Chronology of Events at the HoltraChem Site Including Recent Selected State DEP Actions

August 27, 1980 - International Minerals & Chemical Co. issued interim State Hazardous Waste Facility License.
December 1983 - Maine DEP approves closure plan for landfill #5.
1989-1997 - Discharge of mercury containing brine to leach fields (discovered during 1997).
May 1995 - Mercury contaminated sediment removed from paved sump.
August 1-2, 1995 - Discharge of 65,000 gallons of wastewater with high mercury content.
June 1996 - Maine DEP works with HoltraChem on a pollution prevention project to investigate the piping system at the plant to prevent discharges.
January 25 - 31, 1997 - High and low pH hazardous waste discharged to Penobscot River from caustic soda leaking into sewer system.
January 27, 1997 - DEP staff observe seepage from site into Southerly Stream that contained mercury and high pH.
February 19 - March 4, 1997 - Between 30,000 and 270,000 gallons of mercury contaminated brine, a hazardous waste leaked from a tank into the ground. HMC discovered leak on February 19, 1997, but did not report it to the DEP until February 24, 1997, and did not stop the discharge until March 4, 1999.
February 21, 1997 - DEP Notice of Violation issued to HoltraChem for storage of open containers, leaking containers, treatment of hazardous waste, failure to train employees, failure to have secondary containment, failure to make hazardous waste determinations, discharge of hazardous waste into land and water, and failure to report discharges.
April 1997 - Investigation of north filter backwash receiver tank leak with geoprobes.
May 1, 1997 - 1,000 gallons of mercury contaminated brine, a hazardous waste, spill over the top of a "clarifer" tank and onto the ground and into the Penobscot River.
May 14, 1997 - DEP Notice of Violation issued to HoltraChem for leak from north filter backwash receiver tank and overflow of the brine clarifer.
June 1997 - Surface water and sediment testing done in Southerly Stream due to north filter backwash receiver tank leak.
July 1997 - Leachfield #1 investigation for mercury contamination due to mercury containing brine discharges.
July 17 - 19, 1997 - For three days mercury contaminated wastewater, a hazardous waste, discharge from a sump in the cell building. On the third day, 270 gallons spilled out the door and onto the pavement and bare soil.
July - September, 1997 - Investigate remaining leachfields for mercury releases.
August 19, 1997 - A hydrogen condensate pump malfunctioned causing a spill of 200 gallons of condensate, which due to its mercury content, was a hazardous waste.

October, 1997 - present - Monitor quarterly drinking water wells of Ferry Road residences.
November 1997 - Fence installed between Southerly Stream and Ferry Road residential area.
November 12, 1997 - NPDES outfall break repaired.
December , 1997 - Weekly monitoring of mercury in Southerly Stream and Northern ditch begins.
December 1, 1997 - Chlorine alarm procedures developed.
December 1, 1997 - Inform residences within one mile of chlorine alarm procedure.
December 10 - 16, 1997 - DEP conducts ambient air monitoring at Holtrachem.
December 12, 1997 - Chlorine release training for HMC operators.
December 15, 1997 - Convene community group regarding release/spill response and notification.
December 17, 1997 - Enforcement Consent Agreement signed between DEP and HoltraChem. There were three major components to agreement: (1) extensive corrective measures at the facility to prevent future problems; (2) $700,000 civil penalty, and (3) ordered HoltraChem to comply with laws governing hazardous waste generators.
December 19, 1997 - Contaminated soil removed from spill area.
Early 1998 - Clarifier tank removed.
Monthly 1998 - Continuously monitor the treated wastewater for pH.
1998 - Dye testing of potential mercury discharge locations conducted along with Penobscot River Study.
February 12, 1998 - Independent P.E. submits Facility Integrity Evaluation with recommendations for improvements.
February 20, 1998 - 20,000 gallon hazardous waste brine spill.
March 1998 - Contaminated soil removed from spill area.
March 10, 1998 - Plan and schedule for upgrades recommended in Facility Integrity Evaluation.
April 21-24, 1998 - Excavated mercury containmated soil from spill area, catch basins and paved sump.
May 8, 11, 12, 13, 14, 1998 - Facility Review and Shutdown required by State Order.
July 30, 1998 - Facility Review and Shutdown required by State Order.
July, 1998 - February 2001 - Comprehensive Site Monitoring conducted for mercury (groundwater, surface water and onsite sediment).
July 8, 1998 - Environmental Management System started.
August 18, 19, 1998 - Facility Review and Shutdown required by State Order.
September 1998 - November 1999 - HoltraChem Ambient Air Monitoring program begun.
September 8, 1998 - August 1999 - Environmental Monitor onsite to assess compliance with environmental standards.
September, 1998 - August, 1999 - Monthly Compliance Assessment Reports submitted to DEP by Environmental Monitor.
September 16, 1998 - Facility Review and Shutdown required by State Order.
October 20, 1998 - Install stream guard bags in catch basins.
October 30, 1998 - Implement plan to prevent mercury contaminated sediment in Southerly Stream and northern ditch from entering the Penobscot River.
December, 1998 - North Filter Backwash Receiver tank is repaired.

1999 - Landfill #1 is armored to prevent erosion.
March 1999 - Caustic filtration system is installed.
March 9 - 11, 1999 - Tech Law mercury air sampling at HoltraChem conducted.
May 5, 1999 - East caustic tank tightness test to assess if tank is leaking and is the cause of the problem in the Southerly Stream.
May- July, 1999 - Elevated pH investigation near caustic tanks and rail loading shed.
June 15, 1999 - DEP pH testing of Southerly Stream (Testing also done for previous 4 weeks).

July 1999 - Orrington town library repository established by HoltraChem.
July 6, 1999 - East & West Caustic tank integrity results.

August 1999 - New brine system installed.
October 1, 1999 - Onsite sediment sampling plan completed.

October, 1999 – Sewer line investigation report completed.
December, 1999 - The new wastewater system is operational.

2000 - Cell room mercury monitoring begins as part of State air license.
April 10, 2000 - The new state wastewater treatment license is issued.

Spring, 2000 - The North and South Filter Backwash Receiver tanks are abandoned.
April 10, 2000 - Joint DEP & EPA disapproval letter sent to HoltraChem on Site Investigation Report and Media Protection Standards. The letter required:

Stabilization Measures

Plan for removal of lined process lagoon by April 15, 2000. This unit which contained mercury contaminated brine has historically leaked. Plan submittal date was revised to plan for relining by May 19, 2000 with removal from service by end of 2001. Plan for relining of lagoon submitted.
If holes in lined process lagoon were not repaired per the site investigation report, the lagoon needs to be removed as soon as possible, dead line later revised to July 15, 2000. June 26, 2000 lagoon is relined.
Plan with schedule for collection and treatment of onsite contaminated groundwater by April 30, 2000. Not submitted, item under dispute.
Plan for sediment removal from Penobscot River, Southern Cove by July 15, 2000 with sediment removal to begin by June 1, 2001. Report submitted entitled "Evaluation of Sediment Removal Methods - HoltraChem Site, Orrington, Maine" dated January 22, 2001. Specific target date for removal disputed.
Seal trenches and sump areas or verify that they are tight and free of leakage or rough surfaces by August 30, 2000. Status Unknown, Mallinckrodt has been requested to check on the status.
Plan with schedule for how Hazeltine and DeSanctos properties will be provided with potable water. They have unacceptable salt levels from HoltraChem property runoff. June 30, 2000 plan for installation of filtration system submitted.
Plan and schedule for redesign of onsite salt storage shed to prevent contamination of surface water and groundwater. Plant closure eliminated the necessity for this item.

Investigation Actions

Investigate chloropicrin spill area for a concentrated source area, which could be removed. Plan with schedule due by June 1, 2000, date revised to June 30, 2000. July 3, 2000 plan submitted entitled "Work Plan for the Investigation of chloropicrin in soil dated June, 2000".
Investigate scrap metal area as a potential mercury hot spot area where a concentrated source of mercury could be removed. Plan for investigation by May 30, 2000. Not submitted, item under dispute.
Investigate the following areas for mercury contamination:

used equipment storage area
retort building and area
potential brine discharge pathway
coal brine filter storage area

Plan for investigation by May 30, 2000. Not submitted, item under dispute.

Develop a plan by June 30, 2000 for the investigation of mercury hot spots in the Penobscot River sediment. June 13, 2000 submitted "Work Plan for the Assessment of the Lower Penobscot River, Maine dated June 9, 2000"
Monitor the ongoing soil containment measures to determine that effectiveness in stabilizing soil particles onsite and in preventing their movement into waterways and eventually the Penobscot River. Sediment sampling plan dated September, 1999 submitted which showed that approximately 1.3 pounds of mercury were prevented from being discharged during 2000 from the site by the ongoing soil containment measures. Item under dispute, the need to monitor the effectiveness of the containment system is under dispute.
Investigate landfill #2 to see if it is leaking and if the cap is adequate. Plan and schedule by September 15, 2000. August 6, 2000 groundwater investigation plan submitted. Item disputed, the results of the investigation and the need to monitor landfill are under dispute.
Review mercury, biological, water and sediment data on the Penobscot River and other Maine water bodies and incorporates into Proposed Preliminary Media Protection Standards. Ongoing
Review release, effects and cleanup numbers for other chlor-alkali facilities and take into account in the Proposed Preliminary Media Protection Standards. Ongoing
Maintain landfill #4 in accordance with the maintenance and monitoring standards of landfill #5. Item under dispute, maintenance item disputed, August 14, 2000 monitoring plan for two years proposed.

Specific Comments

Respond to specific comments by May 30, 2000, deadline extended to June 30, 2000. June 30, 2000 response submitted. A number of items remain in dispute.
May 23, 2000 - HoltraChem invokes dispute resolution provisions for April 10, 2000 DEP/EPA letter. Dispute resolution process still in effect as of May 2001, a number of items are still in dispute.
Summer 2000 - chloropicrin contamination investigation conducted.
June 26, 2000 – Leaking lined process lagoon is relined.

· August , 2000 - Excavation of mercury contaminated soils in Southerly Stream area.

· August, 2000 - Groundwater collection system installed in Southerly Stream area to collect high pH and mercury contaminated water.

August 24, 2000 - DEP requests hazardous waste generator closure.
Fall, 2000 - Three of the four wastewater treatment resin trains are replaced.
Closure plans for site approved by DEP:
September 21, 2000 -cell room
September. 22, 2000, October 6, 2000, October 17, 2000 - brine area
September 28, 2000, October 5, 2000 - hydrochloric acid
October 2, 2000 - chlorine
October 5, 2000, October 25, 2000 - sodium hypochlorite.
October 17, 2000 - caustic soda
November 1, 2000 - chloropicrin
December 11, 2000 - Post closure application filed with DEP
January 5, 2001 - Post closure application returned as incomplete by DEP.
January 19, 2001 - Report on the Lower Penobscot River investigation submitted.
February 9, 2001 - Post closure application refiled with state.

· March 30, 2001 - Restrictive Covenant for HoltraChem property signed.

· March 30, 2001 - Memorandum of Understanding signed between DEP, Mallinckrodt and Earth Tech to provide security at HoltraChem site and the continued operation and improvement of the wastewater treatment plant following HoltraChem's dissolution.

· December 2001 – Thirty-five newly fabricated, 1 metric ton, steel containers for shipping mercury were received.

· June 10, 2002 – Mercury transfers into DOT shipping containers begun.

August 2002 - Mallinckrodt Inc., Mercury Waste Solutions, Inc., and Natural Resources Council of Maine sign an agreement for the storage of 84 tons of mercury
September 2002 - Mercury is shipped to Mercury Waste Solutions for storage.
May 2003 -- Dismantling of equipment within the cell building begins along with Lumex monitoring around cell building and at four air monitoring locations.
July 2003 - Pavement sweeping to remove soil containing mercury residue. 7 cubic yards collected with an average concentration of 2.22 mg/kg for a total of 0.046 lb. of mercury.
August 2003 - Catch basin inserts changed and soil containing mercury residue removed. 6 inserts changed and 0.001369 lb. of mercury removed.
September 22, 2003 - A revised Corrective Measures Study is submitted to the Maine DEP and the U.S. EPA.
June 3, 2004 - The Phase 2 process Systems Dismantling Plan approved by the Maine DEP.

Remediation & Waste Management

Chronology of Events at the HoltraChem Site Including Recent Selected State DEP Actions