to review and approval by EPA Quality Assurance -personnel

EPA will review the Work Plan consistent with the provisions of

paragraph 28 of the Consent Order

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b Ancillary Site Activities Respondents shall take such

measures as may be necessary to ensure that while carrying out the

activities of the Work Plan there is no release of hazardous

substances or pollutants or contaminants into the environment

Respondents shall specify in the Work Plan what measures are

necessary to insure there is no release or contamination from their

removal activities

c Disposal of Waste Respondents shall dispose of all

sitlt3-reiated wastes generated during the course of these Vcrk

Activities as well as those waste containers currently on-site which

were generated as a consequence of past response activities All

such disposal shall be in accordance with paragraph Id of this Work

Plan

c Respondents snail assume responsibility for site

security w i t h i n 48 hc^rs of the later of either the execution of the

Consent Order by all parties or the obtaining of site access pursuant

to par ^rop- 21 cf the Consent Order Site security shall be on a 24

hour per cay seven cay per ween basis Respondents agree to

maintain site security until the completion of all field work

pursuant to this Consent Order Work Plan Respondents shall notify

EPA upon completion of all field work that Respondents intend to

terminate site security Within twenty-four (24) hours of receipt of

said notice EPA shall inform Respondents of any field work remaining

or alternatively of EPAs intent to take over site security

3 Work Schedule Respondents shall submit a proposed Work Plan

within 14 days of engagement of a contractor as required by

paragraph 19 of the Consent Order The draft Work Plan will be

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subject to technical and quality assurance review by EPA A final

Work Plan shall be submitted within 10 days of receipt of any EPA

revisions issued under the terms of paragraph 28 of the Consent

Order Respondents shall commence implementation of the final Work

Plan within 7 days of receiving EPA approval and Respondents shall

complete all field work tasks specified in the Work Plan within

thirty (30) days Within forty-five (45) days of completing all

field work tasks Respondents shall complete all laboratory analyses

and submit all reports required by the Work Plan EPA reserves the

option to modify the implementation schedule for any reason

whatsoever

4 Respondents shall submit to EPA all information generated as

a consequence of these activities including laboratory QAQC

nf or-at cr sufficient fcr a Level I EPA analytical data validation

all analytical data both raw and tabulated all Scopes of Work and

scrK Plans and a final report summarizing activities materials and

retrccs coservat icrs firdircs and summary All deliverables are

subject to review i accordance with paragraph 28 of the Consent

Order EPA retains final discretion to decide the acceptability of

any work activity andor work product submitted by the Respondents

subject to the dispute resolution procedures of paragraph 30 of the

Consent Order

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subject to technical and quality assurance review by EPA A final

Work Plan shall be submitted within 10 days of receipt of any EPA

revisions issued under the terms of paragraph 28 of the Consent

Order Respondents shall commence implementation of the final Work

Plan within 7 days of receiving EPA approval and Respondents shall

complete all field work tasks specified in the Work Plan within

thirty (30) days Within forty-five (45) days of completing all

field work tasks Respondents shall complete all laboratory analyses

and submit all reports required by the Work Plan EPA reserves the

option to modify the implementation schedule for any reason

whatsoever

4 Respondents shall submit to EPA all information generated as

a consequence of these activities including laboratory QAQC

nf or-at cr sufficient fcr a Level I EPA analytical data validation

all analytical data both raw and tabulated all Scopes of Work and

scrK Plans and a final report summarizing activities materials and

retrccs coservat icrs firdircs and summary All deliverables are

subject to review i accordance with paragraph 28 of the Consent

Order EPA retains final discretion to decide the acceptability of

any work activity andor work product submitted by the Respondents

subject to the dispute resolution procedures of paragraph 30 of the

Consent Order

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