Creese & Cook Tannery (Former) HRS Documentation Record

MAD001031574 September 2012

HRS DOCUMENTATION RECORD COVER SHEET

Name of Site: Creese & Cook Tannery (Former)

EPA ID No.: MAD001031574

Contact Persons

Site Investigation: Weston Solutions, Inc. (WESTON®)/ (978) 552-2100

Superfund Technical Assessment and

Response Team III (START)

3 Riverside Drive

Andover, MA 01810

(Mr. Gerald A. Hornok and Mr. John F. Kelly)

Documentation Record: U.S. Environmental Protection Agency (617) 918-1436

(EPA) Region I

5 Post Office Square, Suite 100

Boston, MA 02109-3912

(Ms. Nancy Smith)

Pathways, Components, or Threats Not Scored

Ground Water Migration Pathway

Limited ground water sampling has occurred at the Creese & Cook Tannery (Former) facility property. 

Historical ground water monitoring well samples and seep samples along the banks of the Crane River 

have been collected. Analytical results of the samples indicated a release of site-related hazardous 

substances to the ground water. Recent ground water and seep sampling has not been performed, and to 

date, a release of hazardous substances to ground water from on-site sources has not been supported. The 

Ground Water Migration Pathway has not been scored because recent data are unavailable; consequently,

the resulting pathway score would not contribute significantly to the overall site score. Therefore, this 

pathway has not been included in the HRS documentation record.

Air Migration Pathway

To date, a release of hazardous substances to air from on-site sources has not been documented. The Air 

Migration Pathway has not been scored because the data are unavailable; consequently, the resulting 

pathway score would not contribute significantly to the overall site score. Therefore, this pathway has not 

been included in the HRS documentation record.
Creese & Cook Tannery (Former) 1 HRS Documentation Record

MAD001031574 September 2012

HRS DOCUMENTATION RECORD

Name of Site: Creese & Cook Tannery (Former) Date Prepared: September 2012

EPA Region: Region I

Street Address of Site*: 55 Clinton Avenue

City, County, State, Zip Code: Danvers, Essex County, Massachusetts, 01923

General Location in the State: Northeastern Massachusetts

Topographic Map: U.S. Geological Survey, Salem, Massachusetts 7.5-minute × 15-minute series 

Topographical Map. 1985 [19].

Latitude**: 42° 33′ 11.2′′ North

Longitude**: 70° 55′ 36.2′′ West

Scores

Ground Water Pathway NS

Surface Water Pathway 100.00

Soil Exposure Pathway 68.40

Air Pathway NS

HRS SITE SCORE 60.57

NS = Not Scored

* The street address, coordinates, and contaminant locations presented in this Hazard Ranking System 

(HRS) documentation record identify the general area the site is located. They represent one or more 

locations U.S. Environmental Protection Agency (EPA) considers to be part of the site based on the 

screening information EPA used to evaluate the site for National Priorities List (NPL) listing. EPA lists 

national priorities among the known “releases or threatened releases” of hazardous substances; thus, the 

focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been “deposited, stored, placed, or otherwise come to be located.” Generally, HRS scoring 

and the subsequent listing of a release merely represent the initial determination that a certain area may 

need to be addressed under Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA). Accordingly, EPA contemplates that the preliminary description of facility boundaries at 

the time of scoring will be refined as more information is developed as to where the contamination has 

come to be located.

** The geographic coordinates of the site were measured from the location where the former steam 

process pipe/footbridge intersects Source number (No.) 4 [5, pp. 1-2]. See Reference 5 for the location of 

the latitude and longitude measurement point.
Creese & Cook Tannery (Former) 2 HRS Documentation Record

MAD001031574 September 2012

WORKSHEET FOR COMPUTING HRS SITE SCORE

S S2

1. Ground Water Migration Pathway Score (Sgw) NS --

2. Surface Water Overland/Flood Migration Component (Ssw)

(from Table 4-1, line 30) 100.00 10,000

3. Soil Exposure Pathway Score (Ss)

(from Table 5-1, line 22) 68.40 4,678.56

4. Air Migration Pathway Score (Sa)

(from Table 6-1, line 12) NS --

5. Total of Sgw

2 + Ssw2 + Ss2 + Sa2

14,678.56

6. HRS Site Score

Divide the value on line 5 by 4 and take the square root 60.57
Creese & Cook Tannery (Former) 3 HRS Documentation Record

MAD001031574 September 2012

HRS Table 4-1 [1, Table 4-1]

Surface Water Overland/Flood Migration Component Scoresheet

Factor Categories and Factors Maximum 

Value

Value

Assigned

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

 2a. Containment 10 NS

 2b. Runoff 25 NS

 2c. Distance to Surface Water 25 NS

 2d. Potential to Release by Overland Flow (lines 2a x [2b + 2c]) 500 NS

3. Potential to Release by Flood:

 3a. Containment (Flood) 10 NS

 3b. Flood Frequency 50 NS

 3c. Potential to Release by Flood (lines 3a x 3b) 500 NS

4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 500 NS

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics:

6. Toxicity/Persistence (a) NS

7. Hazardous Waste Quantity (a) NS

8. Waste Characteristics 100 NS

Targets:

9. Nearest Intake 50 NS

10. Population:

 10a. Level I Concentrations (b) NS

 10b. Level II Concentrations (b) NS

 10c. Potential Contamination (b) NS

 10d. Population (lines 10a + 10b + 10c) (b) NS

11. Resources 5 NS

12. Targets (lines 9 + 10d + 11) (b) NS

Drinking Water Threat Score:

13. Drinking Water Threat Score 

([lines 5 x 8 x 12]/82,500, subject to a maximum of 100) 

100 NS

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 5 × 108

16. Hazardous Waste Quantity (a) 100

17. Waste Characteristics 1,000 320
Creese & Cook Tannery (Former) 4 HRS Documentation Record

MAD001031574 September 2012

HRS Table 4-1 [1, Table 4-1]

Surface Water Overland/Flood Migration Component Scoresheet (Concluded)

Factor Categories and Factors Maximum 

Value

Value

Assigned

Targets:

18. Food Chain Individual 50 45

19. Population:

 19a. Level I Concentrations (b) NS

 19b. Level II Concentrations (b) 0.03

 19c. Potential Human Food Chain Contamination (b) NS

 19d. Population (lines 19a + 19b + 19c) (b) 0.03

20. Targets (lines 18 + 19d) (b) 45.03

Human Food Chain Threat Score:

21. Human Food Chain Threat Score

([lines 14 x 17 x 20]/82,500, subject to a maximum of 100) 

100 96.06

Environmental Threat

Likelihood of Release:

22. Likelihood of Release (same value as line 5) 550 550

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) 5 × 108

24. Hazardous Waste Quantity (a) 100

25. Waste Characteristics 1,000 320

Targets:

26. Sensitive Environments:

 26a. Level I Concentrations (b) NS

 26b. Level II Concentrations (b) 55

 26c. Potential Contamination (b) NS

 26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 55

27. Targets (value from 26d) (b) 55

Environmental Threat Score:

Environmental Threat Score

([lines 22 x 25 x 27]/82,500, subject to a maximum of 60) 60 60.00

Surface Water Overland/Flood Migration Component Score 

for a Watershed

29. Watershed Scorec

(lines 13 + 21 + 28, subject to a maximum of 100) 100 100.00

Surface Water Overland/Flood Migration Component Score

30. Component Score (Sof), (highest score from line 29 for all 

watersheds evaluated, subject to a maximum of 100) (c)

100 100.00

(a) Maximum value applies to waste characteristics category.

(b) Maximum value not applicable. (c) Do not round to nearest integer.
Creese & Cook Tannery (Former) 5 HRS Documentation Record

MAD001031574 September 2012

HRS Table 5-1 [1, Table 5-1]

Soil Exposure Pathway Scoresheet

Factor Categories and Factors Maximum

Value

Value

Assigned

Resident Population Threat

Likelihood of Exposure:

1. Likelihood of Exposure 550 550

Waste Characteristics:

2. Toxicity (a) 10,000

3. Hazardous Waste Quantity (a) 10

4. Waste Characteristics 100 18

Targets:

5. Resident Individual 50 50

6. Resident Population:

 6a. Level I Concentrations (b) 520

 6b. Level II Concentrations (b) 0

 6c. Resident Population (lines 6a + 6b) (b) 520

7. Workers 15 0

8. Resources 5 0

9. Terrestrial Sensitive Environments (c) NS

10. Targets (lines 5 + 6c + 7 + 8 + 9) (b) 570

Resident Population Threat Score:

11. Resident Population Threat (lines 1 x 4 x 10) (b) 5,643,000

Nearby Population Threat

Likelihood of Exposure:

12. Attractiveness/Accessibility 100 NS

13. Area of Contamination 100 NS

14. Likelihood of Exposure 500 NS

Waste Characteristics:

15. Toxicity (a) NS

16. Hazardous Waste Quantity (a) NS

17. Waste Characteristics 100 NS

Targets:

18. Nearby Individual 1 NS

19. Population Within 1 Mile (b) NS

20. Targets (lines 18 + 19) (b) NS

Nearby Population Threat Score:

21. Nearby Population Threat (lines 14 x 17 x 20) (b) NS
Creese & Cook Tannery (Former) 6 HRS Documentation Record

MAD001031574 September 2012

HRS Table 5-1 [1, Table 5-1]

Soil Exposure Pathway Scoresheet (Concluded)

Soil Exposure Pathway Score

22. Soil Exposure Pathway Score (Ss), (lines [11 +21]/82,500, 

subject to a maximum of 100) (d) 100 68.40

(a) Maximum value applies to waste characteristics category.

(b) Maximum value not applicable.

(c) No specific maximum value applies to factor. However, pathway score based solely on terrestrial 

sensitive environments is limited to maximum of 60.

(d) Do not round to nearest integer
Creese & Cook Tannery (Former) 7 HRS Documentation Record

MAD001031574 September 2012

ACRONYM/ABBREVIATION LIST

° Degrees

‘ Minutes

% Percent

“ Seconds

ABN Acid Base Neutral

ACM Asbestos-containing Material

ACOP Administrative Consent Order with Penalty

AG Attorney General

ATSDR Agency for Toxic Substances and Disease Registry

AUL Activity and Use Limitation

bgs Below ground surface

CERCLA Comprehensive Environmental Response, Compensation, and Liability 

Act

CERCLIS Comprehensive Environmental Response, Compensation, and Liability 

Information System 

CDD Chlorodibenzodioxin

CDF Chlorodibenzofuran

CFR Code of Federal Regulations

CLP Contract Laboratory Program

COC Chain-of-Custody

COD Chemical Oxygen Demand

COPC Contaminants of Potential Concern

CRQL Contract Required Quantitation Limit

CWA Clean Water Act

EPA U.S. Environmental Protection Agency

ESAT Environmental Services Assistance Team

ft Feet

ft2 Square feet

GPS Global Positioning System

H&A Haley & Aldrich

HRS Hazard Ranking System

HpCDD Heptachlorodibenzodioxin

HpCDF Heptachlorodibenzofuran

HxCDD Hexachlorodibenzodioxin

HxCDF Hexachlorodibenzofuran

IHE Imminent Hazard Evaluation

IRA Immediate Response Action

kg Kilogram

L Liter

LSP Licensed Site Professional

MassDEP Massachusetts Department of Environmental Protection

MA DEQE Massachusetts Department of Environmental Quality Engineering

MBTA Massachusetts Bay Transit Authority

MCP Massachusetts Contingency Plan

mg Milligrams
Creese & Cook Tannery (Former) 8 HRS Documentation Record

MAD001031574 September 2012

MGP Manufactured Gas Plant

MW Monitoring Well

NERO Northeast Regional Office

ng Nanograms

No. Number

NOR Notice of Responsibility

NS Not Scored

OHM Oil and/or Hazardous Materials

PA Preliminary Assessment

PAH Polycyclic Aromatic Hydrocarbon

PCB Polychlorinated Biphenyl

PCP Pentachlorophenol

ppb Parts per billion

ppm Parts per million

PRP Potentially Responsible Party

QAPP Quality Assurance Project Plan

RAM Release Abatement Measure

RCRA Resource Conservation and Recovery Act

REW R.E.W. Environmental Consultants

RFI Request for Information

RTN Release Tracking Number

SCDM Superfund Chemical Data Matrix

SI Site Investigation

SIP Site Inspection Prioritization

SIW Site Inspection Worksheet

SOP Standard Operation Procedure

SOW Scope of Work

SR Site Reassessment

START Superfund Technical Assistance and Response Team

SVOC Semivolatile organic compound

T&B Tighe & Bond

TCDF Tetrachlorodibenzofuran.

TCLP Toxicity characteristic leaching procedure

TDD Technical Direction Document

TDL Target Distance Limit

TKN Total Kjedahl Nitrogen

TMDL Total Maximum Daily Load

TPH Total Petroleum Hydrocarbons

VOC Volatile organic compound

W&C Woodard & Curran

XRF X-Ray Fluorescence

yd3 cubic yard
 

 

 

 

 

 

 

 

 

I 

0 0.25 0.5 0.75 1

Miles 

1-Mile Radius 

Most Downstream Probable Point of Entry 

Creese & Cook Co. (Former) 2 Property 

^_ 

^_ 

Most Upstream Probable Point of Entry 

Creese & Cook Co. (Former) 1 Property 

Route 128 

Water Street 

Data Sources: Figure 1 EPA Region I

Superfund Technical Assessment and Topos: MicroPath/USGS 

Response Team (START) III Quadrangle Name(s): Salem, MA 1985 

Site Location Map Contract No. EP-W-05-042 All other data: Weston START (Ref. 11, 12; 19)

TDD Number: 11-12-0002
 

Creese & Cook Tannery (Former) Created by: D. Brammer
 

Danvers, Massachusetts
 Created on: 12 January 2010

Modified by: G. Hornok 

Modified on: 10 August 2012 

HRS Documentation Record

MAD001031574 September 2012 

Creese & Cook Tannery (Former) 
^_

^_

^_

^_

^_

Figure 2

0 50 100 200

Feet

I

LEGEND

Imagery: Massachusetts GIS, 2008 Orthoimagery

All other data: Weston START

 References 11, 12

11-12-0002

D. Brammer

11 January 2010

G. Hornok

10 August 2012

Creese & Cook Tannery (Former)

Danvers, Massachusetts

Site Map

Data Sources:

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on:

Onsite Waste Disposal Cell

55 Clinton Avenue Parcel

33 Water Street Parcel

20 Cheever Street Parcel

MBTA ROW Parcel

Fenced Imminent Hazard Areas

Source Areas

Cemetery

Beamhouse Footprint

On-Site Disposal Cell

^_ Probable Point of Entry (PPE)

PPE Frontage

Source No. 2

Upland Pile

Creese & Cook Tannery (Former)

MAD001031574

HRS Documentation Record

September 2012

Former Beamhouse Footprint

Source No. 3

Former Lagoons

55 Clinton Avenue Parcel

Russell & Endicott Cemetery

Source No. 1

Leather Scrap Pile

Former Landfill Area B

Former Landfill Area A

20 Cheever Street Parcel

33 Water Street Parcel

(Crane River Condominium East)

Source No. 4

Water Street/MBTA Source

MBTA (Former Boston & Maine)

Railroad Right-of-Way Parcel

Former Steam Process Pipe/

Footbridge between Creese & Cook Properties

Crane River

MA Route 128

 Most Upstream PPE

PPE No. 1

Most Downstream PPE

PPE No. 4b

PPE No. 2

PPE No. 3

PPE No. 4a
Figure 3a

0 50 100 150 25

I

Feet

LEGEND

Imagery: Massachusetts GIS, Orthoimagery, 2008

All other data: Weston START, (Ref. 11)

11-12-0002

G. Hornok

17 November 2011

Creese & Cook Tannery (Former) 

Danvers, Massachusetts

Soil/Source Sample 

Location Map A

Data Sources:

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on:

Former Lagoons Imminent Hazard Area

Crane River

Dec. 2011 Soil/Source Sample

May 2011 Soil/Source Sample

55 Clinton Ave Parcel

Source Areas

Fenced Imminent Hazard Areas

Beamhouse Footprint

Cemetery

SO-02

SO-03

SO-04

SO-05/SO-25

SO-5B

SO-16

SO-17

SO-18

SO-19

SO-20/SO-26 (Duplicate)

Upland Imminent Hazard Area

SO-52

SO-64

SO-53

SO-65

SO-54

SO-55

G. Hornok

10 August 2012

Source No. 2

Upland Pile

Source No. 3

Former Lagoons

0

SO-59

SO-61

SO-60

SO-56

SO-58/SO-70

SO-57

Source No. 1 Source No. 1

Leather Scrap Pile

MA Route 128

Former Landfill Area B

Former Landfill Area A

Creese & Cook Tannery (Former)

MAD001031574

HRS Documentation 

September 2012

A
!(

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Figure 3b

0 25 50 100

Feet

I

LEGEND

11-12-0002

G. Hornok

17 November 2011

Creese & Cook Tannery (Former) 

Danvers, Massachusetts

Soil/Source Sample 

Location Map B

Data Sources:

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on:

33 Water Street Parcel

(Crane River Condominiums East)

Crane River

20 Cheever Street Parcel

G. Hornok

10 August 2012

SS-02A/SS-02C

SB-02

SS-03A

SB-03

SS-04A/SS-04C

SS-05A/SS-05C

SB-05A

SS-08A/SS-08C

SS-09A/SS-09C/SS-33A/SS-33C

SB-09A/SB-33A/SB-09B

A SS-21A

B

C

D

A Condominium Building 

Designation

Source No. 4

Water Street/MBTA Source

SS-07A/SS-07C 

SB-07A

SS-18A

SS-10A

SS-23A

SS-11A

SB-11A/SB-11B

SS-06A

SS-20A

SS-24/SS-24C

SS-22A

SO-62

SO-63

!( April 2011 Soil/Source Sample

!( Dec. 2011 Soil/Source Sample

Source Areas

33 Water St Parcel

20 Cheever St Parcel

55 Clinton Ave Parcel

MBTA ROW Parcel

Imagery: Massachusetts GIS, Orthoimagery, 2008

All other data: Weston START, (Ref. 11)

Creese & Cook Co. (Former)

MAD001031574

HRS Documentation Record

September 2012

SS-12A/SS-12C

SB-12
^_

^_

Figure 4a

I

Topos: MicroPath

Quadrangle Name(s): Salem, MA 1985

Imagery: MASSGIS, 1992; 1997

USA Topo Maps 2011 National Geographic Society

NWI Data: USGS, 2010 

All other data: START

11-12-0002

D. Brammer

20 January 2010

B. Mace

12 July 2012

Creese & Cook Tannery (Former)

Danvers, Massachusetts

Target Distance Limit

Data Sources:

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on:

^_

^_

12.32 Mile Arc

2.68 miles to mouth of

Beverly Harbor

BEVERLY

DANVERS

PEABODY

SALEM

MARBLEHEAD

SITE

SITE Porter River

Crane River

Waters River Danvers River

Beverly Harbor

Bass River

North River

Upstream PPE

0.44 miles upstream 

tidal influence

Downstream PPE

Legend

Site Boundary

Source Areas

SWP

^_ Probable Point of Entry (PPE)

0 1 2

Miles

Creese & Cook Co. (Former)

MAD001031574

HRS Documentation Record

September 2012
"

"

""

""

"

"

"

"

"

"

"

"

"

"

"

"

"

"

"

^_

^_

^_

^_

^_

0 125 250 500

Feet

I

Imagery: Massachusetts Orthoimagery, 2008

All other data: Weston START

 References 11, 12

11-12-0002

G. Hornok

17 November 2011

Creese & Cook Tannery (Former) 

Danvers, Massachusetts

Sediment Sample

Location Map

Data Sources:

EPA Region I 

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042

TDD Number:

Created by:

Created on:

Modified by:

Modified on:

Legend

" May 2011 Sediment Sample 

" Dec. 2011 Sediment Sample

Source Areas

PPE Frontage

^_ Probable Point of Entry (PPE)

Figure 4b

SD-50

SD-51

SD-04

SD-57

SD-03

SD-06

SD-56/SD-70

SD-08

SD-10

SD-59

SD-22

SD-23

SD-24

SD-20

SD-61

SD-60

SD-19

SD-18/SD-30

SD-17

SD-15

SD-13

SD-11

G. Hornok

9 April 2012

Source No. 1

Source No. 3

Source No. 4

Downstream Flow

Upstream Flow/

Tidal Influence

Purchase Street

MBTA Right-of-Way Bridge Water Street Bridge

MA Route 128 Bridge

Source No. 2

Most Upstream PPE

Upstream Source No. 1 PPE

Most Downstream PPE

PPE No. 4b

Creese & Cook Co. (Former)

MAD001031574

HRS Documentation Record

September 2012

""

"

"

"

"

"

^_ "

^_

^_

PPE No. 4a

Source No. 1

Source No. 3

Source No. 2

Most Upstream PPE

PPE No. 1

PPE No. 2

PPE No. 3

")

"
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SS-12A 

SS-02A 

SS-26A 

SS-24A/SS-24C 

SO-62 

SO-63 

SS-25A 

SS-03A 

SS-06A 

SS-05A 

SS-04A/SS-04C 

SS-18A 

SS-07A 

SS-20A/SS-20C 

SS-08A 

SS-09A/SS-33A 

SS-21A 

SS-10A 

SS-11A 

SS-23A/SS-35A 

SS-22A 

0 50 100 150 200

Feet 

Figure 5 

I 

LEGEND 

Imagery: Microsoft Bing Maps 2012 

All other data: Weston START (Ref. 12) 

11-12-0002 

G. Hornok 

17 November 2011 

Creese & Cook Tannery (Former)

Danvers, Massachusetts 

Area A Surface Soil

Sample Location Map 

Data Sources: 

EPA Region I

Superfund Technical Assessment and 

Response Team (START) III

Contract No. EP-W-05-042 

TDD Number: 

Created by:

Created on: 

Modified by:

Modified on: 

G. Hornok 

10 August 2012 

A Condominium Building 

Designation 

!( May 2011 Surface Soil Sample 

Dec. 2011 Surface Soil Sample 

Area A 

33 Water St Parcel 

20 Cheever St Parcel 

MBTA ROW Parcel 

Creese & Cook Co. (Former) HRS Documentation Record�

MAD001031574 September 2012
 

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C 

A 

B 
REFERENCES

Ref.

No. Description of the Reference

Creese & Cook Tannery (Former) 16 HRS Documentation Record

MAD001031574 September 2012

[1] U.S. Environmental Protection Agency (EPA). 1990. Hazard Ranking System; Final Rule, 

40 CFR Part 300, Appendix A. The complete Hazard Ranking System; Final Rule is

available from http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS%20 Rule. 14 

December. Excerpt. 96 pages. 

[2] Reference Number Reserved.

[3] Reference Number Reserved. 

[4] U.S. Environmental Protection Agency (EPA). 2012. Superfund Chemical Data Matrix 

(SCDM). Available from http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 31 

March. Excerpt. 20 pages.

[5] Mace, B. Weston Solutions, Inc., Superfund Technical Assistance and Response Team III 

(START). 2012. Project Note, Creese & Cook Site, RE: Latitude/Longitude Calculations. 

TDD No. 11-12-0002. 9 April. 2 pages.

[6] U.S. Environmental Protection Agency (EPA). 2012. Superfund Information Systems, 

Creese & Cook Co (Former) 1 Site Information. Available from 

http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0100380. Internet accessed 23 

July. 2 pages.

[7] U.S. Environmental Protection Agency (EPA). 2012. Superfund Information Systems, 

Creese & Cook Co (Former) 2 Site Information. Available from 

http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0105956. Internet accessed 23 

July. 2 pages.

[8] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2011. Site Assessment Program Site-Specific Quality Assurance Project Plan for 

Surface Soil/Source and Sediment Sampling, Creese & Cook Co. (Former) 1 Site 

Reassessment, Danvers, Massachusetts. TDD No. 09-11-0005. 18 April. 90 pages.

[9] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2011. Creese & Cook Co. (Former) 1 Site-Specific Quality Assurance Project 

Plan (QAPP) Addendum for Additional Soil/Source and Sediment Sampling. TDD No. 01-

09-11-0005. 22 November. 20 pages.

[10] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2011. Site Assessment Program Site-Specific Quality Assurance Project Plan for 

Surface and Subsurface Soil/Source Sampling, Creese & Cook Co. (Former) Combined 2 

Preliminary Assessment/Site Inspection, Danvers, Massachusetts. TDD No. 10-03-0005. 21 

January. 83 pages.

[11] Weston Solutions, Inc. 2011. Field Logbook Notes, Creese & Cook Co. (Former) 1. TDD 

No. 09-11-0005. 27 pages.

[12] Weston Solutions, Inc. 2011. Field Logbook Notes, Creese & Cook Co. (Former) 2. TDD 
REFERENCES

Ref.

No. Description of the Reference

Creese & Cook Tannery (Former) 17 HRS Documentation Record

MAD001031574 September 2012

No. 10-03-0005. 17 pages.

[13] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2012. Trip Report for Creese & Cook Co. (Former) 1 Site Reassessment, 

Danvers, Massachusetts. TDD No. 09-11-0005. 5 July. 136 pages.

[14] Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2011. Trip Report for Creese & Cook Co. (Former) 2 Combined Preliminary 

Assessment/Site Investigation, Danvers, Massachusetts. TDD No. 10-03-0005. 15 

September. 199 pages. 

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[134] Massachusetts Department of Environmental Protection (MassDEP). 2008. Meeting 

Attendance Sheet, Enforcement Conference – Former Creese & Cook Tannery. 5 

September. 1 page.

[135] Decoulos, James J., Decoulos & Company- 2009. Email Letter Re: Former Creese & Cook 

beam house site, 25 Clinton Avenue, Danvers; MassDEP RTNs 3-12711, 3-26474 and 

Commonwealth v. Decoulos, Suffolk Superior Court Civil Action No. 09-2439-E. 30 

December. 12 pages.

[136] Reference Number Reserved.
REFERENCES

Ref.

No. Description of the Reference

Creese & Cook Tannery (Former) 27 HRS Documentation Record

MAD001031574 September 2012

[137] MassDEP (Massachusetts Department of Environmental Protection). 2008. RE: Danvers –

Former Creese & Cook Tannery, 55 Clinton Avenue, Request for Property Access. 22 

September. 2 pages.

[138] Reference Number Reserved.

[139] Massachusetts Department of Environmental Protection (MassDEP). 2006. Memorandum. 

RE: Danvers/Creese & Cook Tannery, DEP RTN 3-0303, Technical Evaluation. 19 May. 6 

pages.

[140] U.S. Environmental Protection Agency. 1996. Using Qualified Data to Document an 

Observed Release and Observed Contamination. November. 18 pages. 

[141] U.S. Environmental Protection Agency. 2009. Analytical Services Branch, Statement of 

Work for Analysis of Chlorinated Dibenzo-p-dioxins (CDDs) and Chlorinated 

Dibenzofurans (CDFs), Multi-Media, Multi-Concentration, DLM02.2. December. Excerpt. 

4 pages. 

[142] U.S. Environmental Protection Agency. 2010. Contract Laboratory Program, Statement of 

Work for Inorganic Superfund Methods, (Multi-Media, Multi-Concentration), ISM01.2. 

January. Excerpt. 3 pages

[143] Massachusetts Department of Environmental Protection (MassDEP). 2007. IRA 

Conditional Approval Letter and Designation of Interim Deadlines 3-12711 & 3-26474 to 

Orchard Farm Trust. 11 January. 5 pages.

[144] Massachusetts Department of Environmental Protection (MassDEP). 2007. Report, North 

Shore Coastal Watersheds 2002 Water Quality Assessment Report. Report Number 93-AC2. March. 198 pages.

[145] Massachusetts Division of Watershed Management. 2010. Massachusetts Year 2010 

Integrated List of Waters, Proposed Listing of the Condition of Massachusetts’ Waters 

Pursuant to Sections 305(b), 314 and 303(d) of the Clean Water Act. April. 157 pages.

[146] State of Massachusetts. 314 CMR 4.00: Division Of Water Pollution Control, 

Massachusetts Surface Water Quality Standards. 19 pages.

[147] Massachusetts Department of Environmental Protection (MassDEP). Draft Pathogen 

TMDL for the North Coastal Watershed. 84 pages. 

[148] Massachusetts Department of Environmental Protection (MassDEP). 1995. Memorandum 

for the Record, Re: Danvers, RTN 3-0303, Creese & Cook Tannery – 25 Clinton Ave, 6 

November. 6 pages.

[149] Massachusetts Division of Marine Fisheries, Department of Fish and Game. 2008. 

Technical Report TR-33, An Evaluation of the Use of Egg Transfers and Habitat

Restoration to Establish an Anadromous Rainbow Smelt Spawning Population. July. 19 

pages. 
REFERENCES

Ref.

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Creese & Cook Tannery (Former) 28 HRS Documentation Record

MAD001031574 September 2012

[150] Massachusetts Division of Marine Fisheries, Department of Fish and Game. 2006. 

Technical Report TR-30, Rainbow smelt (Osmerus mordax) spawning habitat on the Gulf 

of Maine coast of Massachusetts. December. 180 pages.

[151] Kelly, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START). 2011. Project Note. Documentation of Fishing in the Crane River. TDD No. 09-

11-0005. 9 August. 2 pages.

[152] Kelly, J. Weston Solutions, Inc., Superfund Technical Assessment and Response Team III 

(START), 2011. Project Note: Documentation of Fishing in the Crane River. 9 August. 1 

page.

[153] SP, Inc. 1984. Subsurface Hazardous Waste Investigations at Crane River Real Estate 

Trust, 26 Water Street, Danvers, MA. 29 October. 23 pages.

[154] U.S. Environmental Protection Agency. 1981. Review of RCRA Permit Part A (with 

attached maps). 16 June. 4 pages.

[155] Town of Danvers Office of Human Services. 1980. Report of Alleged Major Code 

Violations, 33 Water Street. 31 January. 2 pages.

[156] Southern Essex District Registry of Deeds. 1987. Master Deed, Crane River Condominium 

(East), Plan Book 9131, Plan 491. 13 August. 24 pages.

[157] Massachusetts Department of Environmental Protection (MassDEP). 2012. Reportable 

Release Lookup, Available at http://public.dep.state.ma.us/SearchableSites/Search.asp. 

Internet accessed 5 April. 6 pages. 

[158] Massachusetts Department of Environmental Protection (MassDEP). 1995. Supplemental 

Risk Reduction Transmittal Form. 24 Water Street, Danvers, MA. 6 February. 219 pages.

[159] Haley & Aldrich, Inc. 1999. Phase II Comprehensive Site Assessment, Former 

Manufactured Gas Plant Site, 19 & 21 Merrill Street, Danvers, MA. RTN 3-11970. 

September. 662 pages.

[160] Tighe & Bond. 2010. Release Abatement Measure Plan, Crane River Seawall Repair 

Project, Danvers, Massachusetts. August. 101 pages.

[161] TetraTech. 2011. Phase II – Comprehensive Site Assessment and Phase III Evaluation of 

Comprehensive Remedial Action Alternatives, Route-128 at High Street, Danvers, 

Massachusetts. 2 December. 138 pages.

[162] Tetra Tech. 2011. Phase I Initial Site Investigation and Tier Classification, Route-128 at 

High Street, Danvers, Massachusetts. 16 July. 852 pages.

[163] Hornok, G. Weston Solutions, Inc., Superfund Technical Assistance and Response Team 

III (START). 2012. Project Note, Creese & Cook (Former). Distances between Surface Soil 

Sample locations and residential buildings. 27 March. 7 pages.
REFERENCES

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MAD001031574 September 2012

[164] Agency for Toxic Substances & Disease Registry (ATSDR). 2010. Public Health 

Assessment for the Mohawk Tannery Site, Nashua, New Hampshire. 19 April. 32 pages.

[165] Agency for Toxic Substances & Disease Registry (ATSDR). 2010. Public Health 

Assessment for Pownal Tannery, Pownal, Vermont. 31 March. 17 pages.

[166] Food and Agricultural Industry. 1997. Section 9.15, Leather Tanning. June. Available from 

http://www.epa.gov/ttnchie1/ap42/ch09/final/c9s15.pdf. Excerpt. 5 pages.

[167] Blacksmith Institute. World’s Worst Pollution Problems Report 2010. Top Six Toxic 

Threats. 76 pages. 

[168] Agency for Toxic Substances & Disease Registry (ATSDR). National Drinking Water 

Regulations, Technical Fact Sheet on Barium. Excerpt. 4 pages.

[169] Baker, D. International Labour Organization’s Encyclopedia of Occupational Health and 

Safety. Excerpt, Chapter 88. Tanning and Leather Finishing. Available at 

http://www.ilo.org/safework_bookshelf/english?content&nd=857171045. Internet accessed on 9 

April 2012. 5 pages.

[170] Patriot Properties, Inc. 2010. Town of Danvers Property Card. 

[171] Nuss, J.M., ARCADIS BBL. 2007. Class A-3 Partial Response Action Outcome Statement, 

Class C-1 Partial Response Action Outcome Statement and Activity and Use Limitation, 

Former Danvers Manufactured Gas Plant. 12 June. 22 pages.

[172] Wright, W. Town of Danvers Department of Health & Inspections. 1977. Report of Alleged 

Major Code Violation. 4 January. 2 pages.

[173] National Archives and Records Administration (NARA). 2002. U.S. Code, Title 42: The 

Public Health and Welfare, Chapter 103: Comprehensive Environmental Response, 

Compensation, And Liability Act Of 1980 (Superfund), Section sections 9601 - 9675. 176 

pages.
Creese & Cook Tannery (Former) 30 HRS Documentation Record

MAD001031574 September 2012

SITE SUMMARY – Creese & Cook Tannery (Former)

The Creese & Cook Tannery (Former) facility is located along the east and west banks of the Crane River 

in Danvers, Essex County, MA, along Clinton Avenue, Cheever and Water Streets (see Figures 1 and 2) 

[6; 7; 18; 109]. The geographic coordinates of the Creese & Cook Tannery (Former) site, as measured 

from the approximate location where the steam water/pedestrian footbridge joins the eastern side of the 

former facility [Source Number (No.) 4], are 42° 33' 11.2" north latitude and 70° 55' 36.2" west longitude 

(see Figures 1 and 2) [5-7]. According to available file documentation, from approximately the early 

1900s to 1981, a leather tannery was operated under the name of Creese & Cook Company (Co.) on the 

east and west banks of Crane River on the facility properties [17, pp. 1-3; 30; 31; 32, p. 6; 36, p. 1; 37; 

129, pp. 106-128; 135, pp. 4, 7]. 

The Creese & Cook Tannery (Former) site consists of four sources [two pile sources (Leather Scrap Pile 

and the Upland Pile), one surface impoundment source (Former Lagoons), and one contaminated soil 

source (Water Street/MBTA Source)], which were documented and sampled as part of the EPA SR of the 

Creese & Cook Co. (Former) 1 property and the EPA SI of the Creese & Cook Co. (Former) 2 property 

(see Figure 2) [see Source Characterization sections of this HRS Documentation Record]. These sources 

have been documented to contain six dioxin/furan congeners (1,2,3,6,7,8-HxCDD; 1,2,3,7,8,9-HxCDD;

1,2,3,4,6,7,8-HpCDD; 2,3,7,8-TCDF; 2,3,4,6,7,8-HxCDF; and 1,2,3,4,6,7,8-HpCDF) and four total 

metals (arsenic, barium, chromium, and mercury) (see Source Characterization sections of this HRS 

Documentation Record). As part of this HRS Documentation Record, a release of five dioxin/furan 

congeners (1,2,3,6,7,8-HxCDD; 1,2,3,7,8,9-HxCDD; 2,3,7,8-TCDF; 2,3,4,6,7,8-HxCDF; and 

1,2,3,4,6,7,8-HpCDF) and two total metals (chromium and mercury) from on-site sources to the surface 

water pathway (the adjacent Crane River) has been documented (see Surface Water Overland/Flood 

Migration Pathway section of this HRS Documentation Record). Within the zone of documented 

contamination attributable to the site, the Crane River is documented to be fished for human consumption, 

contain 1.287 miles of wetlands frontage and be a Clean Water Act protected water body. In addition, an 

area of observed contamination (Area A) associated with a condominium property (a portion of Source 

No. 4) has been documented, and 52 Level I Targets identified (see Soil Exposure Pathway section of this 

HRS Documentation Record). 

Facility Operations

In early 1903, the Creese & Cook Co. was established at 33 Water Street (east side of the Crane River) 

with the construction of a new tannery factory building [32, p. 6]. Background information indicates that 

a large settling tank was built under the building with direct flow of all liquid waste to the river (here 

assumed to be the Crane River) [32, p. 6]. A 1910 annual report to the Board of Health of Massachusetts 

concerning treatment of liquid (settling tank) waste, prior to discharge into the Crane River, included an 

estimate of up to 60,000 gallons of waste per day from the Creese & Cook Tannery facility [35, p. 2]. In 

about 1906, the Creese & Cook Co. began production of colored leathers, first using a vegetable tan and 

then switching to the chrome process for both colored and black leathers [32, p. 7]. Operations on the east 

side of the Crane River continued to expand up until 1914, when a new brick beamhouse was constructed,

located across the Crane River (west side) at 55 Clinton Avenue and next to the old Endicott burying 

ground, also known as the Endicott-Russell Family Cemetery [11, p. 21; 18; 31; 32, pp. 7-8]. A 

footbridge was constructed to provide for foot traffic between the two operations as well as to provide a 

means for which steam electric power and water would travel between the main plant to the new 

beamhouse [32, p. 8]. Throughout operations on both sides of the Crane River, the Creese & Cook Co. 

employed chrome tanning techniques to make their patented Cresco waterproof leather, and Spartan Calf 

leather [32, p. 8]. In 1981, Creese & Cook Co. went bankrupt and leased the facility to the Danversport 

Tanning Co. [33, p. 1]. The Danversport Tanning Co. ceased tanning operations at the property in spring 

1983 [33, p. 1]. During the end of tannery operations by the Danversport Tanning Company, wastewater 
Creese & Cook Tannery (Former) 31 HRS Documentation Record

MAD001031574 September 2012

generation was approximately 235,000 gallons per day (and up to an estimated 400,000 gallons per day 

during maximum production), which discharged to a municipal sewer system after neutralization [34, p. 

7].

According to a MA Department of Environmental Quality Engineering (DEQE) representative in a 1984 

site walk summary, operations at the Creese & Cook Co. facility properties included beamhouse 

operations at the Clinton Avenue parcel, where raw hides were brought, dechemicalized, and treated to 

remove hair [33, p. 1]. Once the hides were processed, they were sent to the main building (east side of 

the Crane River), where they were dyed and cut [33, p. 1]. The beamhouse had four concrete settling 

basins which, during operations, contained waste material such as hair, skin, chrome, and sulfides [33, p. 

1]. According to reports, prior to 1975 the liquid effluent was discharged directly to the Crane River, 

while after 1975 the effluent and sludge were deposited to the municipal sewer and on-site lagoons [33, p. 

1; 35, pp. 2-3; 39, p. 2; 43, p. 1; 112, p. 5; 139, p. 1]. 

A summary, provided by Woodard & Curran (W&C) in 2006, indicated that Creese & Cook Co. operated 

a tannery on portions of both sides of the Crane River [113, p. 5]. The report indicated that tanning and 

finishing was performed on the eastern side of the river, while beamhouse operations (consisting of initial 

treatment, dehairing, and bating) occurred on the western side of the Crane River [113, p. 5]. W&C

summarized the typical leather tanning operations as follows: ‘Initial treating and dehairing operations for 

tanning typically involve soaking the skins to treat them for infestation and to prepare the skins for 

mechanical removal of hair. Soaking was typically done with either organic acid solutions or arsenic 

solutions. These solutions frequently contained phthalates, which were added as a penetrant. Phthalates 

were also used in the finishing process in lacquers to aid in penetration into the chromed skins. Final 

dehairing typically involves scraping of the skins in the presence of a strong basic solution or oxidant 

solution. Bating is primarily a pH adjusting step to neutralize and soften the skins prior to chroming, and 

was accomplished in an adjusting bath. All of the solution baths would have accumulated solids and/or 

lost their strength after a period of time, and would have been discharged to on-site lagoons prior to 

replenishing the baths. Discharge from dehairing and bating operations was directed to on-site lagoons 

located to the east of the beamhouse, before decanting into the Crane River through a subsurface 

discharge pipe’ [113, p. 5]. 

In July 1981, Creese & Cook Co. went bankrupt and the property was rented to Danversport Tannery, 

who operated on the facility until 1983 [33, p. 1].

Facility Investigations

Available documentation (see Table 1 below) indicates that one investigation was completed while the 

facility was operational (EPA Preliminary Assessment). Subsequent investigations completed for the 

potentially responsible party (PRP) by SP, Inc. from May 1984 to June 1992 dealt with the initial 

characterization of the facility (both eastern and western banks of the Crane River), the development of 

plans to remove documented raw waste materials on the western facility property in preparation for 

redevelopment, the construction of an on-site containment cell northwest of the former beamhouse to 

contain waste materials from the western facility property, post-construction sampling of areas formerly 

containing waste materials which were excavated during construction of the containment cell, and 

characterization of the former beamhouse. Additional investigations were completed for the PRP, after 

construction of the containment cell, to document areas of hazardous substances that still remained that 

would require action if the western facility property were to be redeveloped for use as a condominium. In 

addition, an EPA Site Inspection Prioritization (SIP) was conducted of the western facility following 

closure. Citing inaction on the part of the property owner to take the necessary steps to protect the public 

and clean up the hazardous waste on the western facility property, the State of MA Attorney General’s 

office filed a suit in June 2009 [118; 119]. An EPA Site Reassessment (SR) of the western portion of the 
Creese & Cook Tannery (Former) 32 HRS Documentation Record

MAD001031574 September 2012

property was initiated in November 2009, while EPA Preliminary Assessment (PA) and Site Inspection 

(SI) studies of the eastern facility were initiated in March 2010. The following table lists investigations 

and inspections mentioned above that occurred at the former Creese & Cook Co. facility and will be 

referenced briefly in the summary below. Unless otherwise noted, the investigation and/or reconnaissance 

was performed on the western facility parcel.

TABLE 1: Summary of Previous Investigations

Company/

Agency Investigation

Document 

Date Task

Samples 

Collected

Hazardous 

Substances 

Detected References

EPA Preliminary 

Assessment

1981 Site 

Recon/Respond 

to Complaint

N/A Chromium 

(suspected)

39, pp. 3-4; 

40, pp. 1-4

SP, Inc. Initial Site 

Investigation

{on behalf of PRP}

May 1984 Site 

Reconnaissance/ 

Sample 

collection

Test pits, soil,

ground water, 

seeps, and 

abandoned tank 

and container 

contents

Chromium

Lead

VOCs

H2S

34, pp. 13-19; 

36, p. 2-3

SP, Inc. Initial Site 

Investigation

(eastern facility 

properties) 

{on behalf of PRP}

October 1984 Subsurface 

Hazardous 

Waste 

Investigation

Soil Arsenic 

Chromium 

Mercury

153

ground water VOC 153

MA DEQE Site Investigation/

Updated 

Preliminary 

Assessment

March 1985 Further 

investigation of 

property for 

redevelopment

N/A N/A 36, pp. 2-3; 

42, p. 1-2

SP, Inc. Supplemental 

Investigation

{on behalf of PRP}

December 

1985

Evaluate options 

for land 

development/ 

collect samples

Soil/waste Chromium 34, p. 35-39

Ground water/ 

seeps

Arsenic

Sediment Chromium

SP, Inc. Site Investigation

{on behalf of PRP}

September 

1986

Investigation of 

lagoons/collect 

samples

Soil Chromium 43, p. 4-8

SP, Inc. Construction/

Removal Actions

{on behalf of PRP}

Dec. 1989 to 

June 1990 

Construction of 

on-site 

containment cell/ 

excavation of 

waste and sludge

N/A N/A 46, p. 1; 48, 

p. 11; 123, p. 

3 

SP, Inc. Well Installation

{on behalf of PRP}

February to 

March 1990

Sample 

collection 

following 

installation

Ground 

water/Seep

Lead

Chromium

48, pp. 6, 13-

23, 43; 49, p. 

1;

SP, Inc. Chapter 21E Site 

Assessment

{on behalf of PRP}

April 1990 Post-Excavation 

Sample 

Collection

Soil Lead

Chromium

48, pp. 49-50; 
Creese & Cook Tannery (Former) 33 HRS Documentation Record

MAD001031574 September 2012

TABLE 1: Summary of Previous Investigations (Continued)

Company/

Agency Investigation Date Task

Samples 

Collected

Hazardous 

Substances 

Detected References

SP, Inc Chapter 21E Site 

AssessmentBeamhouse

{on behalf of PRP}

June 1992 Sample 

Collection

Soil, wipe, and pit 

debris samples

Chromium 48, pp. 24-30 

REW 

Environmental 

Consultants

Initial Site

Characterization

{on behalf of PRP}

July 1995 Satisfy MCP and 

subsurface 

investigation

Soil TPH

VOCs

ABN

Arsenic

Chromium

47, p. 13, 30-

33 

REW 

Environmental 

Consultants

Supplemental 

Sampling Event

{on behalf of PRP}

August 1995 Delineate 

horizontal extent 

of arseniccontaminated 

soil

Soil Arsenic

Chromium

93, pp. 4, 6 

MassDEP Site Inspection November 

1995

Documentation 

of Site 

Conditions

N/A N/A 126, pp. 1-5

Stone and 

Webster

EPA Site 

Inspection 

Prioritization

October 1996 Review of 

Source 

Areas/Collection 

of samples

Surface Water Arsenic, 

Chromium, 

Lead, Mercury

95, pp. 4-20, 

26-33

Sediment Arsenic, Barium, 

Cadmium, 

Chromium, 

Lead, Mercury

REW 

Environmental 

Consultants

Supplemental Site 

Characterization

{on behalf of PRP}

June 1997 Collect soil 

samples, 

determine 

impacts to 

ground water, 

and evaluate 

exposure

Soil Arsenic 97, pp. 11, 

24-25 

Supplemental 

Sampling Event

{on behalf of PRP}

Dec. 1997 to 

Jan. 1998

Sample 

collection/ 

borings

Soil and ground 

water

Arsenic 103, pp. 15, 

18; 

Supplemental 

Sampling Event

{on behalf of PRP}

September 

2001

Sample 

Collection for 

Danvers Board 

of Health

Sediment Sulfides

Arsenic, Barium, 

Cadmium, 

Chromium, 

Lead, Mercury 

106, pp. 2-4, 

8 

GFS Sampling Event

{on behalf of PRP}

April 2005 Sample 

Collection along 

Crane River

Sediment Arsenic 129, pp. 2, 5, 

8 
Creese & Cook Tannery (Former) 34 HRS Documentation Record

MAD001031574 September 2012

TABLE 1: Summary of Previous Investigations (Concluded)

Company/

Agency Investigation Date Task

Samples 

Collected

Hazardous 

Substances 

Detected References

W&C Revised Immediate 

Response Actions/

Imminent Hazard 

Evaluation

{on behalf of PRP}

November 

2006

Sample 

Collection

Soil Arsenic, 

Chromium, 

Dioxins, 

Hexavalent Cr

112, pp. 12-

13, 19-24; 

113, pp. 10-

12, 19-43

Sediment Arsenic 

Dioxins

Building Debris Asbestos

Supplemental 

Sampling Event

{on behalf of PRP}

June 2007 Assess 

contaminant 

concentrations in 

uplands

Soil Arsenic 131, pp. 6-9

MassDEP Determination of 

AsbestosContaining 

Materials

September 

2008

Samples 

collected from 

beamhouse 

demolition 

debris

Building Debris 

(Black mastic)

Chrysotile fibers 122; 137

Weston 

Solutions, Inc.

START

EPA Site 

Reassessment

April 2010 to 

December 

2011,

August 2012

On-site 

reconnaissances; 

Samples 

collected from 

source areas and 

the Crane River

Soils Arsenic, Barium, 

Chromium, 

Mercury, 

Dioxin/furan 

congeners

15, pp. 5-8, 

39-98

Sediments Chromium, 

Mercury, 

Dioxin/furan 

congeners

15, pp. 5-8, 

104-111

Weston 

Solutions, Inc.

START

EPA Site 

Inspection

(eastern facility 

properties)

August 2010 

to April 2011,

July 2012

On-site 

reconnaissances; 

Samples 

collected from 

source areas 

Soils Arsenic, Barium, 

Chromium, 

Mercury, 

Dioxin/furan 

congeners

16, pp. 5, 9, 

23-143

EPA = Environmental Protection Agency.

MA DEQE = Massachusetts Department of Environmental Quality and Engineering. 

MassDEP = Massachusetts Department of Environmental Protection.

PRP = Potentially Responsible Party.

MCP = Massachusetts Contingency Plan.

VOC = Volatile Organic Compound. H2S = Hydrogen Sulfide.

TPH = Total Petroleum Hydrocarbon. ABN = Acid Base Neutral.

N/A = Not Applicable. 

Numerous investigations and inspections were conducted at the facility after construction of the on-site 

containment cell in 1990 (see above summary table). These activities, portions of which are summarized 

in the above table, focused on the following: the presence of hazardous substances, including chromium, 

within the beamhouse on the west side of the Crane River; contamination, including arsenic and 

chromium, still existing in the two landfill areas and former sludge lagoons after construction of the onsite containment cell; the existence of hazardous substances, including arsenic and chromium, in other 
Creese & Cook Tannery (Former) 35 HRS Documentation Record

MAD001031574 September 2012

areas planned for housing development on the west side of the Crane River; plans for containment of the 

documented hazardous waste upon redevelopment of the facility on the west side of the Crane River into 

condominiums; removal of documented waste and contaminated soils from areas on the facility property; 

adherence to the Massachusetts Contingency Plan (MCP) and the protection of populations from 

contamination that was present on the facility; site-related contamination, including arsenic, chromium, 

and dioxins, within the Crane River sediments and surface water; the discovery of dioxin-contaminated 

soils on the facility; and the presence of asbestos-containing material (ACM) within debris from the 

demolished beamhouse [47, pp. 13-17, 26-33, 108; 48, pp. 24-30, 49-50; 92, p. 2; 93, pp. 3-6, 16; 94; 95, 

pp. 4-36; 97, pp. 11-13, 19-20, 24-25, 48-50; 98, pp. 1-32; 99; 100, pp. 18-27; 101, pp. 29-35; 103, pp. 5-

13, 15-18, 21, 23-26, 100-118; 106, pp. 2-4, 8; 108; 112, pp. 8-12, 19; 113, pp. 10-12; 114; 117-120; 121, 

pp. 1-3; 122; 125, p. 1; 127, pp. 1-3; 129, pp. 1-5, 8; 131, pp. 13, 36-50; 132, p. 25; 133-134; 137; 139; 

143, p. 1-5].

The most recent investigations of the Creese & Cook Tannery (Former) facility were an EPA SI on the 

eastern side of the Crane River and an EPA SR on the western side. Activities performed as part of the 

EPA SI involved source sampling which documented hazardous substances in both surface and 

subsurface soils [16]. Activities conducted as part of the EPA SR included source sampling as well as the 

sampling of Crane River sediments [15]. 
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 36 HRS Documentation Record

MAD001031574 September 2012

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source: Leather Scrap Pile 

Number of Source: Source No. 1

Source Type: Pile

Description and Location of Source:

Leather Scrap Pile (Pile - Source No. 1) is located on the former facility property located on the western 

side of the Crane River, depicted on the Town of Danvers, MA Tax Assessor’s Map No. 59, as Lot No. 

2B (see Figure 2) [6 p. 1; 17, p. 3; 170]. Source No. 1 is located on the northern portion of the facility 

property, adjacent to the Crane River (see Figure 2) [11, p. 17]. The geographic coordinates of the Leather 

Scrap Pile, as measured from its approximate center, are 42° 33′ 19.5′′ north latitude and 70° 55′ 50.3′′ 

west longitude (see Figures 1 and 2) [20]. 

As part of an on-site reconnaissance conducted during the EPA SR on 2 November 2011, the Leather 

Scrap Pile was observed [11, p. 17]. The leather scraps were observed to be protruding from the 

riverbank; and protruding from a soil pile extending from the fenced Former Landfill Area B to the Crane 

River and the northeastern property marker [11, p. 17; 22]. Leather scraps were observed eroding out of 

the bank of the river and depositing directly into the river sediments [11, p. 17; 22]. The location of 

exposed leather scraps was mapped using a global positioning system (GPS) unit to define the areal extent 

of the pile, which covers 7,534 square feet (ft2

) [11, pp. 17-18; 21].

The Leather Scrap Pile is located northwest of the area referred to as Former Landfill Area B (see Figure 

2) [11, p. 17; 13, pp. 5, 31-32, 45-46]. As part of an appendix to the Engineering Report completed by SP, 

Inc. in May 1984, a trenching test pit (Trench No. 7) excavated as part of the investigation indicated the 

presence of leather scraps [34, pp. 1, 44-45 (Appendix Figures 5 and 6)]. A sample of leather scraps 

collected as part of the monitoring well installation within Trench No. 7 indicated the presence of 

elevated concentrations of arsenic and chromium (reference indicates that the sample collected from 

Trench No. 7 is mislabelled as Trench No. 6) [34, pp. 40, 45, 48 (Appendix Table 3)]. Based on 

observations made during on-site reconnaissances as part of the EPA SI, the removal conducted at Former 

Landfill Area B created a depression covered with a coarse gravel-type material [11, pp. 1-2, 11]. As part 

of the June 1997 Supplemental Site Characterization Report completed by R.E.W. Environmental 

Consultants (REW), an area described as being associated with Landfill Area B, in the wooded area north 

of the cemetery, contained remnants consisting of leather scraps and organic debris on the surface to a 

depth of five feet below ground surface [97, pp. 38-39]. REW indicated that the area of the Leather Scrap 

Pile, on the bank of the Crane River, measured approximately 40 feet long, 25 feet wide, and was 4 feet 

thick, and required further remedial action [97, p. 39]. In addition, REW concluded that this area appeared 

to correspond with the extent of excavation and/or cleanup by SP, Inc. (SP) in 1990 (here assumed to be 

the On-Site Containment Cell construction) [97, p. 39]. A Supplemental Phase IV Report completed by 

REW indicates the presence of solid waste consisting of hide scraps in the wooded portion of Landfill 

Area B [103, p. 5]. A 16 August 2007 Massachusetts Contingency Plan Immediate Response Action 

Status Report figure completed by W&C after the removal action for Landfill Area B, indicated the 

presence of ‘Area B tannery wastes designated for off-site disposal’ in the area of the Leather Scrap Pile 

[131, p. 58 (Figure 3)]. 
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 37 HRS Documentation Record

MAD001031574 September 2012

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Source Samples:

On 5 December 2011, as part of the EPA SR, source sampling activities for the Leather Scrap Pile were 

conducted [11, pp. 20-24; 13, pp. 36-41]. The source samples were collected in accordance with the EPAapproved Site-Specific Quality Assurance Project Plan (QAPP), dated 18 April 2011, and the SiteSpecific QAPP Addendum, dated 22 November 2011 [8, pp. 32, 34-37; 9, pp. 2-3, 8 (Figure 3), 11-12; 

13, p. 37]. As part of the Leather Scrap Pile characterization, seven source samples (SO-56, SO-57, SO58, SO-59, SO-60, SO-61, SO-70) were collected from various locations throughout the pile (see Figure 

3a) [11, pp. 22, 25; 13, pp. 38-39, 67-68, 70]. 

Table 2 – Source Sample Description

Sample 

ID Sample Description Reference

SO-56

Dark brown, silt, trace fine-to-coarse sand, trace debris (metal and leather scraps), trace 

organics. 26, p. 28

SO-57 Reddish brown, organic rich (leather and organic fibers) silt. 26, p. 29

SO-58/

SO-70

Dark brown, organic rich (organic fibers, rootlets) silt, trace fine-to-medium sand, leather 

scraps. 26, p. 30

SO-59 Dark brown silt, some fine-to-coarse sand, little organics, trace clay. 26, p. 31

SO-60

Brown, organic rich silt, little fine-to-coarse sand, trace debris (chalky-like substance), dark 

purple leather scraps 26, p. 32

SO-61

Dark brown silt and fine-to-coarse sand, little organics, trace debris (metal), trace fine gravel, 

little organics 26, p. 33

The seven source samples (SO-56, SO-57, SO-58, SO-59, SO-60, SO-61, and SO-70) were submitted to 

Contract Laboratory Program (CLP) laboratories for dioxin/furan analyses following DLM02.2, and for 

total metals analysis following ISM01.3 [11, pp. 22, 25, 27; 13, pp. 38-39, 45, 67-68, 70; 28, p. 11; 29, p. 

7; 45; 50, pp. 1, 5-6, 8; 57, pp. 1, 13-15; 71, pp. 6-7, 16-21, 24, 108-119, 124-125; 78, pp. 5-7, 16-18, 20, 

91-96, 101]. Chains-of-custody (COCs) for all source samples collected as part of the 2011 EPA SR and 

presented in this HRS Documentation Record are provided in References 28 and 29. The applicable COC 

sections for the Source No. 1 samples and all corresponding sample identifiers are provided in available 

COC, field notes reference documentation, and sample crosswalk [11, pp. 22, 25; 13, pp. 38-39, 67-68, 

70; 26, pp. 28-33; 28, p. 11; 29, p. 7; 45]. The dioxin/furan analytical results were manually validated at a 

stage 4 level in accordance with the criteria specified in the USEPA SOW DLM02.2 and EPA Region I’s 

Environmental Services Assistance Team (ESAT) Dioxin/Furan Data Validation SOP ESAT-01-0007 

[50, p. 1]. The total metals analytical data were evaluated on a Tier II level in accordance with the Region 

I Tiered Organic and Inorganic Data Validation Guidelines dated November 2008 [57, p. 1]. The 

validation of dioxin/furan and total metals analytical results was conducted independently by designated 

chemists who were not involved in the sample collection and HRS evaluation [11, pp. 22, 25, 27; 13, pp. 

38-39, 45, 67-68, 70; 50, pp. 1-3; 57, pp. 1-8]. For the purposes of the Source No. 1 evaluation and the 

HRS documentation record, analytical results of seven source samples confirm the presence of the 

following hazardous substances: six dioxin/furan congeners (1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 

1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, and 1,2,3,4,6,7,8-HpCDF) and four total 

metals (arsenic, barium, chromium, and mercury) (see Table 3 of this HRS documentation record). 

Source No. 1 has been documented to contain hazardous substances as defined by the HRS [1, p. 51586; 

173, pp. 493, 500-501]. 
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 38 HRS Documentation Record

MAD001031574 September 2012

Among the seven selected source samples: 1,2,3,6,7,8-HxCDD was detected at a maximum concentration 

of 20,200 nanograms per kilogram (ng/Kg) in source sample SO-70; 1,2,3,7,8,9-HxCDD was detected at 

a maximum concentration of 2,650 ng/Kg in source sample SO-70; 1,2,3,4,6,7,8-HpCDD was detected at 

a maximum concentration of 769,000 ng/Kg in source sample SO-70; 2,3,7,8-TCDF was detected at a 

maximum concentration of 12.4 ng/Kg in source sample SO-61; 2,3,4,6,7,8-HxCDF was detected at a 

maximum concentration of 1,360 ng/Kg in source sample SO-70; 1,2,3,4,6,7,8-HpCDF was detected at a 

maximum concentration of 136,000 ng/Kg in source sample SO-70; arsenic was detected at a maximum 

concentration of 565 milligrams per kilogram (mg/Kg) in source sample SO-60; barium was detected at a 

maximum concentration of 1,020 mg/Kg in source sample SO-57; chromium was detected at a maximum 

concentration of 20,500 mg/Kg in source sample SO-58; and mercury was detected at a maximum 

concentration of 9.3 mg/Kg in source sample SO-57 [13, pp. 38-39, 67-68, 70; 50, pp. 5-6, 8; 57, pp. 13-

15; 71, pp. 16-21, 24, 108-119, 124-125; 78, pp. 16-18, 20, 91-96].

Table 3 - Hazardous Substances Associated with Source No. 1

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-56 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 1,170 ng/Kg 5.15 ng/Kg 11, p. 22; 13, 

pp. 38-39, 67; 

50, p. 5; 71, 

pp. 1-2, 16, 

108-109; 78, 

p. 16 

1,2,3,7,8,9-HxCDD None 288 ng/Kg 5.15 ng/Kg

1,2,3,4,6,7,8-HpCDD None 30,400 ng/Kg 258 ng/Kg

2,3,7,8-TCDF None 4.41 ng/Kg 1.03 ng/Kg

2,3,4,6,7,8-HxCDF None 181 ng/Kg 5.15 ng/Kg

1,2,3,4,6,7,8-HpCDF None 5,180 ng/Kg 258 ng/Kg

Arsenic None 100 mg/Kg 1.4 mg/Kg 11, p. 22; 13, 

pp. 38-39, 67; 

57, p. 13; 78, 

pp. 1-2, 8, 16, 

91

Barium None 80.2 mg/Kg 27.6 mg/Kg

Chromium None 7,330 mg/Kg 6.9 mg/Kg

Mercury None 0.40 mg/Kg 0.14 mg/Kg

SO-57 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 3,280 ng/Kg 102 ng/Kg 11, p. 22; 13, 

pp. 38, 67; 50, 

p. 5; 71, pp. 1-

2, 17, 110-

111; 78, p. 16

1,2,3,7,8,9-HxCDD None 396 ng/Kg 102 ng/Kg

1,2,3,4,6,7,8-HpCDD None 122,000 ng/Kg 509 ng/Kg

2,3,4,6,7,8-HxCDF None 386 ng/Kg 102 ng/Kg

1,2,3,4,6,7,8-HpCDF None 29,500 ng/Kg 102 ng/Kg

Arsenic None 42.6 mg/Kg 2 mg/Kg 11, p. 22; 13, 

pp. 38, 67; 57, 

p. 14; 78, pp. 

1-2, 9, 16, 92

Barium None 1,020 mg/Kg 40.2 mg/Kg

Chromium None 13,900 mg/Kg 20.1 mg/Kg

Mercury None 9.3 mg/Kg 0.6 mg/Kg
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 39 HRS Documentation Record

MAD001031574 September 2012

Table 3 - Hazardous Substances Associated with Source No. 1 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-58 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 16,000 ng/Kg 133 ng/Kg 11, p. 22; 13, 

pp. 38, 67; 50, 

p. 5; 71, pp. 1-

2, 18, 112-

113; 78, p. 17

1,2,3,7,8,9-HxCDD None 1,890 ng/Kg 133 ng/Kg

1,2,3,4,6,7,8-HpCDD None 607,000 ng/Kg 2,653 ng/Kg

2,3,4,6,7,8-HxCDF None 1,190 ng/Kg 133 ng/Kg

1,2,3,4,6,7,8-HpCDF None 113,000 ng/Kg 2,653 ng/Kg

Barium None 496 mg/Kg 54.1 mg/Kg 11, p. 22; 13, 

pp. 38, 67; 57, 

p. 14; 78, pp. 

1-2, 9, 17, 93

Chromium None 20,500 mg/Kg 27 mg/Kg

Mercury None 5.4 mg/Kg 0.54 mg/Kg

SO-59 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 1,380 ng/Kg 4.94 ng/Kg 11, pp. 22, 25; 

13, pp. 39, 68; 

50, p. 6; 71, 

pp. 1-2, 19, 

114-115; 78, 

p. 17

1,2,3,7,8,9-HxCDD None 192 ng/Kg 4.94 ng/Kg

1,2,3,4,6,7,8-HpCDD None 29,400 ng/Kg 247 ng/Kg

2,3,7,8-TCDF None 6.66 ng/Kg 0.987 ng/Kg

2,3,4,6,7,8-HxCDF None 149 ng/Kg 4.94 ng/Kg

1,2,3,4,6,7,8-HpCDF None 4,480 ng/Kg 247 ng/Kg

Arsenic None 93.9 mg/Kg 1.6 mg/Kg 11, pp. 22, 25; 

13, pp. 39, 68; 

57, p. 14; 78, 

pp. 1-2, 9, 17, 

94

Barium None 274 mg/Kg 31.8 mg/Kg

Chromium None 4,020 mg/Kg 15.9 mg/Kg

Mercury None 0.37 mg/Kg 0.16 mg/Kg

SO-60 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 4,850 ng/Kg 60.5 ng/Kg 11, p. 22; 13, 

pp. 39, 68; 50, 

p. 6; 71, pp. 1-

2, 20, 116-

117; 78, p. 18

1,2,3,7,8,9-HxCDD None 889 ng/Kg 60.5 ng/Kg

1,2,3,4,6,7,8-HpCDD None 191,000 ng/Kg 1209 ng/Kg

2,3,4,6,7,8-HxCDF None 426 ng/Kg 60.5 ng/Kg

1,2,3,4,6,7,8-HpCDF None 34,200 ng/Kg 1,209 ng/Kg

Arsenic None 565 mg/Kg 1.4 mg/Kg 11, p. 22; 13, 

pp. 39, 68; 57, 

p. 14; 78, pp. 

1-2, 9, 18, 95

Chromium None 1,140 mg/Kg 1.4 mg/Kg

Mercury None 1.9 mg/Kg 0.14 mg/Kg
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 40 HRS Documentation Record

MAD001031574 September 2012

Table 3 - Hazardous Substances Associated with Source No. 1 (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-61 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 735 ng/Kg 39.3 ng/Kg 11, p. 22; 13, 

pp. 39, 68; 50, 

p. 6; 71, pp. 1-

2, 21, 118-

119; 78, p. 18

1,2,3,7,8,9-HxCDD None 196 ng/Kg 39.3 ng/Kg

1,2,3,4,6,7,8-HpCDD None 17,700 ng/Kg 196 ng/Kg

2,3,7,8-TCDF None 12.4 ng/Kg 7.86 ng/Kg

2,3,4,6,7,8-HxCDF None 126 ng/Kg 39.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 3,930 ng/Kg 39.3 ng/Kg

Arsenic None 93.4 mg/Kg 1.4 mg/Kg 11, p. 22; 13, 

pp. 39, 68; 57, 

p. 14; 78, pp. 

1-2, 9, 18, 96

Barium None 127 mg/Kg 27.5 mg/Kg

Chromium None 1,230 mg/Kg 1.4 mg/Kg

Mercury None 0.34 mg/Kg 0.14 mg/Kg

SO-70 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 20,200 ng/Kg 122 ng/Kg 11, p. 22; 13, 

pp. 38, 70; 50, 

p. 8; 71, pp. 1-

2, 24, 124-

125; 78, p. 20

1,2,3,7,8,9-HxCDD None 2,650 ng/Kg 122 ng/Kg

1,2,3,4,6,7,8-HpCDD None 769,000 ng/Kg 6,082 ng/Kg

2,3,4,6,7,8-HxCDF None 1,360 ng/Kg 122 ng/Kg

1,2,3,4,6,7,8-HpCDF None 136,000 ng/Kg 6,082 ng/Kg

Barium None 491 mg/Kg 56 mg/Kg 11, p. 22; 13, 

pp. 38, 70; 57, 

p. 15; 78, pp. 

1-2, 10, 20, 

101

Chromium None 17,500 mg/Kg 28 mg/Kg

Mercury None 4.8 mg/Kg 0.28 mg/Kg

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran.

* = An explanation for the direction of bias is provided in Reference 71, Table 3 and Reference 78.

List of Hazardous Substances Associated with Source

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

2,3,7,8-TCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

Arsenic

Barium

Chromium

Mercury
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 41 HRS Documentation Record

MAD001031574 September 2012

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicated that no portion of Source No. 1 has a maintained engineered cover or 

complete runoff control management system [11, p. 26]. No report of a natural or man-made liner was 

documented during source sampling activities [11, p. 26]. As part of an on-site reconnaissance conducted 

as part of the EPA SR on 2 November 2011, leather scraps were observed to be protruding from the bank; 

and protruding from a soil pile extending from the fenced border of Landfill Area B to the Crane River 

and the northeastern property marker [11, p. 17; 22]. Leather scraps were observed eroding out of the 

bank of the river and depositing into the river sediments [11, p. 17; 22]. Therefore, Source No. 1 does not 

have full containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 4 - Hazardous Substances Available to Pathways

Containment Description

Containment 

Factor References

Gas release to air: NS NS

Particulate release to air: NS NS

Release to ground water: NS NS

Release via overland migration and/or flood: Based on the lack of liner, a 

maintained engineered cover, and any complete run-on control and runoff 

management systems, a Containment Factor Value of 10 has been assigned 

for release to the Surface Water Pathway for Source No. 1.

10

1, p. 51609 (Table 

3-2); 11, pp. 26; 22

NS = Not Scored.

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 1 was assigned based on the Area Factor Value of a “pile” 

source type [1, p. 51591, Table 2-5, Section 2.4.2.1.4]. The Hazardous Constituent Quantity, Hazardous 

Wastestream Quantity, and Volume Values were not evaluated for Source No. 1 because insufficient 

information was available [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)]. 

2.4.2.1.1 Hazardous Constituent Quantity

Description

The hazardous constituent quantity for Source No. 1 could not be adequately determined according to the 

HRS requirements; that is, the total mass of all Comprehensive Environmental Response, Compensation, 

and Liability Act (CERCLA) hazardous substances in the source is not known and cannot be estimated 

with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. There are insufficient historical and 

current data (Manifests, PRP records, State records, Permits, Waste concentration data, etc.) available to 

adequately calculate the total mass of all CERCLA hazardous substances in the source and the associated 

releases from the source. Therefore, there is insufficient information to evaluate the associated releases 

from the source to calculate the hazardous constituent quantity for Source No. 1 with reasonable 

confidence.
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 42 HRS Documentation Record

MAD001031574 September 2012

Table 5 – Hazardous Constituent Quantity

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description

The hazardous wastestream quantity for Source No. 1 could not be adequately determined according to 

the HRS Final Rule requirements; that is, the total mass of all hazardous wastestreams and CERCLA 

pollutants and contaminants for the source and releases from the source is not known and cannot be 

estimated with reasonable confidence [1, p. 51591 (Section 2.4.2.1.2)]. There are insufficient historical 

and current data (Manifests, PRP records, State records, Permits, Waste concentration data, Annual 

reports, etc.) available to adequately calculate the total mass of all hazardous wastestreams and CERCLA 

pollutants and contaminants for the source and the associated releases from the source. Therefore, there is 

insufficient information to adequately calculate or extrapolate the hazardous wastestream quantity for 

Source No. 1 with reasonable confidence.

Table 6 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestream Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]:

Hazardous Wastestream Quantity Assigned Value: Not Scored 

2.4.2.1.3 Volume

Description

The volume for Source No. 1 could not be adequately determined according to the HRS requirements 

because insufficient historical and current waste sampling data are available to adequately calculate the 

volume of the source (or the volume of the area of observed contamination) associated with the source 

with reasonable confidence [1, p. 51591 (Section 2.4.2.1.3)]. Insufficient historical or current sampling 

data are available to adequately estimate the depth of waste material within the source. Therefore, there is 

insufficient information to adequately calculate or estimate the volume for Source No. 1 with reasonable 

confidence.
Source Characterization

Source No. 1

Creese & Cook Tannery (Former) 43 HRS Documentation Record

MAD001031574 September 2012

Table 7 – Volume

Source 

Type

Description

(# drums or dimensions)

Units

(yd3) References

NS

NS = Not Scored.

The volume of a “pile” source, in cubic yards (yd3

), is divided by 2.5 to assign a volume assigned value to 

the source [1, p. 51591 (Table 2-5)]. 

Volume Assigned Value: 0

2.4.2.1.4 Area

Description

Based on sampling results and observations of the material contained within Source No. 1 (Leather Scrap

Pile), the areal extent of the source defined as part of this source characterization was documented using 

GPS (see Figure 2) [11, p. 17; 21]. Based on the information recorded using GPS as part of the EPA SR, 

the area of the Leather Scrap Pile (Source No. 1) was determined to be approximately 7,115 ft2 (see 

Figure 2) [11, p. 17; 21].

Table 8 – Area

Source Type Units (ft2) References

Pile 7,115 Figure 2; 11, p. 17; 21

The area of a “pile” source, in ft2

, is divided by 13 to assign an area assigned value to the source [1, p. 

51591 (Table 2-5)]. 

Sum (ft2

): 7,115

Equation for Assigning Value (1, p. 51591, Table 2-5): 7,115 ÷ 13 = 547.31

Area Assigned Value: 547.31

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 1 was assigned based on the Area Factor Value 

(547.31) [1, p. 51591 (Table 2-5)]. The Hazardous Constituent Quantity, Hazardous Wastestream 

Quantity, and Volume Values were not evaluated for Source No. 1 because insufficient information was 

available [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)].

Highest HWQ value assigned from Ref. 1, Table 2-5: 547.31
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 44 HRS Documentation Record

MAD001031574 September 2012

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source: Upland Pile

Number of Source: Source No. 2

Source Type: Pile

Description and Location of Source:

The Upland Pile (Pile - Source No. 2) is located on the former facility property located on the western 

side of the Crane River, depicted on the Town of Danvers, MA Tax Assessor’s Map No. 59, as Lot No. 

2B (see Figure 2) [6, p. 1; 17, p. 3; 170]. Source No. 2 is located on the northwestern portion of the 

facility property, adjacent to the former beamhouse building footprint (see Figure 2) [11, p. 12]. The 

geographic coordinates of the Upland Pile, as measured from its approximate center, are 42° 33′ 15.4′′ 

north latitude and 70° 55′ 51.6′′ west longitude (see Figures 1 and 2) [20]. 

Based on observations as part of the EPA SR, the Upland Pile source is a fenced area which contains 

piled soil material [11, p. 12; 13, pp. 100-101, 103]. The pile was observed to be steep-sided with small 

shrubs and grasses growing on the pile [11, p. 12; 13, p. 101].

Available file information does not indicate the source of the piled material referred to here as the Upland 

Pile, but site plan maps dating to 6 March 1998 and depicting sampling performed in 1996 indicate an 

area of piled material [97, pp. 45 (Exhibit C), 49 (Table 2); 103, p. 24 (Exhibit A); 113, pp. 19 (Figure 

2)]. Previous sampling of the Upland Pile source indicated the presence of arsenic, chromium, and 

dioxin/furan congeners [113, pp. 10-11, 19 (Figure 2), 22 (Table 2), 32 (Table 3); 131, pp. 18 (Table 1), 

20-30 (Table 3)].

The estimated area and volume of the Upland Pile was not found in available documentation. Based on 

sampling results and observations of the piled material that constitutes Source No. 2 (Upland Pile), the 

areal extent of the base of the source pile defined as part of this source characterization was documented 

using GPS (see Figure 2) [11, p. 13; 21]. Based on the information recorded as part of the EPA SR, the 

area contained by the Upland Pile (Source No. 2) was determined to be approximately 6,009 ft2 (see 

Figures 2 and 3a) [11, p. 13; 21].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Source Samples:

On 23 May 2011, as part of the EPA SR, source sampling activities of the Upland Pile were conducted 

[11, pp. 9-14; 13, pp. 21-27]. The source samples were collected in accordance with the EPA-approved 

Site-Specific QAPP, dated 18 April 2011 [8, pp. 32, 34-37; 9, pp. 2-3, 8 (Figure 3), 11-12; 13, pp. 21-22]. 

As part of the Upland Pile characterization, six source samples (SO-02, SO-03, SO-04, SO-05, SO-05B, 

and SO-25) were collected from various locations throughout the pile (see Figure 3a) [11, p. 12-13; 13, 

pp. 25-26, 59-60, 65]. 
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 45 HRS Documentation Record

MAD001031574 September 2012

Table 9 – Source Sample Description

Sample 

ID Sample Description Reference

SO-02

Brown, silt and fine sand, trace medium-to-coarse sand, trace clay, trace medium-to-coarse 

sand. 26, p. 2

SO-03 Dark brown, silt, little fine sand, trace organics, trace clay, trace medium-to-coarse sand. 26, p. 3

SO-04 Dark brown, silt, some fine gravel, little fine-to-coarse sand, trace clay. 26, p. 4

SO-05/

SO-25 Dark brown, silt, trace fine gravel, trace fine-to-coarse sand. 26, p. 5

SO-05B Light brown, fine-to-coarse sand, little silt. 26, p. 6

The six source samples (SO-02, SO-03, SO-04, SO-05, SO-05B, and SO-25) were submitted to CLP 

laboratories for dioxin/furan analyses following DLM02.2, and total metals analysis following ISM01.2 

[11, p. 12-13, 14; 13, p. 25-27, 59-60, 65; 28, pp. 5-8; 29, pp. 5-6; 45; 51, pp. 1, 4, 7; 52, pp. 1, 4; 58, pp. 

1, 11; 59, pp. 1, 11; 72, pp. 5-6, 10-11, 18, 84-87, 93; 73, pp. 5, 9-11, 92-93, 96-99; 79, pp. 9-10, 13, 70-

71, 80; 80, pp. 9-10, 81, 83-84]. Chains-of-custody (COCs) for all source samples collected as part of the 

2011 EPA SR and presented in this HRS Documentation Record are provided in References 28 and 29. 

The applicable COC sections for the Source No. 2 samples and all corresponding sample identifiers are 

provided in available COC, field notes reference documentation, and sample crosswalk [11, p. 12-13; 13, 

p. 25-26, 59-60, 65; 26, pp. 2-6;28, pp. 5-8; 29, pp. 5-6; 45]. The dioxin/furan analytical results were 

manually validated at a stage 4 level in accordance with the criteria specified in the USEPA SOW 

DLM02.2 and EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [51, p. 1; 52, p. 

1]. The total metals analytical data were evaluated on a Tier II level in accordance with the Region I 

Tiered Organic and Inorganic Data Validation Guidelines dated November 2008 [58, p. 1; 59, p. 1]. The 

validation of dioxin/furan and total metals analytical results was conducted independently by designated 

chemists who were not involved in the sample collection and HRS evaluation [11, p. 13, 14; 13, p. 25-27, 

59-60, 65; 51, pp. 1-3; 52, pp. 1-3; 58, pp. 1-6; 59, pp. 1-6]. For the purposes of the Source No. 2 

evaluation and this HRS documentation record, analytical results of six source samples confirm the 

presence of the following hazardous substances: five dioxin/furan congeners (1,2,3,6,7,8-HxCDD, 

1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,4,6,7,8-HxCDF, and 1,2,3,4,6,7,8-HpCDF) and three total 

metals (arsenic, chromium, and mercury). Source No. 2 has been documented to contain hazardous 

substances as defined by the HRS [1, p. 51586; 173, pp. 493, 500-501].

Among the six selected source samples: 1,2,3,6,7,8-HxCDD was detected at a maximum concentration of 

274 ng/Kg in source sample SO-02; 1,2,3,7,8,9-HxCDD was detected at a maximum concentration of 380 

ng/Kg in source sample SO-03; 1,2,3,4,6,7,8-HpCDD was detected at a maximum concentration of 9,000 

ng/Kg in source sample SO-02; 2,3,4,6,7,8-HxCDF was detected at a maximum concentration of 199 

ng/Kg in source sample SO-03; 1,2,3,4,6,7,8-HpCDF was detected at a maximum concentration of 961 

ng/Kg in source sample SO-02; arsenic was detected at a maximum concentration of 214 mg/Kg in source

sample SO-25; chromium was detected at a maximum concentration of 2,360 mg/Kg in source sample 

SO-03; and mercury was detected at a maximum concentration of 1.3 mg/Kg in source sample SO-25 [51, 

p. 4; 52, p. 4; 58, p. 12; 59, p. 11; 72, pp. 5, 6, 10, 84-85; 73, pp. 5, 10, 96-97; 79, pp. 13, 80; 80, pp. 9, 

83].
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 46 HRS Documentation Record

MAD001031574 September 2012

Table 10 - Hazardous Substances Associated with Source No. 2

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-02 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

274 J

(274) ng/Kg 5.15 ng/Kg

11, p. 13; 13, 

pp. 25-26, 59; 

51, pp. 4; 72, 

pp. 1-3, 5, 10, 

84-85

1,2,3,7,8,9-HxCDD Low

71.2 J

(71.2 ) ng/Kg 5.15 ng/Kg

1,2,3,4,6,7,8-HpCDD Low

9,000 J

(9,000) ng/Kg 30.9 ng/Kg

2,3,4,6,7,8-HxCDF Low

25.5 J

(25.5) ng/Kg 5.15 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

961 J

(961) ng/Kg 5.15 ng/Kg

Arsenic Unknown

93.1 J

(53.5) mg/Kg 0.9 mg/Kg

11, p. 13; 13, 

pp. 25-26, 59; 

58, pp. 11; 72, 

p. 5; 79, pp. 

1-2, 9, 70

Chromium High

356 EB

(276) mg/Kg 0.9 mg/Kg

Mercury None 0.20 mg/Kg 0.11 mg/Kg

SO-03 Soil 5/23/11 1,2,3,6,7,8-HxCDD Unknown

1,570 J EB

(157) ng/Kg 7.07 ng/Kg

11, p. 13; 13, 

pp. 25-26, 59; 

52, p. 4; 73, 

pp. 1-2, 5, 10, 

96-97

1,2,3,7,8,9-HxCDD Low

380 J

(380) ng/Kg 7.07 ng/Kg

1,2,3,4,6,7,8-HpCDD Unknown

51,000 J EB

(5,100) ng/Kg 177 ng/Kg

2,3,4,6,7,8-HxCDF Low

199 J

(199) ng/Kg 7.07 ng/Kg

1,2,3,4,6,7,8-HpCDF Unknown

2,810 J EB

(281) ng/Kg 177 ng/Kg

Arsenic Low

160 J

(160) mg/Kg 0.8 mg/Kg

11, p. 13; 13, 

pp. 25-26, 59; 

59, p. 11; 73, 

p. 5; 80, pp. 

1-2, 9, 83

Chromium None 2360 mg/Kg 8.2 mg/Kg

Mercury None 0.26 mg/Kg 0.12 mg/Kg

SO-04 Soil 5/23/11 1,2,3,6,7,8-HxCDD Unknown

890 J EB

(89) ng/Kg 6.41 ng/Kg

11, p. 12-13; 

13, pp. 25-26, 

59; 52, p. 4; 

73, pp. 1-2, 5, 

11, 98-99

1,2,3,7,8,9-HxCDD Low

203 J

(203) ng/Kg 6.41 ng/Kg

1,2,3,4,6,7,8-HpCDD Unknown

27,100 J EB

(2,710) ng/Kg 96.1 ng/Kg

2,3,4,6,7,8-HxCDF Low

93.9 J

(93.9) ng/Kg 6.41 ng/Kg

1,2,3,4,6,7,8-HpCDF Unknown

2,130 J EB

(213) ng/Kg 6.41 ng/Kg

Arsenic Low

198 J

(198) mg/Kg 1.1 mg/Kg

11, p. 12; 13, 

pp. 25-26, 59; 

59, p. 11; 73, 

p. 5; 80, pp. 

1-2, 10, 84

Chromium None 1560 mg/Kg 5.4 mg/Kg

Mercury None 0.29 mg/Kg 0.11 mg/Kg
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 47 HRS Documentation Record

MAD001031574 September 2012

Table 10 - Hazardous Substances Associated with Source No. 2 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-05 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

141 J

(141) ng/Kg 6.21 ng/Kg

11, p. 12; 13, 

pp. 25-26, 60; 

51, p. 4; 72, 

pp. 1-3, 5, 11, 

86-87

1,2,3,7,8,9-HxCDD Low

51.6 J

(51.6) ng/Kg 6.21 ng/Kg

1,2,3,4,6,7,8-HpCDD Low

4,350 J

(4,350) ng/Kg 18.6 ng/Kg

2,3,4,6,7,8-HxCDF Low

11.5 J

(11.5) ng/Kg 6.21 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

287 J

(287) ng/Kg 6.21 ng/Kg

Arsenic Unknown

320 J

(184) mg/Kg 2.4 mg/Kg

11, p. 12; 13, 

pp. 25-26, 60; 

58, p. 11; 72, 

p. 5; 79, pp. 

1-2, 10, 71

Chromium High

325 EB

(252) mg/Kg 0.8 mg/Kg

Mercury None 1.1 mg/Kg 0.11 mg/Kg

SO-05B Soil 5/23/11 1,2,3,7,8,9-HxCDD Low

12.1 J

(12.1) ng/Kg 4.85 ng/Kg

11, p. 12; 13, 

pp. 25-26, 60; 

52, pp. 4; 73, 

pp. 1-2, 5, 9, 

92-93

1,2,3,4,6,7,8-HpCDD Unknown

1,730 J EB

(173) ng/Kg 9.70 ng/Kg

1,2,3,4,6,7,8-HpCDF Unknown

103 J EB

(10.3) ng/Kg 4.85 ng/Kg

Chromium None 85.2 mg/Kg 0.7 mg/Kg

11, p. 12; 13, 

pp. 25-26, 60; 

59, p. 11; 73, 

p. 5; 80, pp. 

1-2, 9, 81
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 48 HRS Documentation Record

MAD001031574 September 2012

Table 10 - Hazardous Substances Associated with Source No. 2 (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-25 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

134 J

(134) ng/Kg 6.23 ng/Kg

11, p. 12; 13, 

pp. 25-26, 65; 

51, p. 7; 72, 

pp. 1-3, 6, 18, 

94-95

1,2,3,7,8,9-HxCDD Low

38.2 J

(38.2) ng/Kg 6.23 ng/Kg

1,2,3,4,6,7,8-HpCDD Low

4,560 J

(4,560) ng/Kg 18.7 ng/Kg

2,3,4,6,7,8-HxCDF Low

9.29 J

(9.29) ng/Kg 6.23 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

255 J

(255) ng/Kg 6.23 ng/Kg

Arsenic Unknown

373 J

(214) mg/Kg 2.6 mg/Kg

11, p. 12; 13, 

pp. 25-26, 65; 

58, pp. 12; 72, 

p. 6; 79, pp. 

1-2, 13, 80

Chromium High

301 EB

(233) mg/Kg 0.9 mg/Kg

Mercury None 1.3 mg/Kg 0.12 mg/Kg

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

HpCDF= Heptachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

J = The associated numerical value is an estimated quantity [51, pp. 4, 7; 52, p. 4; 58, pp. 11-12; 

59, p. 11; 141, p. B-20; 142, pp. B-23-24].

EB = The associated compound or element was detected in rinsate blank samples collected for 

quality control [44; 52, p. 4; 58, p. 11-12]. The potential contribution for carryover from non-dedicated 

sampling equipment has been evaluated. In most cases, the concentration of the analyte or compound 

observed in a sample is significantly greater than the concentration observed in the associated equipment 

blank. Therefore, the sample data can be used with a high degree of certainty to confirm the presence of 

the substance in the samples. [44]. 

* = An explanation for the direction of bias is provided in Reference 72, Table 3 and Reference 73, 

Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination, for HRS purposes it is not required to adjust qualified source data. 

Although the fact sheet was not intended for application to source data, the bias of these data has been 

considered to demonstrate that even after consideration of the impact of the bias, the substances are 

present above detection and that the contaminants are present in the soil due to a release [140, pp. 4-8]. 

List of Hazardous Substances Associated with Source

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

Arsenic

Chromium

Mercury
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 49 HRS Documentation Record

MAD001031574 September 2012

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicated that no portion of Source No. 2 has a maintained engineered cover or 

complete runoff control management system [11, p. 26]. No report of a natural or man-made liner was 

documented during source sampling activities [11, p. 26]. Therefore, Source No. 2 does not have full 

containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 11 - Hazardous Substances Available to Pathways

Containment Description

Containment 

Factor References

Gas release to air: NS NS

Particulate release to air: NS NS

Release to ground water: NS NS

Release via overland migration and/or flood: Based on the lack of liner, a 

maintained engineered cover, and any complete run-on control and runoff 

management systems, a Containment Factor Value of 10 has been assigned 

for release to the Surface Water Pathway for Source No. 2.

10

1, p. 51609 (Table 

3-2); 11, p. 26

NS = Not Scored.

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 2 was assigned based on the Area Factor Value of a “pile” 

source type [1, p. 51591, Table 2-5, Section 2.4.2.1.4]. The Hazardous Constituent Quantity, Hazardous 

Wastestream Quantity, and Volume values were not evaluated for Source No. 2 because insufficient 

information was available [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)]. 

2.4.2.1.1 Hazardous Constituent Quantity

Description

The hazardous constituent quantity for Source No. 2 could not be adequately determined according to the 

HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source is not known 

and cannot be estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. There are 

insufficient historical and current data (Manifests, PRP records, State records, Permits, Waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA hazardous 

substances in the source and the associated releases from the source. Therefore, there is insufficient 

information to evaluate the associated releases from the source to calculate the hazardous constituent 

quantity for Source No. 2 with reasonable confidence.
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 50 HRS Documentation Record

MAD001031574 September 2012

Table 12 – Hazardous Constituent Quantity

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description

The hazardous wastestream quantity for Source No. 2 could not be adequately determined according to 

the HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and releases from the source is not known and cannot be estimated with 

reasonable confidence [1, p. 51591 (Section 2.4.2.1.2)]. There are insufficient historical and current data 

(Manifests, PRP records, State records, Permits, Waste concentration data, Annual reports, etc.) available 

to adequately calculate the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and the associated releases from the source. Therefore, there is insufficient 

information to adequately calculate or extrapolate the hazardous wastestream quantity for Source No. 2 

with reasonable confidence.

Table 13 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestream Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]:

Hazardous Wastestream Quantity Assigned Value: Not Scored 

2.4.2.1.3 Volume

Description

The volume for Source No. 2 could not be adequately determined according to the HRS Final Rule 

requirements because insufficient historical and current waste sampling data are available to adequately 

calculate the volume of the source (or the volume of the area of observed contamination) associated with 

the source with reasonable confidence [1, p. 51591 (Section 2.4.2.1.3)]. Insufficient historical or current 

sampling data are available to adequately estimate the depth of waste material within the source. 

Therefore, there is insufficient information to adequately calculate or estimate the volume for Source No. 

2 with reasonable confidence.
Source Characterization

Source No. 2

Creese & Cook Tannery (Former) 51 HRS Documentation Record

MAD001031574 September 2012

Table 14 – Volume

Source 

Type

Description

(# drums or dimensions)

Units

(yd3) References

NS

NS = Not Scored.

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a volume assigned value to the source 

[1, p. 51591 (Table 2-5)]. 

Volume Assigned Value: 0

2.4.2.1.4 Area

Description

Based on sampling results and observations of the piled material contained within Source No. 2 (Upland 

Pile), the areal extent of the source defined as part of this source characterization was documented using 

GPS (see Figure 2) [11, p. 13; 21]. Based on the information recorded as part of the EPA SR, the area of 

the Upland Pile (Source No. 2) was determined to be approximately 6,009 ft2 (see Figure 2) [11, p. 13; 

21].

Table 15 – Area

Source Type Units (ft2) References

Pile 6,009 Figure 2, 11, p. 13; 21

The area of a “pile” source, in ft2

, is divided by 13 to assign an area assigned value to the source [1, p. 

51591 (Table 2-5)]. 

Sum (ft2

): 6,009

Equation for Assigning Value [1, p. 51591 (Table 2-5)]: 6,009÷ 13 = 462.23

Area Assigned Value: 462.23

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 2 was assigned based on the Area Factor Value 

(462.23) [1, p. 51591 (Table 2-5)]. The Hazardous Constituent Quantity, Hazardous Wastestream 

Quantity, and Volume Values were not evaluated for Source No. 2 because insufficient information was 

available [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)].

Highest HWQ value assigned from Ref. 1, Table 2-5: 462.23
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 52 HRS Documentation Record

MAD001031574 September 2012

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source: Former Lagoons 

Number of Source: Source No. 3

Source Type: Surface Impoundment

Description and Location of Source:

The Former Lagoons (Surface Impoundment - Source No. 3) are located on the facility property located 

on the western bank of the Crane River, depicted on the Town of Danvers, MA Tax Assessor’s Map No. 

59, as Lot No. 2B (see Figure 2) [6, p. 1; 17, p. 3; 170]. Source No. 3 is located on the southeastern 

portion of the parcel, in proximity to the Crane River (see Figure 2) [11, p. 11]. The geographic 

coordinates of the Former Lagoons, as measured from its approximate center, are 42° 33′ 13.0′′ north 

latitude and 70° 55′ 45.8′′ west longitude (see Figures 1 and 2) [20]. 

Based on observations as part of the EPA SR, the Former Lagoons source is a fenced area which contains 

bermed material in a square shape, outlining a depression [11, p. 11]. Based on previous descriptions and 

figures of the facility, it appears the central berm, which divided the Former Lagoons into two surface 

impoundments, is no longer present and may have been removed during on-site containment cell 

construction in 1990 [11, pp. 11; 34, p. 4; 36, p. 2; 46, p. 1; 48, p. 11; 113, p. 19; 123; 124]. The Former 

Lagoon area appeared overgrown with small trees and shrubs, and contains piping that appears to have 

been previously used during use of the surface impoundments [11, p. 11]. 

The two former wastewater filtration lagoons, referred in reports as Area C, are located approximately 

160 feet east of the site building and in proximity to the Crane River (see Figure 2) [98, p. 1]. A letter 

report completed by SP indicated that the two lagoons were used as final settling ponds after the 

prescreening and primary sedimentation of the raw wastewater produced in the beam and tan process [43, 

p. 1]. The final effluent was discharged directly to the Crane River before 1950 [35, pp. 2; 39, p. 2; 43, p. 

1; 112, p. 5]. W&C indicated that this discharge was directed to the Crane River via a subsurface 

discharge pipe [113, p. 5]. Observations during the EPA SR indicated the presence of a discharge pipe 

from the Former Lagoons into the Crane River [11, p. 2]. A complaint, filed with the Town of Danvers 

Department of Health & Inspections, indicated that in January 1977, liquid waste from the lagoons was 

released to the Crane River [172, pp. 1-2]. The roughly 40′ x 100′ twin lagoons had four 4-inch pipes,

each to diffuse influent, and one 2-inch pipe for discharge to the river [43, p. 1]. According to SP, the 

lagoons appeared to have been scraped periodically and the accumulated sludge disposed of in the 

landfills on site (assumed to be Former Landfill Areas A and B) [43, p. 1]. In addition, SP asserted that 

the lagoons were cleaned before they were abandoned in April 1981, when all plant wastewater entered 

into the municipal system [40, p. 4; 43, p. 1]. Based on sampling, SP initially estimated approximately 

300 yd3 of sludge waste in the Old Lagoons (assumed to be the Former Lagoons source) when they were 

abandoned in 1981 [40, p. 4; 124, p. 20]. During the early part of 1990, SP excavated, treated/stabilized, 

and backfilled tannery wastes/contaminated soils from Landfill Areas A and B and Lagoons 1 and 2 (Area 

C), into the constructed lined on-site containment cell [46, p. 1; 47, p. 7]. An estimated total of 5,000 yd3

of excavated tannery waste and sludge was backfilled into the containment cell [47, p. 7]. 

Investigations of the Former Lagoons after excavation completed as part of the on-site containment cell 

construction indicated elevated levels of arsenic, hexavalent chromium, and chlorinated dioxins [93, pp. 

3-4, 11-16; 98 pp. 2, 9-11; 113, pp. 7, 20-33 (Tables 2 and 3)]. Based on the follow-up investigations of 
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 53 HRS Documentation Record

MAD001031574 September 2012

the Former Lagoons, REW estimated that an area of approximately 26,500 ft2 and volume of 

approximately 79,500 ft3 (2,944 yd3

) was impacted from the Former Lagoon wastes [97, p. 40]. Based on 

GPS measurements collected as part of the EPA SR and site plans from W&C, an area of approximately 

130 ft by 130 ft (16,900 ft2

) is fenced off as an imminent hazard area [11, p. 16; 131, p. 57 (Figures 2)].

Based on the sampling results of soils that have been impacted by materials from the surface 

impoundment and observations of bermed earthen material defining Source No. 3 (Former Lagoons), the 

areal extent of the source, defined as part of this source characterization, was documented using GPS (see 

Figure 2) [11, pp. 16, 26; 21]. Based on the information recorded as part of the EPA SR, the area of the 

Former Lagoons (Source No. 3) was determined to be approximately 14,615 ft2 (see Figure 2) [11, pp. 16, 

26; 21]. 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

The Former Lagoons (Source No. 3) are a surface impoundment source type. The soil materials contained 

within Source No. 3 have become impacted through migration of wastes once contained within the 

Former Lagoons and are therefore compared against background surface and subsurface soil samples, 

which were collected as part of the EPA SR [11, p. 26; 13, pp. 23, 30, 45; 26, pp. 24-25, 36-37]. 

Comparison to background soil sample concentrations is presented to ensure that hazardous substance 

concentrations in soil/source samples are clearly greater then background soil concentrations. On 5 

December 2011, as part of the EPA SR of the Creese & Cook Co. (Former) 1 facility, background soil 

sampling activities were conducted [11, pp. 21, 23, 26; 13, pp. 36-41]. The background surface and 

subsurface soil samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 

18 April 2011, and the Site-Specific QAPP Addendum, dated 22 November 2011 [8, pp. 29, 50; 9, pp. 2-

3, 8 (Figure 3), 11; 13, p. 36]. Two background surface soil samples (SO-52 and SO-53) and two 

background subsurface soil samples (SO-64 and SO-65) were collected from an area directly adjacent to 

the exterior side of the granite stone wall, marking the Russell and Endicott Cemetery (listed to be located 

at 25 Clinton Avenue) [11, pp. 21, 23; 13, pp. 37-38, 40, 66, 69]. The samples were collected to document 

potential background soil concentrations in natural materials in the vicinity of the site [11, pp. 21, 23; 13, 

pp. 37-38, 40]. The samples were collected from an area presumed to be outside the influence of the 

waste disposal practices at the tannery, since the Russell and Endicott Cemetery predates the tannery 

operations [11, pp. 23; 13, pp. 37-38]. START personnel noted grave markers dating back to the mid1700s (including Mrs. Margaret Endicott – 1759 and Capt. Samuel Endicott - 1766) [11, pp. 21; 13, pp. 

37-38]. 

The background soil samples were collected from the similar depth intervals as the soil/source samples 

presented in the Source No. 3 Characterization [26, pp. 17-21, 24-27, 36, 37]. Background soil samples 

were collected within 6 months of and during the same sampling event as the release samples presented as 

part of the Former Lagoons characterization [11, pp. 21, 23; 13, pp. 37-38, 40]. Reconnaissance 

observations during the time period between sampling events did not indicate any change to the 

secured/fenced source area identified here as Source No. 3 [11, pp. 10; 13, p. 44]. Background soil 

samples and Source No. 3 source samples were composed of similar matrix materials [11, pp. 26; 13, pp. 

37-38, 40; 26, pp. 17-21, 24-27, 36, 37]. 
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 54 HRS Documentation Record

MAD001031574 September 2012

Table 16 – Background Soil Sample Description

Sample 

ID Sample Description Reference

SO-52 Brown-to-orange brown, silt and fine-to-coarse sand, trace fine gravel, trace organics. 26, p. 24

SO-53 Brown, silt and fine-to-medium sand, trace fine-to-medium gravel, trace clay, trace organic. 26, p. 25

SO-64 Light brown, fine-to-coarse sand, some silt, trace fine-to-medium gravel, trace organics. 26, p. 36

SO-65 Medium-to-light brown, fine-to-coarse sand, some silt, trace organics. 26, p. 37

Background soil samples SO-53 and SO-64 were submitted to CLP laboratories for dioxin/furan analysis 

following DLM02.2 and for total metals analysis following ISM01.3, while background soil samples SO52 and SO-65 were submitted to a CLP laboratory only for total metals analysis following ISM01.3 [11, 

pp. 21, 23; 13, pp. 36-38, 40, 66, 69; 28, pp. 5, 7-8; 29, pp. 5-7; 50, p. 1; 57, p. 1; 78, pp. 5, 7]. COCs for 

all background soil samples collected as part of the 2011 EPA SR and presented in this HRS 

Documentation Record are provided in References 28 and 29. The applicable COC sections for the 

background soil samples and all corresponding sample identifiers are provided in available COC, field 

notes reference documentation, and sample crosswalk [11, pp. 21, 23; 13, pp. 36-38, 40, 66, 69; 26, pp. 

24-25, 36-37; 28, p. 11; 29, p. 7; 45]. The dioxin/furan analytical results were manually validated at a 

stage 4 level in accordance with the criteria specified in the USEPA SOW DLM02.2 and EPA Region I’s 

ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [50, p. 1; 78, pp. 5, 7]. The total metals 

analytical data were evaluated on a Tier II level in accordance with the Region I Tiered Organic and 

Inorganic Data Validation Guidelines dated November 2008 [57, p. 1; 78, pp. 5, 7]. The validation of 

dioxin/furan and total metals analytical results was conducted independently by designated chemists who 

were not involved in the sample collection and HRS evaluation [11, pp. 21, 23; 13, pp. 36-38, 40, 66, 69; 

50, pp. 1-3; 57, pp. 1-8]. As part of the Source No. 3 characterization, the following dioxin/furan 

congeners and total metals are presented: 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 

1,2,3,4,6,7,8-HpCDF, arsenic, chromium, and mercury. Based on an examination of the two background 

soil samples submitted for dioxin/furan analysis and the four background soil samples submitted for total 

metals analysis, the highest numerical background value concentrations are presented in Table 17 and 

used for comparison. See below for further evaluation of background concentrations utilized in this HRS 

evaluation.

Table 17 - Hazardous Substances Associated with Background Samples

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-64 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 0.752 U ng/Kg 5.04 ng/Kg

11, p. 23; 13, pp. 

40, 69; 50, p. 7; 

71, pp. 1-2, 13, 

123; 78, p. 7

SO-64 Soil 12/5/11 1,2,3,7,8,9-HxCDD None 0.772 U ng/Kg 5.04 ng/Kg

11, p. 23; 13, pp. 

40, 69; 50, p. 7; 

71, pp. 1-2, 13, 

123; 78, p. 7
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 55 HRS Documentation Record

MAD001031574 September 2012

Table 17 - Hazardous Substances Associated with Background Samples (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDD None 21.2 ng/Kg 4.81 ng/Kg

11, p. 21; 13, pp. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107; 78, p. 5

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDF None

1.77 J

(1.77) ng/Kg 4.81 ng/Kg

11, p. 21; 13, pp. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107; 78, p. 5

SO-52 Soil 12/5/11 Arsenic None 11.4 mg/Kg 1.2 mg/Kg

11, p. 21; 13, pp. 

37-38, 66; 57, p. 

13; 78, pp. 1-2, 8, 

11, 87

SO-52 Soil 12/5/11 Chromium None 17.3 mg/Kg 1.2 mg/Kg

11, p. 21; 13, pp. 

37-38, 66; 57, p. 

13; 78, pp. 1-2, 8, 

11, 87

SO-53 Soil 12/5/11 Mercury None

0.040 J

(0.040) mg/Kg 0.12 mg/Kg

11, p. 21; 13, pp. 

38, 66; 57, p. 13; 

78, pp. 1-2, 5, 11, 

88

mg/Kg = Milligrams per kilogram. CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. HxCDD= Hexachlorodibenzodioxin.

HpCDD= Heptachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

U = The compound or element was analyzed for, but not detected. The associated numerical value 

is the sample-adjusted CRQL [141, p. B-21].

J = The associated numerical value is an estimated quantity [50, p. 4; 57, p. 11; 141, p. B-20; 142, 

pp. B-23-24].

* = An explanation for the direction of bias is provided in Reference 71, Table 3 and Reference 78.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination, for HRS purposes it is not required to adjust qualified source data. 

Although the fact sheet was not intended for application to source data, it has been applied in this 

situation to demonstrate the relative increase in contamination in the source samples over background 

levels and that the contaminants are present in the soil due to a release [140, pp. 4-8]. 

Based on an examination of the two background soil samples submitted for dioxin/furan analysis and the 

four background soil samples submitted for total metals analysis, the highest numerical background value 

concentrations are presented in Table 17 and used for comparison. Dioxin congeners 1,2,3,6,7,8-HxCDD 

and 1,2,3,7,8,9-HxCDD were non-detect and are therefore documented above background levels when the 

source sample concentration equals or exceeds the highest presented sample-adjusted CRQL [1, p. 51589 

(Table 2-3)]. Dioxin/furan congeners 1,2,3,4,6,7,8-HpCDD and 1,2,3,4,6,7,8-HpCDF were detected in 

background soil samples. The background concentration of 1,2,3,4,6,7,8-HpCDD exceeded the sampleadjusted CRQL, and is considered above background when the source sample concentration is three times 
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 56 HRS Documentation Record

MAD001031574 September 2012

or more above the background concentration [1, p. 51589 (Table 2-3)]. Furan congener 1,2,3,4,6,7,8-

HpCDF was detected at a concentration below the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. The 

furan congener 1,2,3,4,6,7,8-HpCDF is considered above background when the source sample 

concentration is three times or more above the background concentration [1, p. 51589 (Table 2-3)]. 

Arsenic and chromium were detected in background soil samples above the sample-adjusted CRQL, and 

are considered above background when the source sample concentration is three times or more above the 

background concentration [1, p. 51589 (Table 2-3)]. Barium was detected in background soil samples at a 

concentration below the sample-adjusted CRQL and is considered above background when the source 

sample concentration is three times or more above the background concentration [1, p. 51589 (Table 2-

3)]. Mercury was detected at a concentration below the sample-adjusted CRQL, and is considered above 

background when the source sample concentration is three times or more above the background 

concentration [1, p. 51589 (Table 2-3)].

- Source Samples:

On 23 May 2011 and 5 December 2011, as part of the EPA SR, soil/source sampling activities of the 

Former Lagoons were conducted [11, pp. 9-15, 20-24; 13, pp. 21-28, 36-41]. The soil/source samples 

were collected in accordance with the EPA-approved Site-Specific QAPP, dated 18 April 2011, and the 

Site-Specific QAPP Addendum, dated 22 November 2011 [8, pp. 32, 34-37; 9, pp. 2-3, 8 (Figure 3), 11-

12; 13, pp. 21, 37]. As part of Former Lagoons characterization, eight source samples (SO-16, SO-17, 

SO-18, SO-19, SO-20, SO-26, SO-54, and SO-55) were collected from various locations throughout the 

surface impoundment (see Figure 3a) [11, pp.21, 23; 13, pp. 22-24, 40]. 

Table 18 – Soil/Source Sample Description

Sample 

ID Sample Description Reference

SO-16 Medium-to-dark brown, fine-to-coarse sand, trace fine gravel, trace silt, trace clay. 26, p. 17

SO-17 Dark brown, fine-to-coarse sand, little silt, trace fine gravel, trace clay. 26, p. 18

SO-18 Dark brown, coarse sand and coarse gravel, trace silt. 26, p. 19

SO-19 Brown-to-dark brown, fine-to-coarse sand, trace clay, trace silt, trace fine gravel. 26, p. 20

SO-20/

SO-26

Brown-to-dark brown, fine-to-coarse sand, some fine-to-coarse gravel, little silt, trace clay, 

trace organics. 26, p. 21

SO-54 Dark brown, fine-to-coarse sand and silt, trace organics, trace fine gravel. 26, p. 26

SO-55 Dark brown, silt and clay, little fine-to-coarse sand, trace organics. 26, p. 27

Six of the eight soil/source samples (SO-16, SO-17, SO-18, SO-19, SO-20, and SO-26) were submitted to 

CLP laboratories for dioxin/furan analyses following DLM02.2, and for total metals analysis following 

ISM01.2 [11, pp. 11-14; 13, p. 22-24, 29, 63-65; 28, pp. 5, 7-8; 29, pp. 5-6; 51, pp. 1, 6; 52, pp. 1, 7-8; 58, 

pp. 1, 11-12; 59, pp. 1, 12-13; 72, pp. 5-6, 15-17, 91-93; 73, pp. 6, 19-21, 109-110, 113; 79, pp. 12-13, 

75-77; 80, pp. 14-15, 92-93, 96]. Source samples SO-54 and SO-55 were submitted to CLP laboratories 

for total metals analysis only, following ISM01.3 [11, pp. 23, 27; 13, p. 29, 40, 66-67; 29, pp. 7; 57, p. 1, 

13; 78, pp. 8, 15, 89-90]. COCs for all source samples collected as part of the 2011 EPA SR and 

presented in this HRS Documentation Record are provided in References 28 and 29. The applicable COC 

sections for the Source No. 3 samples and all corresponding sample identifiers are provided in available 

COC, field notes reference documentation, and sample crosswalk [11, pp. 11-13, 23; 13, pp. 22-24, 40, 

63-67; 26, pp. 17-21, 26-27; 28, pp. 5, 7-8; 29, pp. 5-7; 45]. The dioxin/furan analytical results were 

manually validated at a stage 4 level in accordance with the criteria specified in the USEPA SOW 
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 57 HRS Documentation Record

MAD001031574 September 2012

DLM02.2 and EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [51, p. 1; 52, p. 

1]. The total metals analytical data were evaluated on a Tier II level in accordance with the Region I 

Tiered Organic and Inorganic Data Validation Guidelines dated November 2008 [57, p. 1; 58, p. 1; 59, p. 

1]. The validation of dioxin/furan and total metals analytical results was conducted independently by 

designated chemists who were not involved in the sample collection and HRS evaluation [11, pp. 11-13; 

13, p. 22-24, 29, 63-65; 51, pp. 1-3; 52, pp. 1-2; 58, pp. 1-6; 59, pp. 1-6]. For the purposes of the Source 

No. 3 evaluation and this HRS documentation record, analytical results of eight source samples confirm 

the presence of the following hazardous substances: four dioxin/furan congeners (1,2,3,6,7,8-HxCDD, 

1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, and 1,2,3,4,6,7,8-HpCDF) and three total metals (arsenic, 

chromium, and mercury). Source No. 3 has been documented to contain hazardous substances as defined 

by the HRS [1, p. 51586; 173, pp. 493, 500-501].

Among the eight selected soil/source samples: 1,2,3,6,7,8-HxCDD was detected at a maximum 

concentration of 124 J ng/Kg in soil/source sample SO-18; 1,2,3,7,8,9-HxCDD was detected at a 

maximum concentration of 49.8 J ng/Kg in soil/source sample SO-18; 1,2,3,4,6,7,8-HpCDD was detected 

at a maximum concentration of 1,190 J ng/Kg in soil/source sample SO-18; 1,2,3,4,6,7,8-HpCDF was 

detected at a maximum concentration of 57.2 JEB ng/Kg in soil/source sample SO-20; arsenic was 

detected at a maximum concentration of 147 mg/Kg in soil/source sample SO-16; chromium was detected 

at a maximum concentration of 218 mg/Kg in soil/source sample SO-55; and mercury was detected at a 

maximum concentration of 0.23 mg/Kg in soil/source sample SO-18 [13, pp. 22-24, 40, 63-67; 51, p. 6; 

58, p. 12; 59, p. 12; 72, pp. 5, 6, 15, 16, 91-92; 73, p. 6; 79, pp. 12, 76; 80, pp. 14, 92].

Table 19 - Hazardous Substances Associated with Source No. 3

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-16 Soil 5/23/11

1,2,3,7,8,9-HxCDD Low

5.22 J

(5.22) ng/Kg 5.20 ng/Kg

11, pp. 12; 13, pp. 

22-24, 63; 52, p. 

7; 73, pp. 1-2, 6, 

19, 109

Arsenic None 147 mg/Kg 0.8 mg/Kg 11, pp. 12; 13, pp. 

22-24, 63; 59, p. 

12; 73, p. 6; 80, 

Chromium None 55.3 mg/Kg 0.8 mg/Kg pp. 1-2, 14, 92

SO-17 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

19.9 J

(19.9) ng/Kg 5.27 ng/Kg 11, pp. 12; 13, pp. 

24, 63; 51, p. 6; 

72, pp. 1-2, 5, 15, 

1,2,3,7,8,9-HxCDD Low 91

5.41 J

(5.41) ng/Kg 5.27 ng/Kg

1,2,3,4,6,7,8-HpCDD Low

517 J

(517) ng/Kg 5.27 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

36.5 J

(36.5) ng/Kg 5.27 ng/Kg

Arsenic Unknown

103 J

(59.2) mg/Kg 0.7 mg/Kg

11, pp. 12; 13, pp. 

24, 63; 58, p. 11; 

72, p. 5; 79, pp. 1-

2, 12, 75 Chromium High

70 EB

(54.3) mg/Kg 0.7 mg/Kg
Source Characterization

Source No. 3

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MAD001031574 September 2012

Table 19 - Hazardous Substances Associated with Source No. 3 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-18 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

124 J

(124) ng/Kg 5.57 ng/Kg 11, pp. 11; 13, pp. 

23, 63; 51, p. 6; 

72, pp. 1-2, 6, 16, 

1,2,3,7,8,9-HxCDD Low 92

49.8 J

(49.8) ng/Kg 5.57 ng/Kg

1,2,3,4,6,7,8-HpCDD Low

1,190 J

(1,190) ng/Kg 5.57 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

31 J

(31) ng/Kg 5.57 ng/Kg

Arsenic Unknown

63.4 J

(36.4) mg/Kg 0.9 mg/Kg

11, pp. 11; 13, pp. 

23, 63; 58, p. 12; 

72, p. 6; 79, pp. 1-

2, 12, 76 Chromium High

70.3 EB

(54.5) mg/Kg 0.9 mg/Kg

Mercury None 0.23 mg/Kg 0.1 mg/Kg

SO-19 Soil 5/23/11 1,2,3,6,7,8-HxCDD Low

5.94 J

(5.94) ng/Kg 5.57 ng/Kg 11, pp. 11; 13, pp. 

23, 63; 51, p. 6; 

72, pp. 1-2, 6, 17, 

1,2,3,4,6,7,8-HpCDD Low 93

270 J

(270) ng/Kg 5.57 ng/Kg

1,2,3,4,6,7,8-HpCDF Low

16 J

(16) ng/Kg 5.57 ng/Kg

Arsenic Unknown

94.6 J

(54.4) mg/Kg 0.8 mg/Kg

11, pp. 11; 13, pp. 

23, 63; 58, p. 12; 

72, p. 6; 79, pp. 1-

2, 13, 77

SO-20 Soil 5/23/11 1,2,3,7,8,9-HxCDD Low

7.13 J

(7.13) ng/Kg 5.23 ng/Kg

11, pp. 11; 13, pp. 

22-23, 64; 52, p. 

7; 73, pp. 1-2, 6, 

20, 110 1,2,3,4,6,7,8-HpCDD Unknown

858 J EB

(85.8) ng/Kg 5.23 ng/Kg

1,2,3,4,6,7,8-HpCDF Unknown

57.2 J EB

(5.72) ng/Kg 5.23 ng/Kg

Arsenic None 83.2 mg/Kg 0.7 mg/Kg 11, pp. 11; 13, pp. 

22-23, 64; 59, p. 

12; 73, p. 6; 80, 

Chromium None 173 mg/Kg 0.7 mg/Kg pp. 1-2, 14, 93

SO-26 Soil 5/23/11 1,2,3,7,8,9-HxCDD Low

6.13 J

(6.13) ng/Kg 5.31 ng/Kg

11, pp. 11; 13, pp. 

22-23, 65; 52, p. 

8; 73, pp. 1-2, 6, 

21, 113 1,2,3,4,6,7,8-HpCDD Unknown

762 J EB 

(76.2) ng/Kg 5.31 ng/Kg

Arsenic None 72.5 mg/Kg 0.7 mg/Kg 11, pp. 11; 13, pp. 

22-23, 65; 59, p. 

13; 73, p. 6; 80, 

Chromium None 160 mg/Kg 0.7 mg/Kg pp. 1-2, 15, 96
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 59 HRS Documentation Record

MAD001031574 September 2012

Table 19 - Hazardous Substances Associated with Source No. 3 (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-54 Soil 12/5/11 Arsenic None 56.8 mg/Kg 1.2 mg/Kg 11, p. 23; 13, pp. 

40, 66; 57, p. 13; 

78, pp. 1-2, 8, 15, 

89

Chromium None 71.9 mg/Kg 1.2 mg/Kg

Mercury None 0.16 mg/Kg 0.12 mg/Kg

SO-55 Soil 12/5/11 Arsenic None 82.9 mg/Kg 1.5 mg/Kg

11, p. 23; 13, pp. 

40, 67; 57, p. 13; 

78, pp. 1-2, 8, 15, 

Chromium None 218 mg/Kg 1.5 mg/Kg 90

ng/Kg = Nanograms per kilogram. CRQL = Contract Required Quantitation 

Limit.

HpCDF= Heptachlorodibenzofuran. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

J = The associated numerical value is an estimated quantity [51, p. 6; 52, pp. 7-8; 58, pp. 11-12; 

72, pp. 15-17, 91-93; 73, pp. 19-21, 109-111; 79, pp. 12-13, 75-77; 141, p. B-20; 142, pp. B-23-24].

EB = The associated compound or element was detected in rinsate blank samples collected for 

quality control [52, pp. 7-8; 58, pp. 11-12; 73, pp. 19-21, 109-111; 79, pp. 12, 75-76]. The potential 

contribution for carryover from non-dedicated sampling equipment has been evaluated. In most cases, the 

concentration of the analyte or compound observed in a sample is significantly greater than the 

concentration observed in the associated equipment blank. Therefore, the sample data can be used with a 

high degree of certainty to confirm the presence of the substance in the samples [44].

* = An explanation for the direction of bias is provided in Reference 72, Table 3; Reference 73, 

Table 3; Reference 78; Reference 79, Table 3; and Reference 80, Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination, for HRS purposes it is not required to adjust qualified source data. 

Although the fact sheet was not intended for application to source data, it has been applied in this 

situation to demonstrate the relative increase in contamination in the source samples over background 

levels and that the contaminants are present in the soil due to a release [140, pp. 4-8]. 

List of Hazardous Substances Associated with Source

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

1,2,3,4,6,7,8-HpCDF

Arsenic

Chromium

Mercury
Source Characterization

Source No. 3

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MAD001031574 September 2012

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicated that no portion of Source No. 3 has a maintained engineered cover or 

complete runoff control management systems [11, p. 26]. No report of a natural or man-made liner was 

documented during source sampling activities [11, p. 26]. Therefore, Source No. 3 does not have full 

containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 20 - Hazardous Substances Available to Pathways

Containment Description

Containment 

Factor References

Gas release to air: NS NS

Particulate release to air: NS NS

Release to ground water: NS NS

Release via overland migration and/or flood: Based on the lack of liner, a 

maintained engineered cover, and any complete run-on control and runoff 

management systems, a Containment Factor Value of 10 has been assigned 

for release to the Surface Water Pathway for Source No. 3.

10

1, p. 51596 (Table 

3-2); 11, p. 26

NS = Not Scored.

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 3 was assigned based on the Area Factor Value of a 

“surface impoundment” source type [1, p. 51591, Table 2-5, Section 2.4.2.1.4]. The Hazardous 

Constituent Quantity, Hazardous Wastestream Quantity, and Volume values were not evaluated for 

Source No. 3 because insufficient information was available [1, pp. 51590-51591 (Sections 2.4.2.1.1,

2.4.2.1.2, and 2.4.2.1.3 Table 2-5)]. 

2.4.2.1.1 Hazardous Constituent Quantity

Description

The hazardous constituent quantity for Source No. 3 could not be adequately determined according to the 

HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source is not known 

and cannot be estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. There is 

insufficient historical and current data (Manifests, PRP records, State records, Permits, Waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA hazardous 

substances in the source and the associated releases from the source. Therefore, there is insufficient 

information to evaluate the associated releases from the source to calculate the hazardous constituent 

quantity for Source No. 3 with reasonable confidence.
Source Characterization

Source No. 3

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MAD001031574 September 2012

Table 21 – Hazardous Constituent Quantity

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description

The hazardous wastestream quantity for Source No. 3 could not be adequately determined according to 

the HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and releases from the source is not known and cannot be estimated with 

reasonable confidence [1, p. 51591 (Section 2.4.2.1.2)]. There is insufficient historical and current data 

(Manifests, PRP records, State records, Permits, Waste concentration data, Annual reports, etc.) available 

to adequately calculate the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and the associated releases from the source. Therefore, there is insufficient 

information to adequately calculate or extrapolate the hazardous wastestream quantity for Source No. 3 

with reasonable confidence.

Table 22 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestream Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]:

Hazardous Wastestream Quantity Assigned Value: Not Scored 

2.4.2.1.3 Volume

Description

The volume for Source No. 3 could not be adequately determined according to the HRS requirements 

because insufficient historical and current waste sampling data are available to adequately calculate the 

volume of the source (or the volume of the area of observed contamination) associated with the source 

with reasonable confidence [1, p. 51591 (Section 2.4.2.1.3)]. Insufficient historical or current sampling 

data are available to adequately estimate the depth of waste material within the source. Therefore, there is 

insufficient information to adequately calculate or estimate the volume for Source No. 3 with reasonable 

confidence.
Source Characterization

Source No. 3

Creese & Cook Tannery (Former) 62 HRS Documentation Record

MAD001031574 September 2012

Table 23 – Volume

Source 

Type

Description

(# drums or dimensions)

Units

(yd3) References

NS

NS = Not Scored.

The volume of a “pile” source, in yd3

, is divided by 2.5 to assign a volume assigned value to the source 

[1, p. 51591 (Table 2-5)]. 

Volume Assigned Value: 0

2.4.2.1.4 Area

Description

Based on sampling results of soils that have been impacted by materials from the surface impoundment 

and observations of bermed earthen material defining Source No. 3 (Former Lagoons), the areal extent of 

the source defined as part of this source characterization was documented using GPS (see Figure 2) [11, 

p. 26; 21]. Based on the information recorded as part of the EPA SR, the area of the Former Lagoons 

(Source No. 3) was determined to be approximately 14,615 ft2 (see Figure 2) [11, p. 26; 21]. 

Table 24 – Area

Source Type Units (ft2) References

Surface Impoundment 14,615 Figure 2, 11, p. 26; 21

The area of a “surface impoundment” source, in ft2

, is divided by 13 to assign an area assigned value to 

the source [1, p. 51591 (Table 2-5)]. 

Sum (ft2

): 14,615

Equation for Assigning Value [1, p. 51591 (Table 2-5)]: 14,615 ÷ 13 = 1,124.23

Area Assigned Value: 1,124.23

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 3 was assigned based on the Area Factor Value 

(1,124.23) [1, p. 51591 (Table 2-5)]. The Hazardous Constituent Quantity, Hazardous Wastestream 

Quantity, and Volume Values were not evaluated for Source No. 3 because insufficient information was 

available [1, pp. 51590-51591 (Sections 2.4.2.1.1, 2.4.2.1.2, 2.4.2.1.3, Table 2-5)].

Highest HWQ value assigned from Ref. 1, Table 2-5: 1,124.23
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 63 HRS Documentation Record

MAD001031574 September 2012

2.2 SOURCE CHARACTERIZATION

2.2.1 SOURCE IDENTIFICATION

Name of Source: Water Street/MBTA Source

Number of Source: Source No. 4

Source Type: Contaminated Soil

Description and Location of Source:

The Water Street/MBTA Source (Contaminated Soil - Source No. 4) is located on the former Creese & 

Cook Tannery facility property located at 33 Water Street and identified on the Town of Danvers, MA 

Tax Assessor’s Map No. 59, as Crane River East Condominiums (Lot No. 72), and a Boston and Maine 

Railroad parcel [7; 17, p. 2]. The geographic coordinates of the Water Street/MBTA Source, as measured 

from its approximate center, are 42° 33′ 10.91′′ north latitude and 70° 55′ 34.6′′ west longitude (see 

Figures 1 and 2) [20].

Limited information was found in available documentation concerning the Water Street/MBTA Source 

area. In early 1903, the Creese & Cook Co. was established at the 33 Water Street property with the 

construction of the original tannery building [32, p. 6]. In 1904, two large four-story wooden wings were 

added to the main building [32, p. 7]. In about 1906, the company employed a chrome process for both 

colored and black leathers [32, p. 7]. Between the years 1908 and 1914, three more additions were added 

to the business, including a brick store house and hide house in 1908, a five-story brick building in 1910, 

and a brick beamhouse in 1914, which was located across the Crane River next to the old Endicott 

burying ground (here assumed to be the Endicott-Russell Family Cemetery) [32, pp. 7]. Due to odor 

complaints regarding the tannery process, water supply and quality issues with the on-site wells, and a 

right-of-way access granted by the State through the 33 Water Street property along the Crane River for a 

proposed electric railroad, Creese & Cook Co. needed to move or expand their tannery operation [32, p. 

8]. In 1911, Creese & Cook Co. bought the land rights from the Clinton Avenue property to a pump house 

at Ash and Purchase Streets, where water from Brown Pond (Crane River) was pumped to a water tank 

adjacent to the new beamhouse [154, p. 4].A footbridge built across the Crane River connecting the 

beamhouse with the main plant was planned to carry steam pipes, electric power, and processing water 

[32, p. 7]. In 1914, the Creese & Cook Co. completed construction of the new brick beamhouse [32, p. 7]. 

According to W&C, beamhouse operations, including treatment, dehairing, and bating of skins prior to 

chroming and finishing, occurred on the portion of the facility located on the western shore of the Crane 

River [113, p. 5]. Tanning and finishing activities were performed at the original facility located on the 

opposite (eastern shore) side of the river [113, p. 5]. 

From 1914 to 1981, Creese & Cook Co. operated a leather tannery on the properties; however, details of 

the operations that continued to be conducted at the 33 Water Street facility were not found in available 

documentation [32, p. 7; 33, p.1]. 

On 31 January 1980, the Town of Danvers Office of Human Services received a complaint regarding 

buffing dust being emitted from a stack at the 33 Water Street facility and settling onto the Water Street 

bridge and ice in the Crane River immediately downstream of the bridge [155, pp. 1]. 

In 1983, a fire damaged portions of the 33 Water Street tannery buildings and a connecting wood building 

was torn down [153, p. 8]. 
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 64 HRS Documentation Record

MAD001031574 September 2012

On 7 December 1983, Creese & Cook Co. (Mr. George Hebb, President and Treasurer) sold the Creese & 

Cook Co. property, including the lots at 33 Water Street, 55 Clinton Avenue, and 20 Cheever Street, to 

the Crane River Realty Trust (Emmanuel Papanickolas, Trustee) [41]. 

An investigation report completed in 1984 was found in available documentation regarding the eastern 

Creese & Cook Tannery facility property, which includes the Water Street/MBTA Source. The 29 

October 1984 Subsurface Hazardous Waste Investigation completed by SP, Inc., indicated that the parcel 

contained gravel fill around the buildings [153, p. 7]. As part of the Subsurface Hazardous Waste 

Investigation, SP advanced four borings (Core Nos. 1 through 4) on the 33 Water Street property [153, p. 

21]. Selected soil samples were analyzed for Resource Conservation and Recovery Act (RCRA) 8 metals 

via extraction procedure (EP) Toxicity, and percent (%) oil and grease by the SP laboratory. The boring 

logs from the 33 Water Street property indicated the presence of oily topsoil and some building debris 

[153, p. 19]. Analytical results of the soil samples submitted for RCRA 8 metals via EP Toxicity 

indicated the presence of the following (maximum concentration in parentheses): arsenic (0.038 mg/L in

No. 2); barium (0.3 mg/L in No. 2); chromium (0.08 mg/L in No. 3); and mercury (0.058 mg/L in No. 3) 

[153, pp. 15].

In August 1987, the 33 Water Street property (Tax Map No. 59, Lot No. 72 [17, p. 3]) was separated from 

the other lots constituting the former Creese & Cook Tannery facility property, 55 Clinton Avenue (Tax 

Map No. 59, Lot No. 2B [17, p. 3]) and 20 Cheever Street (Tax Map No. 59, Lot No. 39 [17, p. 3]), with 

the recording of the Master Deed for the Crane River Condominium (East) with the Essex Registry of 

Deeds [156]. Note that the MBTA right-of-way access through the 33 Water Street property was granted 

by the State in circa 1914, as stated above [32, p. 8].

Based on GPS documentation of samples collected to characterize the Water Street/MBTA Source, the 

estimated area of contaminated soil is 114,099 ft2 [21].

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE

- Background Concentrations:

The Water Street/MBTA Source (Source No. 4) is a contaminated soil source type, and the materials 

comprising the Water Street/MBTA Source are compared against background surface and subsurface soil 

samples, which were collected as part of the EPA SR [11, pp. 21, 23; 12, p. 4-17; 13, pp. 37-38, 40, 66, 

69; 14, pp. 10-30; 26, pp. 34-35; 27, pp. 4-39, 53-70]. On 5 December 2011, as part of the EPA SR of the 

Creese & Cook Co. (Former) 1 facility, background soil sampling activities were conducted [11, pp. 20-

24; 13, pp. 36-41]. The background surface and subsurface soil samples were collected in accordance 

with the EPA-approved Site-Specific QAPP, dated 18 April 2011, and the Site-Specific QAPP 

Addendum, dated 22 November 2011 [8, pp. 29, 50; 9, pp. 2-3, 8 (Figure 3), 11; 13, p. 37]. Two 

background surface soil samples (SO-52 and SO-53) and two background subsurface soil samples (SO-64 

and SO-65) were collected from an area directly adjacent to the exterior side of the granite stone wall, 

marking the Endicott-Russell Family Cemetery (listed to be located at 25 Clinton Street) [11, pp. 21, 23; 

13, pp. 37-38, 40, 53, 56-57, 66, 69, 135]. The samples were collected to document potential background 

soil concentrations in natural materials in the vicinity of the site [11, pp. 21, 23; 13, p. 40]. The samples 

were collected from an area presumed to be outside the influence of the waste disposal practices at the 

tannery since the Endicott-Russell Family Cemetery predates the tannery operations [11, p. 21; 13, p. 38]. 

START personnel noted grave markers dating back to the mid-1700s (including Mrs. Margaret Endicott -

1759 and Capt. Samuel Endicott - 1766) [11, p. 21; 13, pp. 37-38]. 

The background soil samples were collected from similar depth intervals as the source samples presented 

in the Source No. 4 Characterization [26, pp. 24-25, 34-37; 27, pp. 4-39, 53-70]. Samples SO-52 and SO-
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 65 HRS Documentation Record

MAD001031574 September 2012

53 are shallow background surface soil samples, collected at maximum sampling depths of 24 inches [11, 

pp. 21, 23, 26-27; 26, p. 24-25] Samples SO-64 and SO-65 are subsurface background soil samples, 

collected at sampling depths greater than 24 inches [11, pp. 21, 23, 26-27; 26, p. 36-37]. Background soil

samples were collected within 7 months of those source samples presented as part of the Water 

Street/MBTA Source characterization [11, pp. 21, 23; 12, p. 4-17; 13, pp. 37-38; 14, pp. 10-30; 26, pp. 

24-25; 34-35; 27, pp. 4-39, 53-70]. Reconnaissance observations during the time period between 

sampling events did not indicate any changes to the source area identified here as Source No. 4 [11, pp. 5, 

16; 13, p. 44]. Background soil samples and Source No. 4 soil/source samples were comprised of similar 

matrix materials [11, pp. 21, 23; 12, pp. 4-17; 13, pp. 37-38, 40; 14, pp. 10-30; 26, pp. 24-25, 34-37; 27, 

pp. 4-39, 53-70].

Table 25 – Background Soil Sample Description

Sample 

ID Sample Description Reference

SO-52 Brown-to-orange brown, silt and fine-to-coarse sand, trace fine gravel, trace organics. 26, p. 24

SO-53 Brown, silt and fine-to-medium sand, trace fine-to-medium gravel, trace clay, trace organic. 26, p. 25

SO-64 Light brown, fine-to-coarse sand, some silt, trace fine-to-medium gravel, trace organics. 26, p. 36

SO-65 Medium-to-light brown, fine-to-coarse sand, some silt, trace organics. 26, p. 37

Background soil samples SO-53 and SO-64 were submitted to CLP laboratories for dioxin/furan analysis 

following DLM02.2 and for total metals analysis following ISM01.3, while background soil samples SO52 and SO-65 were submitted to a CLP laboratory for total metals analysis only, following ISM01.3 [11, 

pp. 21, 23, 26-27; 13, p. 37-38, 40, 45, 66, 69; 28, p. 11; 29, p. 7; 50, p. 1, 4, 7; 57, p. 1, 13, 15; 71, pp. 

12-13, 107, 123; 78, pp. 11-12, 87-88, 99]. COCs for all source samples collected as part of the 2011 EPA 

SR and SI and presented in this HRS Documentation Record are provided in References 28 and 29. The 

applicable COC sections for the background soil samples and all corresponding sample identifiers are 

provided in available COC, field notes reference documentation, and sample crosswalk [11, pp. 21, 23; 

13, pp. 36-38, 40, 66, 69; 26, pp. 24-25, 36-37; 28, p. 11; 29, p. 7; 45]. The dioxin/furan analytical results 

were validated manually validated at a stage 4 level in accordance with the criteria specified in the 

USEPA SOW DLM02.2 and EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 

[50, p. 1]. The total metals analytical data were evaluated on a Tier II level in accordance with the Region 

I Tiered Organic and Inorganic Data Validation Guidelines dated November 2008 [57, p. 1]. The 

validation of dioxin/furan and total metals analytical results was conducted independently by designated 

chemists who were not involved in the sample collection and HRS evaluation [11, pp. 21, 23; 13, pp. 36-

38, 40, 66, 69; 50, pp. 1-3; 57, pp. 1-8]. As part of the Source No. 4 characterization, the following 

dioxin/furan congeners and total metals are presented: 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 

1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, arsenic, barium, 

chromium, and mercury. Based on an examination of the two background soil samples collected and 

submitted for dioxin/furan analysis and the four background soil samples collected and submitted for total 

metals analysis, the highest background hazard concentrations for both surface and subsurface 

background soil samples are presented in Table 28. See below for further evaluation of background 

concentrations utilized in this section of the HRS evaluation.
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 66 HRS Documentation Record

MAD001031574 September 2012

Table 26 - Hazardous Substances Associated with Background Soil Samples

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

Shallow Surface Soil Samples 

SO-53 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 0.371 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-53 Soil 12/5/11 1,2,3,7,8,9-HxCDD None 0.425 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDD None 21.2 ng/Kg 4.81 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-53 Soil 12/5/11 2,3,7,8-TCDF None 0.259 EMPC ng/Kg 0.961 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-53 Soil 12/5/11 2,3,4,6,7,8-HxCDF None 0.338 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDF None

1.77 J

(1.77) ng/Kg 4.81 ng/Kg

11, p. 21; 13, 

pp. 38, 66; 50, 

p. 4; 71, pp. 1-

2, 12, 107

SO-52 Soil 12/5/11 Arsenic None 11.4 mg/Kg 1.2 mg/Kg

11, p. 21; 13, 

pp. 37-38, 66; 

57, p. 13; 78, 

pp. 1-2, 11, 87

SO-53 Soil 12/5/11 Barium None

21.2 J

(21.2) mg/Kg 23.6 mg/Kg

11, p. 21; 13, 

pp. 38, 66; 57, 

p. 13; 78, pp. 

1-2, 11, 88

SO-52 Soil 12/5/11 Chromium None 17.3 mg/Kg 1.2 mg/Kg

11, p. 21; 13, 

pp. 37-38, 66; 

57, p. 13; 78, 

pp. 1-2, 11, 87

SO-53 Soil 12/5/11 Mercury None

0.040 J

(0.040) mg/Kg 0.12 mg/Kg

11, p. 21; 13, 

pp. 38, 66; 57, 

p. 13; 78, pp. 

1-2, 11, 88
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 67 HRS Documentation Record

MAD001031574 September 2012

Table 26 - Hazardous Substances Associated with Background Soil Samples (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

Subsurface Soil Samples 

SO-64 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 0.752 U ng/Kg 5.04 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 1,2,3,7,8,9-HxCDD None 0.772 U ng/Kg 5.04 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 1,2,3,4,6,7,8-HpCDD None 9.66 ng/Kg 5.04 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 2,3,7,8-TCDF None 0.169 U ng/Kg 1.01 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 2,3,4,6,7,8-HxCDF None 0.345 U ng/Kg 5.04 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 1,2,3,4,6,7,8-HpCDF None 1.15 ng/Kg 5.04 ng/Kg

11, p. 23; 13, 

pp. 40, 69; 50, 

p. 7; 71, pp. 1-

2, 13, 123

SO-64 Soil 12/5/11 Arsenic High

7.1 J

(7.1) mg/Kg 1.2 mg/Kg

11, p. 23; 13, 

pp. 40, 69; 57, 

p. 15; 78, pp. 

1-2, 12, 99 

SO-64 Soil 12/5/11 Barium None

14.0 J

(14.0) mg/Kg 24.2 mg/Kg

11, p. 23; 13, 

pp. 40, 69; 57, 

p. 15; 78, pp. 

1-2, 12, 99

SO-64 Soil 12/5/11 Chromium None 16.9 mg/Kg 1.2 mg/Kg

11, p. 23; 13, 

pp. 40, 69; 57, 

p. 15; 78, pp. 

1-2, 12, 99
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 68 HRS Documentation Record

MAD001031574 September 2012

Table 26 - Hazardous Substances Associated with Background Soil Samples (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

Subsurface Soil Samples 

SO-64 Soil 12/5/11 Mercury None

0.11 J

(0.11) mg/Kg 0.12 mg/Kg

11, p. 23; 13, 

pp. 40, 69; 57, 

p. 15; 78, pp. 

1-2, 12, 99 

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran.

U = The compound or element was analyzed for, but not detected. The associated numerical value 

is the sample-adjusted CRQL [50, p. 7; 57, p. 11; 141, p. 3].

J = The associated numerical value is an estimated quantity [50, p. 4; 57, p. 11; 141, p. 2; 142, pp. 

23-24].

EMPC = Estimated Maximum Possible Concentration based on a failure of the ion abundance ratio. The 

EMPC is a worst case estimate of the sample concentration that the signal would represent if it did meet 

all the identification criteria [141, p. D-4]. 

* = An explanation for the direction of bias is provided in Reference 71, Table 3 and Reference 78.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination, for HRS purposes it is not required to adjust qualified source data. 

Although the fact sheet was not intended for application to source data, it has been applied in this 

situation to demonstrate the relative increase in contamination in the source samples over background 

levels and that the contaminants are present in the soil due to a release [140, pp. 4-8]. 

Based on an examination of the two background soil samples submitted for dioxin/furan analysis and the 

four background soil samples submitted for total metals analysis, the highest comparative numerical 

background value concentrations are presented in Table 28 and used for comparison. 

Dioxin/furan congeners 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, and 2,3,4,6,7,8-HxCDF in background 

surface soil samples, and 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, and 2,3,4,6,7,8-

HxCDF in background subsurface soil samples were non-detect. Therefore, a soil/source sample is 

considered significantly above background when the comparative soil/source sample concentration equals 

or exceeds the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. 

Dioxin congener 1,2,3,4,6,7,8-HpCDD was detected in background surface and subsurface soil samples at 

a concentration exceeding the sample-adjusted CRQL; therefore, the dioxin congener is considered 

significantly above background when the soil/source sample concentration is three times or more above 

the background concentration [1, p. 51589 (Table 2-3)]. In addition, arsenic and chromium were each 

detected in background surface and subsurface soil samples at a concentration exceeding the sampleadjusted CRQL; therefore, the two total metals are considered significantly above background when the 

comparative soil/source sample concentration is three times or more above the background concentration.

[1, p. 51589 (Table 2-3)]. 
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 69 HRS Documentation Record

MAD001031574 September 2012

Furan congener 1,2,3,4,6,7,8-HpCDF was detected in the background surface soil sample at a 

concentration below the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. This furan congener is 

considered above background when the comparative surface soil/source sample concentration is three 

time or more above the background concentration, as using the sample-adjusted CRQL for comparison 

would provide a lower background threshold value [1, p. 51589 (Table 2-3)]. In addition, barium and 

mercury were each detected in background surface and subsurface soil samples at concentrations below 

the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. Barium in both surface and subsurface soil/source 

samples and mercury in subsurface soil/source samples are each considered above background when the 

comparative soil/source sample concentration is three times or more above the background concentration, 

as using the sample-adjusted CRQL for comparison would provide a lower background threshold value 

[1, p. 51589 (Table 2-3)]. Mercury in surface soil/source samples is considered above background when 

the comparative soil/source sample concentration is three times or more above the background 

concentration, as using the sample-adjusted CRQL for comparison would provide the same comparison

value [1, p. 51589 (Table 2-3)].

Furan congeners 2,3,7,8-TCDF, in surface background soil sample, and 1,2,3,4,6,7,8-HpCDF, in 

background subsurface soil sample, were each detected at concentrations below the sample-adjusted 

CRQL. These furan congeners are considered above background when the source sample concentration is 

greater than the sample-adjusted CRQL, as three times the detected sample concentration is below the 

sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. This approach provides the highest possible 

comparison value.

- Source Samples:

On 18 through 22 April 2011, as part of the EPA SI of the Creese & Cook Co. (Former) 2 property and on 

5 December 2011, as part of the EPA SR of the Creese & Cook Co. (Former) 1 property, soil/source

sampling activities of the Water Street/MBTA Source were conducted [11, pp. 20-24; 12, pp. 4-17; 13, p. 

36-41; 14, pp. 10-30]. All soil source samples were collected in accordance with the EPA-approved SiteSpecific QAPP for the Creese & Cook Co. (Former) 2, dated 21 January 2011, and/or the EPA-approved 

Site-Specific QAPP for the Creese & Cook Co. (Former) 1 property, dated 18 April 2011, and the SiteSpecific QAPP Addendum, dated 22 November 2011 [8, pp. 34-37; 9, pp. 2-3, 11-12; 10, pp. 39-41; 13, 

pp. 36-41; 14, pp. 10-30]. As part of the Water Street/MBTA Source characterization, 49 soil/source

samples (SS-02A, SS-02C, SB-02, SS-03A, SB-03, SS-04A, SS-04C, SS-05A, SS-05C, SB-05A, SS06A, SS-07A, SS-07C, SB-07A, SS-08A, SS-08C, SB-08A, SB-08B, SS-09A, SS-09C, SB-09A, SB09B, SS-10A, SS-11A, SB-11A, SB-11B, SS-12A, SS-12C, SB-12A, SS-18A, SS-18C, SS-20A, SS-20C, 

SS-21A, SS-22A, SS-22C, SS-23A, SS-24A, SS-24C, SS-25A, SS-25C, SS-26A, SS-26C, SS-33A, SS33C, SB-33A, SS-35A, SO-62, and SO-63) were collected from various locations throughout the 

contaminated soil source (see Figure 3b) [11, pp. 23-25; 12, pp. 4-17; 13, pp. 39-40, 69; 14, pp. 10-30].

Table 27 – Soil/Source Sample Description

Sample 

ID Sample Description Reference

SS-02A

Brown, fine-to-coarse sand, some fine-to-coarse gravel (rocks), debris (metal slag, leather, and 

brick), trace silt, and trace roots. 27, p. 4

SS-02C

Combination of two distinct intervals: Interval 1 = medium brown, fine-to-coarse sand, little 

debris (brick, glass, concrete), some silt, and trace clay; Interval 2 = light-to-medium brown, fineto-coarse sand and silt, little clay, trace fine gravel, trace debris (brick fragments, concrete, and 

tile). 27, p. 5
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 70 HRS Documentation Record

MAD001031574 September 2012

Table 27 – Soil/Source Sample Description (Continued)

Sample 

ID Sample Description Reference

SB-02

Combination of two distinct intervals: Interval 1 = saturated, medium brown, fine-to-coarse sand 

and silt, some debris (brick and metal), trace clay; Interval 2 = saturated, black, fine-to-coarse 

sand, some fine-to-medium gravel, little silt, and trace clay. 27, p. 6

SS-03A

Black, fine-to-medium gravel and fine-to-coarse sand, trace silt, trace clay, and trace debris 

(concrete). 27, pp. 7-8

SB-03

Combination of three distinct intervals: Interval 1 = saturated, reddish brown-to-brown, fine-tocoarse sand and fine gravel, trace silt, and trace clay; Interval 2 = brown, coarse gravel; Interval 3 

= medium brown-to-dark brown, clay and silt, little organics (roots, matted vegetation), trace fine 

sand. 27, p. 9

SS-04A Brown, fine-to-medium sand and silt, trace fine-to-coarse gravel, and trace organics. 27, p. 10

SS-04C

As brown, fine sand, some silt, little fine-to-coarse gravel (up to 5-inch cobble), trace debris 

(brick, plastic, glass, ceramic, and slag), and trace organics. 27, p. 11

SS-05A

Light brown-to-brown, fine-to-coarse gravel (up to 10-inch cobble), little fine-to-coarse sand, 

trace silt. 27, p. 12

SS-05C

Combination of two distinct intervals: Interval 1 = dark brown, fine-to-coarse sand and silt, some 

debris (concrete, brick, and tile), trace fine gravel, and trace organics (roots); Interval 2 = 

cinnamon brown-to-brown, fine-to-coarse sand and silt, trace gravel, trace debris (cinder ash, 

clunkers, and brick fragments), and trace clay. 27, p. 13

SB-05A

Combination of four distinct intervals: Interval 1 = brick; Interval 2 = cinnamon brown-to-brown, 

fine-to-coarse sand and silt, little fine-to-medium gravel; Interval 3 = dark brown, silt, little fine 

sand, trace debris (glass); Interval 4 = dark brown, silt and fine-to-coarse sand, little fine-tomedium gravel, trace organics. 27, p. 14

SS-06A

Combination of two distinct intervals: Interval 1= dark brown to black, fine-to-coarse sand and 

silt, some fine-to-medium gravel, trace clay, trace debris (brick), trace organics (roots); Interval 

2= reddish brown to medium brown, fine-to-medium sand, some silt, trace fine gravel.

27, pp. 16-

17

SS-07A Dark brown, sand and silt and organics (roots and grass), trace fine gravel

27, pp. 20-

21

SS-07C

Combination of two distinct intervals: Interval 1 = brown, fine-to-medium sand and silt, little 

debris (brick, concrete, and glass); Interval 2 = brown fine-to-medium sand and silt, little debris 

(brick and concrete), trace coarse sand, and trace fine gravel. 27, p. 21

SB-07A

Combination of two distinct intervals: Interval 1 = dark brown, fine-to-coarse sand and silt, little 

debris (concrete, brick, possible mortar), trace clay, and trace fine gravel; Interval 2 = medium 

brown, fine-to-coarse sand, some silt, and trace gravel. 27, p. 22

SS-08A Light brown, fine-to-medium sand, little silt, little fine-to-coarse gravel, trace roots. 27, p. 24

SS-08C Dark brown, silt and sand, some debris (concrete and brick fragments). 27, p. 25

SB-08A

Black, coarse sand and silt, little fine gravel, trace clay, trace medium gravel, and containing a 

petroleum-like odor. 27, p. 26

SB-08B

Combination of two distinct intervals: Interval 1 = grey silt, little clay, little fine sand, trace fine 

gravel, and trace coarse sand; Interval 2 = dark grey clay and silt, little fine sand. 27, p. 27
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 71 HRS Documentation Record

MAD001031574 September 2012

Table 27 – Soil/Source Sample Description (Continued)

Sample 

ID Sample Description Reference

SS-09A/

SS-33A

As light brown-to-brown, fine-to-coarse sand, little fine-to-coarse gravel, trace silt, and trace 

organics. 27, p. 28

SS-09C/

SS-33C

Combination of two distinct intervals: Interval 1 = medium-to-dark brown, fine-to-medium 

gravel and fine-to-coarse sand, some silt, trace clay, and trace debris (brick); Interval 2 = grey, 

fine-to-medium gravel (concrete debris, brick), little silt, little fine-to-coarse sand. 27, p. 29

SB-09A

Combination of two distinct intervals: Interval 1 = medium brown, silt and fine-to-coarse sand, 

little clay, trace gravel; Interval 2 = medium brown, fine-to-coarse sand and silt, little fine gravel, 

and little clay. 27, p. 30

SB-09B

Combination of two distinct intervals: Interval 1 = light brown-to-medium brown, silt, little clay, 

little fine-to-coarse sand, with inclusions of fine sand; Interval 2 = light brown-to-grey, silt, little 

clay. 27, p. 30

SS-10A

Combination of two distinct intervals: Interval 1 = dark brown-to-greyish black, fine-to-coarse 

sand, some silt, trace debris (brick); Interval 2 = black silt, some fine-to-coarse sand, little debris 

(burned materials, apparent roofing and tar material), trace gravel, and contained a petroleumlike/creosote-like odor throughout the interval.

27, p. 31-

33

SS-11A

Combination of two distinct intervals: Interval 1 = dark brown silt, trace fine-to-coarse sand, 

trace debris (glass), trace organics (rootlets); Interval 2 = dark brown, fine-to-coarse sand and silt, 

some fine-to-medium gravel, little debris (brick, ash material, clinkers), trace clay, and was 

moist. 27, p. 34

SB-11A

Combination of three distinct intervals: Interval 1 = wet, debris which included red and brown 

crushed brick, white-to-cream-colored mortar, and black burnt charred wood with fibrous 

material; Interval 2 = saturated, dark brown-to-black, silt and fine-to-coarse sand, little debris 

(mortar, brick, and wood); Interval 3 = saturated, black, organics (wood). 27, p. 35

SB-11B

Combination of two distinct intervals: Interval 1 = blue-grey, clay; Interval 2 = black-to-bluegrey, clay, trace black organic material. 27, p. 36

SS-12A

Dark brown silt and debris (glass, brick, wood, metal, and ash), trace fine-to-coarse sand, and 

trace rootlets. 27, p. 37

SS-12C

As moist, dark brown, fine-to-coarse sand, little clay, little silt, little debris (glass, rope, wood, 

ceramic fragments, and metal debris), and trace fine-to-coarse gravel. 27, p. 38

SB-12A

Combination of two distinct intervals: Interval 1 = medium brown-to-dark brown, fine-to-coarse 

sand and fine-to-medium gravel, some silt, little debris (glass, metal, brick, tile); Interval 2 = 

blue-grey, clay. 27, p. 39

SS-18A Light brown, sand. 27, p. 53

SS-18C

Combination of two distinct intervals: Interval 1 = light brown, fine-to-coarse sand, some gravel 

(up to 2-inch rock), trace debris (brick and mortar); Interval 2 = moist, dark brown, gravel (up to 

1⁄4-inch), little sand. 27, p. 54

SS-20A

Dark brown, fine-to-coarse sand and gravel (up to 5-inch cobble), and trace organics (roots and 

mulch). 27, p. 57

SS-20C Dark brown, fine-to-coarse sand and gravel (up to 3-inch cobble), and trace organics. 27, p. 58
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 72 HRS Documentation Record

MAD001031574 September 2012

Table 27 – Soil/Source Sample Description (Concluded)

Sample 

ID Sample Description Reference

SS-21A

Brown, fine-to-medium sand, some silt, trace gravel (up to 1-inch, brick debris), and trace 

organics. 27, p. 59

SS-22A Light brown, clay, some silt, trace fine sand, trace fine-to-coarse gravel, and trace organics. 27, p. 61

SS-22C Light brown, fine sand and silt, trace fine gravel, and trace organics. 27, p. 62

SS-23A/

SS-35A

Dark brown, fine-to-medium sand and silt, some clay, trace fine-to-coarse gravel, trace debris and 

plastic, and trace organics. 27, p. 63

SS-24A

Dark brown, fine sand and silt, some debris (leather and plastic), trace fine-to-coarse gravel, trace 

clay, and trace organics. 27, p. 65

SS-24C Dark brown, fine sand and silt, trace gravel, trace clay, trace debris (plastic), and trace organics. 27, p. 66

SS-25A

Dark brown, fine-to-coarse sand, little gravel (up to 1-inch rock, plastic, leather debris, possible 

coal slag), trace organics. 27, p. 67

SS-25C

Dark brown, fine-to-coarse sand, little gravel (up to 1.5-inch rock, plastic, leather, and glass), 

trace organics. 27, p. 68

SS-26A

Dark brown-to-black, fine-to-coarse sand, little gravel (up to 1-inch cobble, leather, glass, metal), 

trace organics. 27, p. 69

SS-26C

Combination of two distinct intervals: Interval 1 = dark brown-to-black, fine-to-coarse sand, little 

gravel (up to 2-inch rock, leather, glass), trace organics (roots and reeds); Interval 2 = orangebrown, gravel (up to 2-inch rock). 27, p. 70

SO-62 Dark brown, organic-rich silt, little fine-to-coarse sand, trace fine gravel. 26, p. 34

SO-63 Dark brown, silt and fine-to-coarse sand, little organics, trace fine-to-medium gravel, trace clay. 26, p. 35

Thirty-three of the 49 soil/source samples (SS-02A, SB-02, SS-03A, SB-03, SS-04A, SS-05A, SB-05A, 

SS-06A, SS-07A, SB-07A, SS-08A, SB-08A, SB-08B, SS-09A, SB-09A, SB-09B, SS-10A, SS-11A, SB11A, SB-11B, SS-12A, SB-12, SS-18A, SS-20A, SS-21A, SS-22A, SS-23A, SS-24A, SS-25A, SS-26A, 

SS-33A, SB-33A, SS-35A) were submitted to CLP laboratories for dioxin/furan analyses following 

DLM02.2, and for total metals analysis following ISM01.2 [12, pp. 5-16; 14, pp. 14-25; 28, pp. 13, 15, 

17, 19; 29, pp. 9, 15-16, 23-24, 26-27; 45; 53, p. 1, 4-6, 8; 54, p. 1, 4-5, 7-8; 55, p. 1, 4, 6; 56, p. 1, 4-8; 

60, p. 1, 11-13; 62, p. 1, 12-14; 64, p. 1, 11-13; 74, pp. 12-14, 19, 24, 112-114, 119, 124; 75, pp. 11-16, 

21, 23, 106-111, 116, 118; 76, pp. 9-10, 14-15, 95-96, 101-102; 77, pp. 9-12, 14-15, 17, 20-21, 104-107, 

109-110, 112-113, 116; 81, pp. 11-13, 16-17, 19-20, 84-88, 93, 95-96, 100-101; 85, pp. 9-10, 12-15, 76-

77, 79, 84, 86, 88-90]. Two of the 49 soil/source samples (SO-62 and SO-63) were submitted to CLP 

laboratories for dioxin/furan analyses following DLM02.2, and for total metals analysis following 

ISM01.3 [11, pp. 20-24; 13, p. 39-40, 57, 69; 28, p. 11; 29, p. 7; 50, p. 1, 7; 57, p. 1, 4; 70, pp. 22-23, 

120-122; 78, pp. 19, 77-78]. Fourteen of the 49 soil/source samples (SS-02C, SS-04C, SS-05C, SS-07C, 

SS-08C, SS-09C, SS-12C, SS-18C, SS-20C, SS-22C, SS-24C, SS-25C, SS-26C, and SS-33C) were 

submitted to a CLP laboratory for total metals analysis only, following ISM01.2 [12, pp. 5-16; 14, p. 14-

25; 29, pp. 13, 20; 45; 61, p. 1, 8-10; 63, p. 1, 8-9; 82, pp. 11-12, 64, 66-67, 69-70, 77, 79; 84, pp. 9, 55-

56, 58, 60-62, 66]. COCs for all soil/source samples collected as part of the 2011 EPA SR and SI and 

presented in this HRS Documentation Record are provided in References 28 and 29. The applicable COC 

sections for the Source No. 4 samples and all corresponding sample identifiers are provided in available 

COC, field notes reference documentation, and sample crosswalk [11, pp. 23-25; 12, pp. 4-16; 13, pp. 39-

40, 69; 14, pp. 12-17, 19-21, 23-25, 28; 26, pp. 34-35; 27, pp. 4-14, 16-17, 20-39; 28, pp. 11, 13, 15, 17, 

19; 29, pp. 7, 9, 13, 15-16, 20, 23-24, 26-27, 29; 45]. The dioxin/furan analytical results were manually 
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 73 HRS Documentation Record

MAD001031574 September 2012

validated at a stage 4 level in accordance with the criteria specified in the USEPA SOW DLM02.2 and 

EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [53, p. 1, 4-6, 8; 54, p. 1, 4-5, 

7-8; 55, p. 1, 4, 6; 56, p. 1, 4-8; 60, p. 1, 11-13; 62, p. 1, 12-14; 64, p. 1, 11-13]. The total metals 

analytical data were evaluated on a Tier II level in accordance with the Region I Tiered Organic and 

Inorganic Data Validation Guidelines dated November 2008 [50, p. 1, 7; 53, p. 1, 4-6, 8; 54, p. 1, 4-5, 7-

8; 55, p. 1, 4, 6; 56, p. 1, 4-8; 57, p. 1, 14; 60, p. 1, 11-13; 62, p. 1, 12-14; 63, p. 1, 8-9; 64, p. 1, 11-13]. 

The validation of dioxin/furan and total metals analytical results was conducted independently by 

designated chemists who were not involved in the sample collection and HRS evaluation [11, pp. 23-25; 

12, pp. 4-17; 13, pp. 39-40, 69; 14, pp. 10-30;50, pp. 1-3; 53, pp. 1-3; 54, pp. 1-3; 56, pp. 1-3; 57, pp. 1-8; 

60, pp. 1-7; 61, pp. 1-4; 62, pp. 1-8; 63, pp. 1-4; 64, pp. 1-7]. For the purposes of the Source No. 4 

evaluation and this HRS documentation record, analytical results of the 49 soil/source samples confirm 

the presence of the following hazardous substances: six dioxin/furan congeners (1,2,3,6,7,8-HxCDD, 

1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, and 1,2,3,4,6,7,8-HpCDF) 

and four total metals (arsenic, barium, chromium, and mercury). Source No. 4 has been documented to 

contain hazardous substances as defined by the HRS [1, p. 51588; 173, pp. 493, 500-501].

Among the 49 selected soil/source samples: 1,2,3,6,7,8-HxCDD was detected at a maximum 

concentration of 776 ng/Kg in soil/source sample SO-62; 1,2,3,7,8,9-HxCDD was detected at a maximum 

concentration of 391 ng/Kg in soil/source sample SO-62; 1,2,3,4,6,7,8-HpCDD was detected at a 

maximum concentration of 21,900 ng/Kg in soil/source sample SO-62; 2,3,7,8-TCDF was detected at a 

maximum concentration of 8.82 ng/Kg in soil/source sample SS-12A; 2,3,4,6,7,8-HxCDF was detected at 

a maximum concentration of 126 ng/Kg in soil/source sample SO-62; 1,2,3,4,6,7,8-HpCDF was detected 

at a maximum concentration of 2,840 ng/Kg in soil/source sample SO-62; arsenic was detected at a 

maximum concentration of 201 mg/Kg in soil/source sample SB-03; barium was detected at a maximum 

concentration of 923 mg/Kg in soil/source sample SB-12; chromium was detected at a maximum 

concentration of 21,300 J mg/Kg in soil/source sample SB-08A; and mercury was detected at a maximum 

concentration of 7.2 mg/Kg in soil/source sample SS-06A [11, pp. 23-25; 12, pp. 5-16, 13, pp. 39-40, 69; 

14, pp. 14-25; 45; 50, p. 7; 53, pp. 4-6, 8; 54, pp. 4-5, 7-8; 55, p. 4, 6; 56, pp. 4-8; 57, p. 14; 60, pp. 11-13; 

61, pp. 8-10; 62, pp. 12-14, 63, pp. 8-9; 64, pp. 11-13; 71, pp. 22-23, 120-122; 74, pp. 12-14, 19, 24, 112-

114, 119, 124; 75, pp. 11-16, 21, 23, 106-111, 116, 118; 76, pp. 9-10, 14-15, 95-96, 101-102; 77, pp. 9-

12, 14-15, 17, 104-107, 109-110, 112-113, 116; 78, pp. 19, 97-98; 80, pp. 13, 20; 81, pp. 11-13, 16-17, 

19-20, 84-88, 93, 95-96, 100-101; 82, pp. 11-12, 64, 66-67, 69-70, 77, 79; 83, pp. 11-12, 14-15, 17-20, 

91-98, 100-101, 105, 107-108; 84, pp. 9, 55-56, 58, 60-62, 66; 85, pp. 9-10, 12-15, 76-77, 79, 84, 86, 88-

90].
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 74 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-02A Soil 4/18/11 1,2,3,6,7,8-HxCDD None 7.61 ng/Kg 4.91 ng/Kg 12, p. 5; 14, pp. 

10, 14; 53, p. 4; 

74, p. 1-2, 12, 

112

1,2,3,4,6,7,8-HpCDD None 223 ng/Kg 4.91 ng/Kg

2,3,7,8-TCDF None 3.14 ng/Kg 0.982 ng/Kg

1,2,3,4,6,7,8-HpCDF None 41.1 ng/Kg 4.91 ng/Kg

Barium None 73.4 mg/Kg 20.7 mg/Kg 12, p. 5; 14, p. 

10, 14; 60, p. 11; 

81, pp. 1-2, 11, 

84

Chromium None 94.6 mg/Kg 1.0 mg/Kg

Mercury None 0.23 mg/Kg 0.10 mg/Kg

SS-02C Soil 4/18/11

Chromium Unknown

141 J

(109) mg/Kg 0.9 mg/Kg

12, pp. 5-6; 14, p. 

10, 14; 61, p. 8; 

82, pp. 1-2, 11, 

64

SB-02 Soil 4/18/11 1,2,3,6,7,8-HxCDD None 6.93 ng/Kg 4.82 ng/Kg 12, pp. 5-6; 14, p. 

10, 14; 53, p. 8; 

74, pp. 1-2, 24, 

124

1,2,3,4,6,7,8-HpCDD None 200 ng/Kg 4.82 ng/Kg

1,2,3,4,6,7,8-HpCDF None 30.3 ng/Kg 4.82 ng/Kg

Arsenic None 39.2 mg/Kg 0.9 mg/Kg 12, pp. 5-6; 14, p. 

10, 14; 60, p. 13; 

81, pp. 1-2, 19, 

100

Barium None 91.6 mg/Kg 17.9 mg/Kg

Chromium None 870 mg/Kg 1.8 mg/Kg

Mercury None 0.22 mg/Kg 0.11 mg/Kg

SS-03A Soil 4/19/11 1,2,3,7,8,9-HxCDD None 5.37 ng/Kg 4.10 ng/Kg 12, pp. 6-8; 14, 

pp. 15-16; 53, p. 

4; 74, pp. 1-2, 13, 

113

1,2,3,4,6,7,8-HpCDD None 687 ng/Kg 4.10 ng/Kg

1,2,3,4,6,7,8-HpCDF None 77.1 ng/Kg 4.10 ng/Kg

Barium None 86.1 mg/Kg 20.4 mg/Kg 12, pp. 6-8; 14, 

pp. 15-16; 60, p. 

11; 81, pp. 1-2, 

12, 85

Chromium None 491 mg/Kg 1.0 mg/Kg

Mercury None 0.29 mg/Kg 0.10 mg/Kg

SB-03 Soil 4/19/11 Arsenic None 201 mg/Kg 1.6 mg/Kg 12, pp. 6-8; 14, 

pp. 15-16; 60, p. 

13; 81, pp. 1-2, 

Chromium None 58 mg/Kg 0.8 mg/Kg 20, 101
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 75 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-04A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 21.6 ng/Kg 4.82 ng/Kg 12, p. 13; 14, p. 

22-24; 56, p. 4; 

77, pp. 1-2, 9, 

104

1,2,3,7,8,9-HxCDD None 5.09 ng/Kg 4.82 ng/Kg

1,2,3,4,6,7,8-HpCDD None 694 ng/Kg 4.82 ng/Kg

2,3,7,8-TCDF None 5.75 ng/Kg 0.964 ng/Kg

1,2,3,4,6,7,8-HpCDF None 101 ng/Kg 4.82 ng/Kg

Chromium High

861 J

(667) mg/Kg 1.9 mg/Kg

12, p. 13; 14, p. 

22-24; 62, p. 13; 

83, pp. 1-2, 17, 

Mercury None 0.31 mg/Kg 0.11 mg/Kg 91

SS-04C Soil 4/21/11

Chromium Unknown

871 J

(675) mg/Kg 2.6 mg/Kg

12, pp. 13-14; 14, 

p. 22-24; 61, p. 8; 

82, pp. 1-2, 11, 

66

SS-05A Soil 4/20/11 1,2,3,4,6,7,8-HpCDD None 141 ng/Kg 4.83 ng/Kg 12, p. 10; 14, p. 

19-20; 54, p. 4; 

75, pp. 1-2, 11, 

1,2,3,4,6,7,8-HpCDF None 19.9 ng/Kg 4.83 ng/Kg 106

Chromium None 196 mg/Kg 0.8 mg/Kg 12, p. 10; 14, p. 

19-20; 60, p. 11; 

81, pp. 1-2, 12, 

Mercury None 0.23 mg/Kg 0.10 mg/Kg 86

SS-05C Soil 4/20/11

Chromium Unknown

755 J

(585) mg/Kg 2.1 mg/Kg

12, pp. 10-11; 14, 

pp. 19-20; 61, p. 

8; 82, pp. 1-2, 11, 

67

SB-05A Soil 4/20/11 Chromium High

2,930 J

(2,270) mg/Kg 8.2 mg/Kg

12, p. 10; 14, pp. 

19-21; 62, p. 12; 

83, pp. 1-2, 12, 

Mercury None 0.42 mg/Kg 0.12 mg/Kg 101

SS-06A Soil 4/19/11 1,2,3,4,6,7,8-HpCDD None 1,160 ng/Kg 43.0 ng/Kg 12, pp. 7-8; 14, p. 

15-16; 53, p. 5; 

74, pp. 1-2, 14, 

1,2,3,4,6,7,8-HpCDF None 134 ng/Kg 114

43.0

ng/Kg

Barium None 67.8 mg/Kg 15.0 mg/Kg 12, pp. 7-8; 14, p. 

15-16; 60, p. 11; 

81, pp. 1-2, 13, 

87

Chromium None 337 mg/Kg 0.7 mg/Kg

Mercury None 7.2 mg/Kg 1.08 mg/Kg
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 76 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-07A Soil 4/19/11 1,2,3,4,6,7,8-HpCDD None 885 ng/Kg 36.3 ng/Kg 12, pp. 7-8; 14, p. 

15-17; 54, p. 4; 

75, p. 1-2, 12, 

1,2,3,4,6,7,8-HpCDF None 96.2 ng/Kg 36.3 ng/Kg 107

Arsenic None 50 mg/Kg 0.8 mg/Kg 12, pp. 7-8; 14, p. 

15-17; 60, p. 11; 

81, pp. 1-2, 13, 

88

Chromium None 623 mg/Kg 2.3 mg/Kg

Mercury None 0.7 mg/Kg 0.11 mg/Kg

SS-07C Soil 4/19/11

Chromium Unknown

1,330 J

(1,031) mg/Kg 4.3 mg/Kg

12, pp. 7-8; 14, p. 

15-17; 61, p. 8; 

82, pp. 1-2, 11, 

69

SB-07A Soil 4/19/11 1,2,3,6,7,8-HxCDD None 5.94 ng/Kg 4.43 ng/Kg 12, pp. 7-8; 14, p. 

15-17; 54, p. 7; 

75, pp. 1-2, 21, 

116

1,2,3,4,6,7,8-HpCDD None 278 ng/Kg 4.43 ng/Kg

1,2,3,4,6,7,8-HpCDF None 26.7 ng/Kg 4.43 ng/Kg

Chromium High

93.9 J

(72.8) mg/Kg 0.9 mg/Kg

12, pp. 7-8; 14, p. 

15-17; 62, p. 12; 

83, pp. 1-2, 14, 

Mercury None 0.24 mg/Kg 0.11 mg/Kg 105

SS-08A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 7.78 ng/Kg 4.82 ng/Kg 12, pp. 9-10; 14, 

pp. 19-20; 54, p. 

4; 75, pp. 1-2, 13, 

108

1,2,3,4,6,7,8-HpCDD None 231 ng/Kg 4.82 ng/Kg

1,2,3,4,6,7,8-HpCDF None 42.7 ng/Kg 4.82 ng/Kg

Chromium High

93.1 J

(72.2) mg/Kg 0.8 mg/Kg

12, pp. 9-10; 14, 

pp. 19-20; 62, p. 

12; 83, pp. 1-2, 

Mercury None 0.15 mg/Kg 0.11 mg/Kg 11, 92

SS-08C Soil 4/20/11

Chromium None 1,730 mg/Kg 5.2 mg/Kg

12, pp. 9-11; 14, 

pp. 19-20; 63, p. 

8; 84, pp. 1-2, 9, 

55

SB-08A Soil 4/20/11 1,2,3,4,6,7,8-HpCDD None 74.6 ng/Kg 4.90 ng/Kg 12, pp. 9-11; 14, 

pp. 19-20; 54, p. 

8; 75, pp. 1-2, 23, 

1,2,3,4,6,7,8-HpCDF None 12.5 ng/Kg 4.90 ng/Kg 118

Chromium High

21,300 J

(16,500) mg/Kg 49.0 mg/Kg

12, pp. 9-11; 14, 

pp. 19-20; 62, p. 

13; 83, pp. 1-2, 

15, 107
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 77 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SB-08B Soil 4/20/11

Chromium High

19,100 J

(14,800) mg/Kg 52.1 mg/Kg

12, pp. 9-11; 14, 

p. 19-20; 62, p. 

13; 83, pp. 1-2, 

15, 108

SS-09A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 90.4 ng/Kg 4.83 ng/Kg 12, pp. 12-13; 14, 

p. 22-23; 55, p. 4; 

76, pp. 1-2, 9, 95 2,3,7,8-TCDF None 1.62 ng/Kg 0.967 ng/Kg

1,2,3,4,6,7,8-HpCDF None 14.2 ng/Kg 4.83 ng/Kg

Mercury Unknown

0.7 J

(0.38) mg/Kg 0.10 mg/Kg

12, pp. 12-13; 14, 

p. 22-23; 64, p. 

11; 85, pp. 1-2, 9, 

76

SS-09C Soil 4/21/11 Chromium

Unknown

83.8 J

(65.0) mg/Kg 0.8 mg/Kg

12, pp. 12, 14; 

14, p. 22; 61, p. 

9; 82, pp. 1-2, 11, 

70

SB-09A Soil 4/21/11

1,2,3,4,6,7,8-HpCDD None 64 ng/Kg 4.85 ng/Kg

12, pp. 12, 14; 

14, p. 22-24; 56, 

p. 7; 77, pp. 1-2, 

20, 113

SB-09B Soil 4/21/11

Barium None 70.1 mg/Kg 20.1 mg/Kg

12, pp. 12, 14; 

14, p. 22-24; 64, 

p. 12; 85, pp. 1-2, 

13, 86

SS-10A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 313 ng/Kg 49.1 ng/Kg 12, p. 13; 14, p. 

22-24; 56, p. 4; 

77, pp. 1-2, 10, 

1,2,3,4,6,7,8-HpCDF None 55.1 ng/Kg 49.1 ng/Kg 105

Barium None 68.5 mg/Kg 19.2 mg/Kg 12, p. 13; 14, p. 

22-24; 62, p. 13; 

83, pp. 1-2, 17, 

93

Chromium High

79.9 J

(61.9) mg/Kg 1.0 mg/Kg

Mercury None 0.39 mg/Kg 0.11 mg/Kg
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 78 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-11A Soil 4/21/11

1,2,3,4,6,7,8-HpCDF None 8.02 ng/Kg 4.83 ng/Kg

12, pp. 13-14; 14, 

p. 22, 25; 56, p. 

4; 77, pp. 1-2, 11, 

106

Chromium High

175 J

(136) mg/Kg 0.8 mg/Kg

12, pp. 13-14; 14, 

p. 22, 25; 62, p. 

14; 83, pp. 1-2, 

Mercury None 0.21 mg/Kg 0.11 mg/Kg 18, 94

SB-11A Soil 4/21/11

2,3,7,8-TCDF None 1.65 ng/Kg 0.955 ng/Kg

12, pp. 13-14; 14, 

p. 22, 25; 56, p. 

8; 77, pp. 1-2, 21, 

116

Arsenic None 43.7 mg/Kg 1.1 mg/Kg 12, pp. 13-14; 14, 

p. 25; 64, p. 12; 

85, pp. 1-2, 14, 

88

Barium None 191 mg/Kg 21.1 mg/Kg

Chromium None 780 mg/Kg 2.1 mg/Kg

SB-11B Soil 4/21/11 Barium None 74 mg/Kg 26.3 mg/Kg 12, pp. 13-14; 14, 

p. 22, 25; 64, p. 

12; 85, pp. 1-2, 

Chromium None 57.4 mg/Kg 1.3 mg/Kg 14, 89

SS-12A Soil 4/22/11 1,2,3,6,7,8-HxCDD None 52.5 ng/Kg 4.84 ng/Kg 12, pp. 15-16; 14, 

p. 26-28; 55, p. 4; 

76, pp. 1-2, 10, 

96

1,2,3,7,8,9-HxCDD None 25.4 ng/Kg 4.84 ng/Kg

1,2,3,4,6,7,8-HpCDD High

1,000 EB

(100) ng/Kg 4.84 ng/Kg

2,3,7,8-TCDF None 8.82 ng/Kg 0.969 ng/Kg

2,3,4,6,7,8-HxCDF None 31.4 ng/Kg 4.84 ng/Kg

1,2,3,4,6,7,8-HpCDF None 1,050 ng/Kg 4.84 ng/Kg

Barium None 859 mg/Kg 20.2 mg/Kg 12, pp. 15-16; 14, 

p. 26-28; 64, p. 

11; 85, pp. 1-2, 9, 

77

Chromium None 91.1 mg/Kg 1.0 mg/Kg

Mercury Unknown

0.63 J 

(0.34) mg/Kg 0.13 mg/Kg

SS-12C Soil 4/22/11 Arsenic None 91.1 mg/Kg 0.9 mg/Kg 12, pp. 15-16; 14, 

p. 26-28; 63, p. 9; 

Chromium None 437 mg/Kg 0.9 mg/Kg 84, pp.1-2, 9, 56
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 79 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SB-12 Soil 4/22/11 1,2,3,6,7,8-HxCDD None 6.60 ng/Kg 4.83 ng/Kg 12, pp. 15-16; 14, 

p. 26-28; 55, p. 6; 

76, pp. 1-2, 15, 

102

1,2,3,4,6,7,8-HpCDD None 309 ng/Kg 4.83 ng/Kg

2,3,7,8-TCDF None 2.78 ng/Kg 0.967 ng/Kg

1,2,3,4,6,7,8-HpCDF None 105 ng/Kg 4.83 ng/Kg

Arsenic None 77.3 mg/Kg 1.3 mg/Kg 12, pp. 15-16; 14, 

p. 26-28; 64, p. 

13; 85, pp. 1-2, 

15, 90

Barium None 923 mg/Kg 25.6 mg/Kg

Chromium None 173 mg/Kg 1.3 mg/Kg

Mercury None 0.58 mg/Kg 0.12 mg/Kg

SS-18A Soil 4/19/11

1,2,3,4,6,7,8-HpCDD None 105 ng/Kg 52.0 ng/Kg

12, pp. 6, 8; 14, 

p. 15; 53, p. 6; 

74, pp. 1-2, 19, 

119

Chromium None 72.5 mg/Kg 0.9 mg/Kg 12, pp. 6, 8; 14, 

p. 15; 60, p. 12; 

81, pp. 1-2, 16, 

Mercury None 0.24 mg/Kg 0.11 mg/Kg 93

SS-18C Soil 4/19/11 Chromium

Unknown

272 J

(211) mg/Kg 0.9 mg/Kg

12, pp. 6-8; 14, p. 

15; 61, p. 9; 82, 

pp. 1-2, 12, 77

SS-20A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 16.1 ng/Kg 4.80 ng/Kg 12, pp. 10-11; 14, 

p. 19-20; 56, p. 5; 

77, pp. 1-2, 12, 

107

1,2,3,4,6,7,8-HpCDD None 523 ng/Kg 4.80 ng/Kg

1,2,3,4,6,7,8-HpCDF None 71.1 ng/Kg 4.80 ng/Kg

Barium None 164 mg/Kg 17.2 mg/Kg 12, pp. 10-11; 14, 

p. 19-20; 62, p. 

14; 83, pp. 1-2, 

18, 95

Chromium High

169 J

(131) mg/Kg 0.9 mg/Kg

Mercury None 0.32 mg/Kg 0.10 mg/Kg

SS-20C Soil 4/20/11

Chromium Unknown

216 J

(167) mg/Kg 0.9 mg/Kg

12, pp. 10-11; 14, 

p. 19-20; 61, p. 

10; 82, pp. 1-2, 

12, 79

SS-21A Soil 4/20/11 1,2,3,4,6,7,8-HpCDD None 1,010 ng/Kg 54.4 ng/Kg 12, pp. 9-10; 14, 

p. 19; 54, p. 5; 

75, pp. 1-2, 14, 

1,2,3,4,6,7,8-HpCDF None 132 ng/Kg 54.4 ng/Kg 109

Barium None 73.6 mg/Kg 20.9 mg/Kg 12, pp. 9-10; 14, 

p. 19; 60, p. 12; 

81, pp. 1-2, 17, 

95

Chromium None 117 mg/Kg 1.0 mg/Kg

Mercury None 0.47 mg/Kg 0.10 mg/Kg
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 80 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-22A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 105 ng/Kg 4.72 ng/Kg 12, pp. 12-13; 14, 

p. 22-24; 56, p. 5; 

77, pp. 1-2, 13, 

1,2,3,4,6,7,8-HpCDF None 6.62 ng/Kg 4.72 ng/Kg 108

Barium None 74.6 mg/Kg 17.9 mg/Kg 12, pp. 12-13; 14, 

p. 22-24; 64, p. 

11; 85, pp. 1-2, 

Chromium None 53.5 mg/Kg 0.9 mg/Kg 10, 79

SS-22C Soil 4/21/11

Chromium None 72.9 mg/Kg 1.5 mg/Kg

12, pp. 12-14; 14, 

p. 22-24; 63, p. 8; 

84, pp. 1-2, 9, 58

SS-23A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 13.2 ng/Kg 4.82 ng/Kg 12, pp. 12-13; 14, 

p. 22-23; 56, p. 5; 

77, pp. 1-2, 14, 

109

1,2,3,4,6,7,8-HpCDD None 258 ng/Kg 4.82 ng/Kg

2,3,7,8-TCDF None 2.7 ng/Kg 0.965 ng/Kg

1,2,3,4,6,7,8-HpCDF None 57.8 ng/Kg 4.82 ng/Kg

Mercury None 0.80 mg/Kg 0.11 mg/Kg

12, pp. 12-13; 14, 

p. 22-23; 62, p. 

14; 83, pp. 1-2, 

19, 96

SS-24A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 768 ng/Kg 75.6 ng/Kg 12, pp. 12-13; 14, 

p. 22-23; 56, p. 6; 

77, pp. 1-2, 15, 

110

1,2,3,7,8,9-HxCDD None 205 ng/Kg 75.6 ng/Kg

1,2,3,4,6,7,8-HpCDD None 17,000 ng/Kg 75.6 ng/Kg

2,3,4,6,7,8-HxCDF None 116 ng/Kg 75.6 ng/Kg

1,2,3,4,6,7,8-HpCDF None 2,440 ng/Kg 75.6 ng/Kg

Barium None 165 mg/Kg 32.5 mg/Kg 12, pp. 12-13; 14, 

p. 22-23; 62, p. 

14; 83, pp. 1-2, 

19, 97

Chromium High

4430 J

(3,430) mg/Kg 16.2 mg/Kg

Mercury None 1.4 mg/Kg 0.16 mg/Kg

SS-24C Soil 4/21/11

Chromium None 152 mg/Kg 1.1 mg/Kg

12, pp. 12, 14; 

14, p. 22-23; 63, 

p. 8; 84, pp. 1-2, 

9, 60
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 81 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-25A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 159 ng/Kg 65.3 ng/Kg 12, pp. 9-10; 14, 

p. 19; 54, p. 5; 

75, pp. 1-2, 15, 

110

1,2,3,7,8,9-HxCDD None 135 ng/Kg 65.3 ng/Kg

1,2,3,4,6,7,8-HpCDD None 4,600 ng/Kg 65.3 ng/Kg

2,3,4,6,7,8-HxCDF None 94.5 ng/Kg 65.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 970 ng/Kg 65.3 ng/Kg

Arsenic None 45.2 mg/Kg 1.1 mg/Kg 12, pp. 9-10; 14, 

p. 19; 60, p. 12; 

81, pp. 1-2, 17, 

96

Barium None 71.2 mg/Kg 21.6 mg/Kg

Chromium None 1,030 mg/Kg 3.2 mg/Kg

Mercury None 0.85 mg/Kg 0.14 mg/Kg

SS-25C Soil 4/20/11 Arsenic None 59.4 mg/Kg 1.0 mg/Kg 12, pp. 9, 11; 14, 

p. 19; 63, p. 8; 

Chromium None 596 mg/Kg 2.0 mg/Kg 84, pp. 1-2, 9, 61

SS-26A Soil 4/19/11 1,2,3,6,7,8-HxCDD None 382 ng/Kg 61.8 ng/Kg 12, pp. 7-8; 14, p. 

15-16; 54, p. 5; 

75, pp. 1-2, 16, 

111

1,2,3,7,8,9-HxCDD None 140 ng/Kg 61.8 ng/Kg

1,2,3,4,6,7,8-HpCDD None 12,100 ng/Kg 61.8 ng/Kg

2,3,4,6,7,8-HxCDF None 84.8 ng/Kg 61.8 ng/Kg

1,2,3,4,6,7,8-HpCDF None 1,840 ng/Kg 61.8 ng/Kg

Barium None 173 mg/Kg 20.2 mg/Kg 12, pp. 7-8; 14, p. 

15-16; 62, p. 12; 

83, pp. 1-2, 11, 

98 Chromium High

2,770 J

(2,150) mg/Kg 10.1 mg/Kg

Mercury None 0.97 mg/Kg 0.13 mg/Kg

SS-26C Soil 4/19/11 Arsenic None 34.5 mg/Kg 0.9 mg/Kg 12, pp. 7-8; 14, p. 

15-16; 63, p. 8; 

Chromium None 827 mg/Kg 2.8 mg/Kg 84, pp. 1-2, 9, 62

SS-33A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 145 ng/Kg 4.75 ng/Kg 12, pp. 12-13; 14, 

p. 22-23; 55, p. 6; 

76, pp. 1-2, 14, 

1,2,3,4,6,7,8-HpCDF None 17.8 ng/Kg 4.75 ng/Kg 101

Chromium None 59.3 mg/Kg 0.9 mg/Kg

12, pp. 12-13; 14, 

p. 22-23; 64, p. 

12; 85, pp. 1-2, 

12, 84

SS-33C Soil 4/21/11

Chromium None 85.4 mg/Kg 0.7 mg/Kg

12, pp. 12, 14; 

14, p. 23; 63, p. 

8; 84, pp. 1-2, 9, 

66
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 82 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-35A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 7.92 ng/Kg 4.89 ng/Kg 12, pp. 12-13; 14, 

p. 22-23; 56, p. 6; 

77, pp. 1-2, 17, 

112

1,2,3,4,6,7,8-HpCDD None 157 ng/Kg 4.89 ng/Kg

2,3,7,8-TCDF None 1.92 ng/Kg 0.979 ng/Kg

1,2,3,4,6,7,8-HpCDF None 35 ng/Kg 4.89 ng/Kg

Mercury None 0.69 mg/Kg 0.12 mg/Kg

12, pp. 12-13; 14, 

p. 22-23; 62, p. 

14; 83, pp. 1-2, 

20, 100

SO-62 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 776 ng/Kg 75.3 ng/Kg 11, pp. 23, 25; 

13, pp. 39-40, 69; 

50, p. 7; 71, pp. 

1-2, 22, 120

1,2,3,7,8,9-HxCDD None 391 ng/Kg 75.3 ng/Kg

1,2,3,4,6,7,8-HpCDD None 21,900 ng/Kg 75.3 ng/Kg

2,3,4,6,7,8-HxCDF None 126 ng/Kg 75.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 2,840 ng/Kg 75.3 ng/Kg

Barium None 114 mg/Kg 36.9 mg/Kg 11, pp. 23, 25; 

13, pp. 39-40, 69; 

57, p. 14; 78, pp. 

1-2, 19, 97

Chromium None 10,700 mg/Kg 18.5 mg/Kg

Mercury None 1.3 mg/Kg 0.18 mg/Kg
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 83 HRS Documentation Record

MAD001031574 September 2012

Table 28 - Hazardous Substances Associated with Source No. 4 (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-63 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 167 ng/Kg 4.87 ng/Kg 11, pp. 23-24; 13, 

pp. 40, 69; 50, p. 

7; 71, pp. 1-2, 23, 

121-122

1,2,3,7,8,9-HxCDD None 34.8 ng/Kg 4.87 ng/Kg

1,2,3,4,6,7,8-HpCDD None 3260 ng/Kg 24.3 ng/Kg

2,3,7,8-TCDF None 3.59 ng/Kg 0.973 ng/Kg

2,3,4,6,7,8-HxCDF None 53.8 ng/Kg 4.87 ng/Kg

1,2,3,4,6,7,8-HpCDF None 829 ng/Kg 4.87 ng/Kg

Chromium None 768 mg/Kg 1.2 mg/Kg 11, pp. 23-24; 13, 

pp. 40, 69; 57, p. 

14; 78, pp. 1-2, 

Mercury None 0.67 mg/Kg 0.12 mg/Kg 19, 98

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin.

HpCDD= Heptachlorodibenzodioxin. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran. TCDF = Tetrachlorodibenzofuran.

J = The associated numerical value is an estimated quantity [61, p. 3; 62, p. 6; 64, p. 5; 141, p. B20; 142, pp. B-23-24].

EB = The associated compound or element was detected in rinsate blank samples collected for 

quality control [55, p. 4; 76, pp. 10, 96]. The potential contribution for carryover from non-dedicated 

sampling equipment has been evaluated. In most cases, the concentration of the analyte or compound 

observed in a sample is significantly greater than the concentration observed in the associated equipment 

blank. Therefore, the sample data can be used with a high degree of certainty to confirm the presence of 

the substance in the samples [44].

* = An explanation for the direction of bias is provided in Reference 71, Table 3; Reference 74, 

Table 3; Reference 75, Table 3; Reference 76, Table 3; Reference 77, Table 3; Reference 78; Reference 

81, Table 3; Reference 82, Table 3; Reference 83, Table 3; Reference 84, Table 3; and Reference 85, 

Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment. Based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination, for HRS purposes it is not required to adjust qualified source data. 

Although the fact sheet was not intended for application to source data, it has been applied in this 

situation to demonstrate the relative increase in contamination in the source samples over background 

levels and that the contaminants are present in the soil due to a release [140, pp. 4-8]. 

List of Hazardous Substances Associated with Source

1,2,3,6,7,8-HxCDD

1,2,3,7,8,9-HxCDD

1,2,3,4,6,7,8-HpCDD

2,3,7,8-TCDF

2,3,4,6,7,8-HxCDF

1,2,3,4,6,7,8-HpCDF

Arsenic

Barium

Chromium

Mercury
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 84 HRS Documentation Record

MAD001031574 September 2012

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY

On-site observations indicated that no portion of Source No. 4 has a maintained engineered cover or 

complete runoff control management systems [11, p. 26;]. No report of a natural or man-made liner was 

documented during source sampling activities [11, p. 26;]. Therefore, Source No. 4 does not have full 

containment, and the source yields a containment value of 10 [1, p. 51596 (Table 3-2)].

Table 29 - Hazardous Substances Available to Pathways

Containment Description

Containment 

Factor References

Gas release to air: NS NS

Particulate release to air: NS NS

Release to ground water: NS NS

Release via overland migration and/or flood: Based on the lack of liner, a 

maintained engineered cover, and any complete run-on control and runoff 

management systems, a Containment Factor Value of 10 has been assigned 

for release to the Surface Water Pathway for Source No. 4.

10

1, p. 51609 (Table 

3-2); 11, p. 26

NS = Not Scored.

2.4.2 HAZARDOUS WASTE QUANTITY

2.4.2.1 Hazardous Waste Quantity

The Hazardous Waste Quantity for Source No. 4 was assigned based on the Area Factor Value of a 

“contaminated soil” source type [1, p. 51591, Table 2-5, Section 2.4.2.1.4]. The Hazardous Constituent 

Quantity, Hazardous Wastestream Quantity, and Volume values were not evaluated for Source No. 4 

because insufficient information was available [1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, 

Table 2-5)]. 

2.4.2.1.1 Hazardous Constituent Quantity

Description

The hazardous constituent quantity for Source No. 4 could not be adequately determined according to the 

HRS requirements; that is, the total mass of all CERCLA hazardous substances in the source is not known 

and cannot be estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. There are 

insufficient historical and current data (Manifests, PRP records, State records, Permits, Waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA hazardous 

substances in the source and the associated releases from the source. Therefore, there is insufficient 

information to evaluate the associated releases from the source to calculate the hazardous constituent 

quantity for Source No. 4 with reasonable confidence.
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 85 HRS Documentation Record

MAD001031574 September 2012

Table 30 – Hazardous Constituent Quantity

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Hazardous Constituent Quantity Assigned Value: Not Scored

2.4.2.1.2 Hazardous Wastestream Quantity

Description

The hazardous wastestream quantity for Source No. 4 could not be adequately determined according to 

the HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and releases from the source is not known and cannot be estimated with 

reasonable confidence [1, p. 51591 (Section 2.4.2.1.2)]. There are insufficient historical and current data 

(Manifests, PRP records, State records, Permits, Waste concentration data, Annual reports, etc.) available 

to adequately calculate the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and the associated releases from the source. Therefore, there is insufficient 

information to adequately calculate or extrapolate the hazardous wastestream quantity for Source No. 4 

with reasonable confidence.

Table 31 – Hazardous Wastestream Quantity

Hazardous Wastestream Wastestream Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Sum of Wastestream Quantity/5,000 [1, p. 51591 (Table 2-5)]:

Hazardous Wastestream Quantity Assigned Value: Not Scored 

2.4.2.1.3 Volume

Description

The volume for Source No. 4 could not be adequately determined according to the HRS requirements 

because insufficient historical and current waste sampling data are available to adequately calculate the 

volume of the source (or the volume of the area of observed contamination) associated with the source 

with reasonable confidence [1, p. 51591 (Section 2.4.2.1.3)]. Insufficient historical or current sampling 

data are available to adequately estimate the depth of waste material within the source. Therefore, there is 

insufficient information to adequately calculate or estimate the volume for Source No. 4 with reasonable 

confidence.
Source Characterization

Source No. 4

Creese & Cook Tannery (Former) 86 HRS Documentation Record

MAD001031574 September 2012

Table 32 – Volume

Source 

Type

Description

(# drums or dimensions)

Units

(yd3) References

NS

NS = Not Scored.

The volume of a “contaminated soil” source, in yd3

, is divided by 2,500 to assign a volume assigned value 

to the source [1, p. 51591 (Table 2-5)]. 

Volume Assigned Value: 0

2.4.2.1.4 Area

Description

Based on sampling results and observations of the contaminated soil material contained within Source 

No. 4 (Water Street/MBTA Source), the areal extent of the source defined as part of this source 

characterization was documented using GPS (see Figure 2) [12, p. 1; 21]. Based on the information 

recorded as part of the EPA Site Inspection and SR, the area of the Water Street/MBTA Source (Source 

No. 4) was determined to be approximately 114,099 ft2 (see Figure 2) [12, p. 1; 21]. 

Table 33 – Area

Source Type Units (ft2) References

Contaminated Soil 114,099 Figure 2, 12, p. 1; 21

The area of a “contaminated soil” source, in ft2

, is divided by 34,000 to assign an area assigned value to 

the source [1, p. 51591, Table 2-5]. 

Sum (ft2

): 114,099

Equation for Assigning Value (1, p. 51591, Table 2-5): 114,099 ÷ 34,000 = 3.36

Area Assigned Value: 3.36

2.4.2.1.5 Source Hazardous Waste Quantity Value

The Hazardous Waste Quantity Value for Source No. 4 was assigned based on the Area Factor Value 

(3.36) [1, p. 51591 (Table 2-5)]. The Hazardous Constituent Quantity, Hazardous Wastestream Quantity, 

and Volume values were not evaluated for Source No. 4 because insufficient information was available 

[1, pp. 51590-51591 (Sections 2.4.2.1.1 and 2.4.2.1.2, Table 2-5)].

Highest HWQ value assigned from Ref. 1, Table 2-5: 3.36
Source Characterization

Summary

Creese & Cook Tannery (Former) 87 HRS Documentation Record

MAD001031574 September 2012

SUMMARY OF SOURCE DESCRIPTIONS

Table 34 – Summary of Source Descriptions

Source 

No.

Source 

HWQ

Value

Source 

Hazardous 

Constituent 

Quantity 

Complete? 

(Y/N)

Containment Factor Value by Pathway

Ground 

Water

(GW)

(Ref. 1, 

Table 3-2)

Surface Water (SW)* Air

Overland/ 

flood

(Ref. 1, 

Table 4-2)

GW to 

SW

(Ref. 1, 

Table 3-2)

Gas

(Ref. 1, 

Table 6-3)

Particulate

(Ref. 1, 

Table 6-9)

1 547.31 N NS 10 NS NS NS

2 462.23 N NS 10 NS NS NS

3 1,124.23 N NS 10 NS NS NS

4 3.36 N NS 10 NS NS NS

HWQ = Hazardous Waste Quantity.

NS = Not Scored.

No. = Number.

Total Source Hazardous Waste Quantity Value: 2,137.13

Other possible sources not scored:

Five source areas which include the Former Landfill Area A, Former Landfill Area B, the On-site 

Containment Cell, Former Beamhouse/Former Beamhouse Debris, and the 20 Cheever Street Parcel, have 

been documented as part of the facility operated by the Creese & Cook Co. These sources were not scored 

as they do not affect the overall Hazardous Waste Quantity because of the lack of information to 

sufficiently characterize the sources, and therefore they do not impact the overall site score. 

Former Landfill Area A:

A Massachusetts Department of Environmental Quality and Engineering (MA DEQE) memorandum 

dated February 1981, summarizing site conditions during an inspection of the facility, stated that sludge 

collected in detention basins was disposed of on site [38, p. 1; 39, p. 2]. As part of an Engineering Report 

completed by SP, the area herein referred to as Former Landfill Area A was described as an area where 

tanning operations accumulated waste piles consisting primarily of hides and animal scraps [34, pp. 13-

14, 18-19, 36-37, 39-45; 97, p. 5]. Former Landfill Area A was described as the area adjacent to the 

northeast exterior wall of the beamhouse [34, p. 40; 97, p. 5]. Sampling of leather scraps within the 

Former Landfill Area A indicated the presence of arsenic and chromium [34, pp. 40-46, 48]. A removal 

action conducted by SP on the facility property excavated material from Former Landfill Area A and 

secured the material in an On-site Containment Cell [34, p. 4; 36, p. 2; 46, p. 1; 48, p. 11; 97, p. 6; 123; 

124]. Subsequent sampling conducted by SP and REW indicated residual arsenic and chromium 

contamination within the Former Landfill Area A [97, pp. 38, 45]. As part of the EPA SR, Former 

Landfill Area A was observed to be a forested/low shrub area of uneven ground surface [11, p. 10]. 

Sampling conducted as part of the EPA SR indicated elevated concentrations of arsenic, chromium, and 
Source Characterization

Summary

Creese & Cook Tannery (Former) 88 HRS Documentation Record

MAD001031574 September 2012

dioxin/furan congeners [15]. This source was not scored, as its extent and associated hazardous substance 

require further investigation and its inclusion into this HRS evaluation would not impact the overall site 

score.

Former Landfill Area B: 

A MA DEQE memorandum dated February 1981, summarizing site conditions during an inspection of 

the facility, stated that sludge collected in detention basins was disposed of on site [38, p. 1; 39, p. 2]. As 

part of an Engineering Report completed by SP, the area herein referred to as Former Landfill Area B was 

described as an area where tanning operations accumulated waste piles consisting primarily of hides and 

animal scraps [34, pp. 13-14, 18-19, 36-37, 39-45; 97, p. 5]. Former Landfill Area B was described as the 

area between the Crane River and the existing cemetery (here assumed to be the Endicott- Russell Family 

Cemetery) [34, p. 40; 97, p. 5]. Waste material was observed at the surface of the former landfill to 

approximately 16 feet below ground surface [34, p. 40; 97, p. 5]. Sampling of waste material within the 

Former Landfill Area B indicated the presence of arsenic and chromium [34, pp. 40-46, 48]. A removal 

action conducted by SP, Inc. on the facility property excavated material from Former Landfill Area B and 

secured the material in an On-site Containment Cell [34, p. 4; 36, p. 2; 46, p. 1; 48, p. 11; 97, p. 6; 123; 

124]. Subsequent sampling conducted by SP and REW indicated residual arsenic and chromium 

contamination within the Former Landfill Area B [97, pp. 38-39, 45]. In addition, REW investigated an 

area directly adjacent to the Former Landfill Area B removal which is described later in this evaluation as 

Source No. 1 (Leather Scrap Pile) [97, p. 38-39]. As part of the EPA SR, Former Landfill Area B was 

observed to be a depressed area partially covered by gravel, with an elevated sewer line running along the 

southwestern boundary of the area [11, pp. 1-2, 11]. Sampling conducted as part of the EPA SR indicated 

elevated concentrations of arsenic, chromium, and dioxin/furan congeners [15]. This source was not 

scored as its extent and associated hazardous substance require further investigation and its inclusion into 

this HRS evaluation would not impact the overall site score.

On-site Containment Cell:

In October 1987, SP submitted an initial Tannery Waste Solidification Project plan, and in March 1988 

submitted a revised Tannery Waste Solidification Project plan which proposed a remedial action to 

treat/stabilize identified buried solid and sludge waste and dispose of treated waste in a designed on-site 

lined and capped containment cell [123, p. 3; 124]. Based on pilot tests conducted with on-site material, 

the excavated tannery wastes would be chemically fixed with flyash, lime, and cement and a deodorant 

added to limit odors [123, pp. 15, 27 (Figure 4); 124, p. 23]. Successfully treated waste material would 

then be backfilled into a 32-mil hyalon lined and capped cell [123, pp. 17-19, 27 (Figure 4); 124, p. 29]. 

From December 1989 to May 1990, the containment cell area was prepared and constructed, tannery 

wastes/sludge from Former Landfill Areas A and B and from Lagoons Area C (Former Sludge Lagoons)

were excavated, and soils were treated and stabilized, and backfilled into the constructed lined On-site 

Containment Cell [48, p. 11; 46, p. 1]. Chemical analysis of pre- and post-treated sludge material 

excavated from Former Landfill Areas A and B and the Former Sludge Lagoons indicated elevated 

concentrations of arsenic and chromium [48, pp. 12, 52, 54-59]. The final total estimated areas and 

volumes of tannery wastes moved to the containment cell and final as-built plans of the containment cell 

were not found in available documentation. A later estimated total of 5,000 yd3 of excavated tannery 

waste and sludge backfilled into the containment cell was presented by R.E.W. Environmental 

Consultants [47, p. 7]. The integrity of the On-site Containment Cell has not been investigated, and it is 

yet unknown if the waste contained within the structure is releasing to the environment [15]. Therefore, 

the On-site Containment Cell has not been scored as part of this evaluation. 
Source Characterization

Summary

Creese & Cook Tannery (Former) 89 HRS Documentation Record

MAD001031574 September 2012

Former Beamhouse/ Former Beamhouse Debris:

In April 1994, SP completed a Chapter 21E Site Assessment Report for Riversedge Realty Trust [48]. 

The site assessment report summarized the results of sampling investigations in preparation for 

demolition of the beamhouse conducted from 28 May to 4 June 1992 and post-demolition sampling of the 

former beamhouse pits and trenches in March-April 1994. Samples of trenches and pits, as well as wipe 

samples from the beamhouse walls, indicated the presence of chromium and phenols at elevated 

concentrations [48, pp. 24-29]. Post-cleanup pit and trench samples still indicated elevated concentrations 

of chromium [48, p. 30]. The investigation summary is not clear to what level the cleanup was completed. 

In November 2004, demolition of the former beamhouse reportedly occurred with the demolition debris 

piles staged on top of the intact floor/foundation [3; 110]. Further sampling of the building debris 

indicated the presence of ACM, including black mastic on concrete and transite [99; 112, p. 8; 114;122; 

137]. Sampling conducted as part of the EPA SR indicated elevated concentrations of arsenic, chromium, 

and dioxin/furan congeners [SR Report]. This source was not scored as its extent and associated 

hazardous substance require further investigation and its inclusion into this HRS evaluation would not 

impact the overall site score.

20 Cheever Street Parcel:

Limited investigations have been conducted on the 20 Cheever Street Parcel which, up until 1987, was

part of the facility property [16; 153]. Only one limited site investigation report, completed in 1984, was 

found in available documentation regarding the parcel. The 29 October 1984 Subsurface Hazardous 

Waste Investigation completed by SP, described the 20 Cheever Street Parcel as predominantly 

undisturbed except for the southern edge which contained large amounts of fill [153, p. 7]. Borings 

advanced as part of the Subsurface Hazardous Waste Investigation completed by SP on the 20 Cheever 

Street parcel indicated shallow debris and the presence of mercury above laboratory reporting limits [153, 

pp. 15-23]. Sampling conducted as part of the EPA SI indicated elevated concentrations of arsenic, 

barium, chromium, mercury, and dioxin/furan congeners [16]. This source was not scored as its extent 

and associated hazardous substance require further investigation and its inclusion into this HRS 

evaluation would not impact the overall site score.
Surface Water Overland Flow 

General 

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 OVERLAND/FLOOD MIGRATION COMPONENT

4.1.1 GENERAL CONSIDERATIONS 

The Creese & Cook Co. (Former) site is located within the Crane River System, which is located in the 

Beverly Harbor Drainage Area and is part of the North Shore Coastal Watersheds [144, pp. 1, 12, 69, 86]. 

The Crane River System is comprised of two freshwater streams that flow into Mill Pond in Danvers 

(Beaver Brook and Crane Brook) with the Crane River flowing from the outlet of Mill Pond [144, p. 79]. 

The Crane River is a small, freshwater tributary to the Danvers River estuary [149, p. 5]. Source areas 

associated with former tannery operations at the site are located within the Crane River drainage, 

designated as segment MA93-41, which extends 0.8 miles from the outlet pump house sluiceway on 

Purchase Street to the confluence with the Danvers River (see Figures 2, 4a, and 4b) [144, p. 86; 147, 

p.47]. The Crane River segment MA93-41 is listed as an estuary and designated by the state Integrated 

List of Waters as a Category 5, which denotes the segment as impaired and requiring one or more Total 

Maximum Daily Load studies [145, p. 22, 134; 147, p. 33]. In addition, Crane River segment MA93-41 is 

listed as a class SA water body, which denotes an excellent habitat for fish, other aquatic life and wildlife, 

including for their reproduction, migration, growth and other critical functions, and for primary and 

secondary contact recreation [146, p. 12; 147, p. 47]. 

The Creese & Cook Co leather tannery operated on portions of both sides of the Crane River [113, p. 5]. 

A summary of tannery operations was provided by W&C working on behalf of the property owner, and 

was as follows: ‘Initial treating and dehairing operations for tanning involve soaking the skins to treat 

them for infestation and to prepare the skins for the mechanical removal of hair. Soaking was typically 

done with either organic acid solution or arsenic solutions. These solutions frequently contained 

phthalates, which were added as a penetrant. Phthalates were also used in the finishing process in lacquers 

to aid in penetration to the chromed skins. Final dehairing typically involves scraping the skins in the 

presence of a strong basic solution or oxidant solution. Bating is primarily a pH adjusting step to 

neutralize and soften the skins prior to chroming, and was accomplished in an adjusting bath. All of the 

solution baths would have accumulated solids and/or lost their strength after a period of time, and would 

have been discharged to on-site lagoons prior to replenishing baths’ [113, p. 5]. According to W&C, 

beamhouse operations, including treatment, dehairing, and bating of skins prior to chroming and 

finishing, occurred on the portion of the facility located on the western shore of the Crane River [113, p. 

5]. Tanning and finishing activities were performed on the opposite (eastern shore) of the river [113, p. 5]. 

Discharge from dehairing and bating was directed to the on-site lagoons, located east of the beamhouse, 

before decanting into the Crane River [113, p. 5]. 

Based on a Department of the Interior topographic map, as well as site figures referencing a survey 

conducted by Hancock Survey Associates, the western Creese & Cook Tannery facility generally slopes 

toward the Crane River [19, p. 1; 97, p. 43 (Exhibit A); 129, p. 5 (C-1); 148, p. 2]. Three source areas 

have been evaluated on the western side of the Crane River and include the following: a pile of leather 

scraps and soil located directly adjacent to Crane River (see Source No. 1 Evaluation); a pile of soil 

material of unknown origin with documented site-related contaminants (see Source No. 2 Evaluation); 

and the Former Lagoons utilized by the tannery operations and located directly adjacent to the Crane 

River (see Source No. 3 Evaluation). No portions of Source Nos. 1 through 3 were observed to have a 

maintained engineered cover or complete runoff control management systems [11, p. 26]. No report of a 

natural or man-made liner was documented or observed during source sampling activities on these 

sources [11, p. 26]. 

Based on a Department of the Interior topographic and on-site observations, the eastern Creese & Cook 

Creese & Cook Tannery (Former) 90 HRS Documentation Record 

MAD001031574 September 2012 
Surface Water Overland Flow 

General 

Co. facility generally slopes toward the Crane River [11, p. 5; 12, p. 2; 19, p. 1]. One source area has been 

evaluated on the eastern side of the Crane River and is documented as a contaminated soil source 

associated with the Water Street and MBTA parcels (see Source No. 4 Evaluation). No portion of Source 

No. 4 was observed to have a maintained engineered cover or complete runoff control management 

systems [11, p. 26]. No report of a natural or man-made liner was documented or observed during source 

sampling activities on these sources [11, p. 26]. 

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component 

Source No. 1, which is located in the northern area of the western facility property, was observed to be 

sloping steeply toward the Crane River, with source matrix material containing leather scraps eroding 

from the pile and depositing into the river sediments [11, p. 17; 22]. Therefore, the hazardous substance 

migration path for Source No. 1 is defined by the direct contact of source materials with the Crane River. 

Site plans indicate that the area associated with Source No. 1 drops approximately 8 feet to the Crane 

River [129, p. 5 (C-1)]. The areal extent of Source No. 1 was mapped by documenting exposed leather 

scraps along the western bank of the Crane River; therefore, the most upstream probable point of entry 

(PPE) for the source is located at the most upstream point where the pile abuts the Crane River (PPE No. 

1) [11, pp. 17-18; 21]. 

Source No. 2, which is located in the northwestern area of the western facility property, adjacent to the 

former beamhouse building footprint, was observed to be a pile roughly 8 feet in height [11, p. 12; 129, p. 

5 (C-1)]. The area surrounding and contained by Source No. 2 slopes east toward the Crane River [129, p. 

5 (C-1)]. The overland segment of the hazardous substance migration path follows the gravel path, 

located north of the beamhouse footprint, east toward the Crane River [11, p. 14; 113, p. 19; 129, p. 5 (C1)]. The PPE for the source is along the base of the slope to the Crane River (PPE No. 2) [11, p. 17-18; 

113, p. 19; 129, p. 5 (C-1)]. 

Source No. 3, which is located in the southeastern area of the western facility property, adjacent to the 

Crane River, was observed to be bounded by raised earthen bermed material and is slightly depressed 

from the surrounding area [11, p. 11; 113, p. 19; 129, p. 5 (C-1)]. Based on multiple reference sources, 

discharge from the lagoons was directed into the Crane River through a discharge pipe [35, p. 2; 43, p. 1; 

113, p. 5]. In addition, liquid material contained within the surface impoundment source was documented 

to overtop the earthen berms and discharge into the Crane River [172, pp. 1-2]. The PPE for the source is 

the location where the discharge pipe empties into the Crane River (PPE No. 3) [11, p. 2; 113, p. 19; 129, 

p. 5 (C-1)]. 

Source No. 4, which is located on the southern and western area of the eastern facility property, was 

observed to be sloping west, toward the Crane River, with source matrix material containing leather 

scraps eroding from the bank and depositing into the river sediments [11, p. 16; 12, p. 2; 22]. In addition, 

stormwater drains located on the condominium portion of Source No. 4 drain directly into the Crane 

River [12, pp. 1-2]. This source borders directly onto the Crane River, and therefore contains numerous 

probable points of entry. The PPE for the source is the most upstream portion of the source that borders 

the river (PPE No. 4a). In addition, Source No. 4 represents the most downstream source for the site, and 

therefore, the target distance limit (TDL) is measured from the most downstream PPE associated with this 

source (PPE No. 4b) [1, p. 51605 (Section 4.1.1.2)]. 

Two of the source areas evaluated as part of this HRS Documentation Record border directly onto the 

Crane River (see Figure 2, and Source Nos. 1 and 4 Evaluation Sections). Source matrix materials 

containing leather scraps were observed eroding from these two source areas (Source Nos. 1 and 4) and 

depositing into the Crane River sediments [22]. In addition, based on multiple reference sources, 

discharge from the former wastewater lagoons (Source No. 3) was directed into the Crane River [35, p. 2; 

Creese & Cook Tannery (Former) 91 HRS Documentation Record 

MAD001031574 September 2012 
Surface Water Overland Flow 

General 

Creese & Cook Tannery (Former) 92 HRS Documentation Record 

MAD001031574 September 2012 

43, p. 1; 113, p. 5; 172, pp. 1-2]. Based on maps depicting the topography of the western facility property, 

the land surface elevation slopes from Source No. 2 toward the Crane River [113, p. 19; 129, p. 5 (C-1)]. 

The TDL for the Creese & Cook Tannery (Former) site extends from the most downstream PPE (PPE No. 

4b) for 15-miles, terminating in the Atlantic Ocean (see Figures 4a, 4b, and Section 4.1.1.2 of this HRS 

Evaluation). In addition, flow within the Crane River is reversed by tides, and the TDL extends upstream 

of PPE No. 1 (see Figures 4a, 4b, and Section 4.1.1.2 of this HRS Evaluation) [11, pp. 16, 18-20; 149, p. 

5; 150, pp. 132, 135]. 

4.1.1.2 Target Distance Limit

The most upstream PPE for the Creese & Cook Tannery (Former) site is PPE No. 1 associated with 

Source No. 1 (see Figure 4b) [41]. The most downstream PPE for the Creese & Cook Tannery (Former) 

site is PPE No. 4b which is associated with Source No. 4 and is 0.36 miles downstream of PPE No. 1 

[41]. Sediment sample SD-26 is the most downstream sediment sample collected as part of the EPA SR, 

while sediment sample SD-24 is the most downstream sample documenting an observed release to the 

Crane River through chemical analysis (see Section 4.1.2.1.1 of this HRS Evaluation) [13, pp. 12, 51, 80]. 

Therefore, as observed contamination is not documented more than 15 miles downstream of PPE No. 4b, 

the TDL extends 15 miles downstream of the PPE (see Figure 4b) [1, p. 51605 (Section 4.1.1.2)]. The 

TDL extends from the Crane River, through the Danvers River, to Beverly Harbor, which then extends 

into the Atlantic Ocean (see Figure 4a) [41]. 

In addition, flow within the Crane River is reversed by tides, and the TDL extends upstream of PPE No. 1 

(see Figure 4b and Section 4.1.1.2 of this HRS Evaluation) [11, pp. 16, 18-20; 149, p. 5; 150, pp. 132, 

135]. Based on sampling results outlined in Section 4.1.2.1.1 of this evaluation, sediments (SD-04) 

impacted by site-attributable hazardous substances have been documented immediately north of the MA 

Route 128 Bridge. Tidal influence has been documented through salinity observations to a location just 

south of the Purchase Street Bridge at sediment sample locations SD-03, SD-50, and SD-51 [11, pp. 18-

20, 25, 26]. A Massachusetts Division of Marine Fisheries study on Rainbow Smelt populations in the 

Crane River indicated the sluiceway just north of Purchase Street is located less than 100 meters upstream 

of the tidal interface of the Danvers River estuary [149, p. 5]. The TDL for the Creese & Cook Tannery 

(Former) site is evaluated only to the point where substances from the site have been documented 

upstream, which is to sediment sample location SD-04 [1, p. 51605 (Section 4.1.1.2)]. The TDL may 

extend upstream past this point, but this has not been confirmed to date. 
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 93 HRS Documentation Record

MAD001031574 September 2012

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release

Direct Observation

Basis for Direct Observation:

During reconnaissances of the property, portions of Source No. 1 (Leather Scrap Pile) and Source No. 4 

(Water Street/MBTA Source) were observed to be inundated by river flow during tidal fluctuations [11, 

pp. 16-20; 22]. Sources materials containing pieces of leather scraps were observed eroding from Source 

Nos. 1 and 4 and depositing directly into the river. Pieces of leather scraps within both the bank materials 

adjacent to the Crane River and within the river sediments adjacent to the riverbank were also observed

[11, pp. 17-19; 12, p. 2; 22]. Analysis of source materials containing leather scraps from Source Nos. 1 

and 4 indicated hazardous substances (dioxin/furan congeners and total metals) associated with the 

tannery at concentrations significantly exceeding background concentrations (see Source No. 1 and 

Source No. 4 Evaluation Sections of this Documentation Record). Analysis of the Crane River sediment 

samples adjacent to the river banks of Source Nos. 1 and 4, within the areas of direct observation, also 

confirmed the presence of hazardous substances (dioxin/furan congeners and total metals) at 

concentrations significantly exceeding background concentrations (see Chemical Analysis below) [11, 

pp., 24-25; 13, pp. 57-58; 22]. 

Hazardous Substances in Release:

Table 35 - Hazardous Substances in Observed Release by Direct Observation

Hazardous 

Substance Evidence References

1,2,3,6,7,8-HxCDD

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

1,2,3,7,8,9-HxCDD

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

2,3,7,8-TCDF

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

2,3,4,6,7,8-HxCDF

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

1,2,3,4,6,7,8-HpCDF

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

Chromium

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation

Mercury

Analysis of material containing leather scraps observed 

to be eroding out of sources and depositing into the 

Crane River.

11, pp. 24-25; 13, pp. 57-58; 22, 

Source Numbers 1 and 4 of this 

Evaluation
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 94 HRS Documentation Record

MAD001031574 September 2012

Chemical Analysis

Background Concentrations:

On 18 May 2011 and 6 December 2011, as part of the EPA SR, background sediment sampling activities 

were conducted [11, pp. 8-9, 24-26; 13, pp. 18-21, 41-44]. The background sediment samples were 

collected in accordance with the EPA-approved Site-Specific QAPP, dated 18 April 2011, and the SiteSpecific QAPP Addendum, dated 22 November 2011 [8, pp. 34, 37-45, 50; 9, pp. 2-3, 9 (Figure 4), 11, 

pp. 8, 24; 13, pp. 18, 41-42]. Three background sediment samples (SD-03, SD-50, and SD-51) were 

collected from the Crane River, south of Purchase Street and between 0.461 and 0.471 miles upstream of 

PPE No. 1 for the Creese & Cook Tannery (Former) site (see Figure 4b) [11, pp. 8-9, 18-20, 25-26; 13, 

pp. 18-19, 57-58; 23, p. 2]. The background and release sediment samples were collected from the 

estuarine Crane River segment MA93-41 (see Figure 4b) [145, p. 134; 147, p. 33]. Based on observations 

during the EPA SR, the locations of background sediment samples are influenced by tidal fluctuations, as 

evident from changes in salinity measurements and stream flow at the background sediment sample 

locations [11, p. 18]. A Massachusetts Division of Marine Fisheries study on rainbow smelt populations 

in the Crane River indicated the sluiceway just north of Purchase Street is located less than 100 meters 

upstream of the tidal interface of the Danvers River estuary [149, p. 5]. In addition, observations 

conducted during the EPA SR did not indicate additional major surface water inputs (rivers, streams, 

pipes) in the area of the background sediment sample locations downstream, through the TDL reach of 

the Creese & Cook Tannery (Former) site, to the Water Street Bridge [11, pp. 17-18]. The background 

sediment samples were collected from similar depths as the release samples, contained similar matrix 

material as the release samples, and were collected and analyzed using the same methods during the two 

sediment sampling events as the release samples [11, pp. 8, 25-26; 13 pp. 18-19, 57-58; 25, pp. 1-2, 4, 6, 

8-9, 13, 15-18, 20-22, 25-28, 30-32]. The three background sediment samples were used to establish 

reference chemical composition of the matrix materials within the Crane River System. This includes the 

establishment of the range of concentration variations for naturally occurring metals in the media of 

concern (sediment) located upstream of the Creese & Cook Tannery (Former) source areas, and the 

establishment of specific concentration values that demonstrate that a significant concentration of a 

hazardous substance is present above naturally occurring concentrations.

Table 36 - Background Sediment Sample Location Description

Sample 

ID

Sample 

Medium Sample Location

Depth

(inches) Date References

SD-03 Sediment

Crane River – south of Purchase 

Street and approximately 0.471 

miles upstream of PPE No. 1 0 to 12 5/18/11

11, pp. 8-9, 18-20, 25-26; 13, p. 

18-19; 23, p. 2; Figure 4b

SD-50 Sediment

Crane River – south of Purchase 

Street and approximately 0.466 

miles upstream of PPE No. 1 0 to 8 12/6/11

11, p. 25; 13, p. 43; 23, p. 2; 

Figure 4b

SD-51 Sediment

Crane River – south of Purchase 

Street and approximately 0.461 

miles upstream of PPE No. 1 0 to 8 12/6/11

11, p. 26; 13, p. 43; 23, p. 2; 

Figure 4b
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 95 HRS Documentation Record

MAD001031574 September 2012

Table 37 – Background Sediment Sample Description

Sample 

ID Sample Description Reference

SD-03 Black, organic rich silt, trace clay, trace fine-to-coarse sand. 25, p. 1

SD-50 Dark brown, silt and clay, trace fine-to-medium sand, little organics. 25, p. 25

SD-51 Dark brown, silt and clay, trace fine-to-medium sand, little organics. 25, p. 26

Background sediment sample SD-03 was submitted to CLP laboratories for dioxin/furan analyses 

following DLM02.2, and for total metals analysis following ISM01.2; while background sediment 

samples SD-50 and SD-51 were submitted to a CLP laboratory for total metals analysis only, following 

ISM01.3 [11, pp. 8-9, 27; 13, pp. 19, 58, 71; 28, p. 3; 29, pp. 3, 8; 66, pp. 1, 4; 68, p. 1, 12; 70, p. 1; 87, 

pp. 10, 94; 89, pp. 9, 78]. COCs for all background sediment samples collected as part of the 2011 EPA 

SR and presented in this HRS Documentation Record are provided in References 28 and 29. The 

applicable COC sections for the background sediment samples and all corresponding sample identifiers 

are provided in available COC, field notes reference documentation, and sample crosswalk [11, pp. 8-9, 

18-20, 25-26; 13, p. 18-19, 43; 25, pp. 1, 25-26; 28, p. 3; 29, pp. 3, 8]. The dioxin/furan analytical results 

were manually validated at a stage 4 level in accordance with the criteria specified in the USEPA SOW 

DLM02.2 and EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [66, p. 1]. The 

total metals analytical data were evaluated on a Tier II level in accordance with the Region I Tiered 

Organic and Inorganic Data Validation Guidelines dated November 2008 [68, p. 1; 70, p. 1]. The 

validation of dioxin/furan and total metals analytical results was conducted independently by designated 

chemists who were not involved in the sample collection and HRS evaluation [11, pp. 8-9, 18-20, 25-26; 

13, p. 18-19, 43; 66, pp. 1-3; 68, pp. 1-7]. Based on an examination of the background sediment sample 

collected and submitted for dioxin/furan analysis and the three background sediment samples collected 

and submitted for total metals analysis, the highest background hazardous substance concentrations are 

presented in Table 38. See below for further evaluation of background concentrations utilized in this HRS 

evaluation.

Table 38 - Hazardous Substances Associated with Background Sediment Samples

Sample

ID

Sample

Type Date

Hazardous

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-03 Sediment 5/18/11 1,2,3,6,7,8-HxCDD None 8.39 ng/Kg 7.86 ng/Kg 11, p. 8; 13, 

pp.19, 71; 66, p. 

4; 87, pp. 1-2, 10, 

94

SD-03 Sediment 5/18/11 1,2,3,7,8,9-HxCDD None 7.46 ng/Kg 7.86 ng/Kg

SD-03 Sediment 5/18/11 2,3,7,8-TCDF None 7.1 ng/Kg 1.57 ng/Kg

SD-03 Sediment 5/18/11 2,3,4,6,7,8-HxCDF None

2.97 J

(2.97) ng/Kg 7.86 ng/Kg

SD-03 Sediment 5/18/11 1,2,3,4,6,7,8-HpCDF None 62.8 ng/Kg 7.86 ng/Kg
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

Table 38 - Hazardous Substances Associated with Background Sediment Samples (Concluded)

Sample

ID

Sample

Type Date

Hazardous

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-03 Sediment 5/18/11 Chromium None 82.4 mg/Kg 1.89 mg/Kg 11, p. 8; 13, pp. 

19, 71; 68, p. 12; 

SD-03 Sediment 5/18/11 Mercury None 0.69 mg/Kg 0.19 mg/Kg 89, pp. 1-2, 9, 78

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

HxCDF= Hexachlorodibenzofuran. HpCDF= Heptachlorodibenzofuran.

TCDF = Tetrachlorodibenzofuran. CRQL = Contract Required Quantitation Limit.

J = The associated numerical value is an estimated quantity [141, p. B-20; 66, p. 4].

* = An explanation for the direction of bias is provided in Reference 87, Table 3; Reference 89, 

Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

following adjustment, based on the EPA Fact Sheet, Using Qualified Data to Document an Observed 

Release and Observed Contamination [140, pp. 4-8].

Based on an examination of the background sediment sample submitted for dioxin/furan analysis and the 

three background sediment samples submitted for total metals analysis, the highest numerical background 

value concentrations are presented in Table 38 and used to determine representative background 

concentrations for comparison of contaminated release samples. 

Dioxin/furan congeners 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, and 

1,2,3,4,6,7,8-HpCDF were detected in background sediment samples. The background concentration of 

1,2,3,6,7,8-HxCDD, 2,3,7,8-TCDF, and 1,2,3,4,6,7,8-HpCDF each exceeded the sample-adjusted CRQL;

and therefore, an observed release is established when the sample measurement is three times or more 

above the background concentration [1, p. 51589 (Table 2-3)].

Dioxin/furan congeners 1,2,3,7,8,9-HxCDD and 2,3,4,6,7,8-HxCDF were detected at concentrations 

below the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. An observed release is established for these 

two congeners when the release sample concentration is three times or more above the background 

concentration, since using the sample-adjusted CRQL for comparison would provide a lower threshold 

value [1, p. 51589 (Table 2-3)]. 

Chromium and mercury were each detected in background sediment samples above the sample-adjusted 

CRQL; and therefore, an observed release is established when the release sample concentration is three 

times or more above the background concentration [1, p. 51589 (Table 2-3)]. 

Contaminated Samples:

On 16 through 18 May 2011 and 6 December 2011, as part of the EPA SR of the Creese & Cook Co. 

(Former) 1 property, sediment sampling activities were conducted at locations both upstream and 

downstream of the Creese & Cook Tannery (Former) site [11, pp. 2-9, 20-24; 13, pp. 10-21, 41-44]. The 

sediment samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 18 

April 2011, and the Site-Specific QAPP Addendum, dated 22 November 2011 [8, pp. 34, 37-45, 50; 9, pp. 

2-3, 9 (Figure 4), 11, pp. 2-9, 20-24; 13, pp. 11, 14, 18, 41]. 
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 97 HRS Documentation Record

MAD001031574 September 2012

A total of 20 sediment samples (SD-04, SD-06, SD-08, SD-10, SD-11, SD-13, SD-15, SD-17, SD-18, 

SD-19, SD-20, SD-22, SD-23, SD-24, SD-56, SD-57, SD-59, SD-60, SD-61, and SD-70) were collected 

from the Crane River both upstream and downstream of the site, from immediately upstream (north) of 

the MA Route 128 Bridge and extending downstream to the Water Street Bridge (see Figure 4b) [11, pp. 

3-7, 24-25; 13, pp. 50, 57-58; 23, p. 2]. The release sediment samples were collected through the TDL

reach associated with the Creese & Cook Tannery (Former) on-site sources and from estuarine Crane 

River segment MA93-41 (see Figure 4b) [11, pp. 3-7, 24-25; 13, pp. 50, 57-58; 145, p. 134; 147, p. 33]. 

In addition, the release sediment samples were collected from similar depths as the background sediment 

samples, contained similar matrix material as the background sediment samples, and were collected and 

analyzed using the same methods during the two sediment sampling events as the background sediment 

samples [11, pp. 8, 25-26; 13, pp. 50, 57-58; 25, pp. 1-2, 4, 6, 8-9, 13, 15-18, 20-22, 25-28, 30-32].

Table 39 - Sediment Sample Location Description

Sample 

ID

Sample 

Medium Sample Location

Distance from 

PPE No. 1

Depth

(inches) Date References

SD-04 Sediment

Crane River – upstream of MA Route 

128 and Source No. 1

0.057 miles 

Upstream 0 to 6 5/17/11

11, p. 7; 23; 25, p. 

2; Figure 4b

SD-06 Sediment

Crane River – adjacent to Creese & 

Cook Co. (Former) 1 facility and 

Source No. 1

0.011 miles 

Downstream 0 to 12 5/17/11

11, p. 7; 23; 25, p. 

4; Figure 4b

SD-08 Sediment

Crane River - adjacent to Creese & 

Cook Co. (Former) 1 facility

0.163 miles 

Downstream 0 to 12 5/17/11

11, pp. 6-7; 23; 

25, p. 6; Figure 

4b

SD-10 Sediment

Crane River - adjacent to Creese & 

Cook Co. (Former) 1 facility

0.212 miles 

Downstream 0 to 12 5/17/11

11, pp. 6-7; 23; 

25, p. 8; Figure 

4b

SD-11 Sediment

Crane River – adjacent to eastern 

riverbank and upstream of Source No. 

4

0.129 miles 

Downstream 0 to 12 5/17/11

11, pp. 6-7; 23; 

25, p. 9; Figure 

4b

SD-13 Sediment

Crane River - adjacent to eastern 

riverbank and upstream of Source No. 

4

0.168 miles 

Downstream 6 to 12 5/16/11

11, pp. 3-5; 23; 

25, p. 11; Figure 

4b

SD-15 Sediment

Crane River - adjacent to eastern 

riverbank and upstream of Source No. 

4

0.230 miles 

Downstream 10 to 14 5/16/11

11, pp. 3-5; 23; 

25, p. 13; Figure 

4b

SD-17 Sediment

Crane River - adjacent to eastern 

riverbank and upstream of Source No. 

4

0.324 miles 

Downstream 12 to 18 5/16/11

11, pp. 3, 5; 23; 

25, p. 15; Figure 

4b

SD-18 Sediment

Crane River - adjacent to eastern 

riverbank and Source No. 4

0.262 miles 

Downstream 0 to 12 5/16/11

11, p. 5; 25, 23; p. 

16; Figure 4b

SD-19 Sediment

Crane River – adjacent to eastern 

riverbank and Source No. 4

0.308 miles 

Downstream 0 to 12 5/16/11

11, p. 5; 25, p. 17; 

Figure 4b
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 98 HRS Documentation Record

MAD001031574 September 2012

Table 39 - Sediment Sample Location Description (Concluded)

Sample 

ID

Sample 

Medium Sample Location

Distance from 

PPE No. 1

Depth

(inches) Date References

SD-20 Sediment

Crane River – adjacent to eastern 

riverbank and Source No. 4

0.366 miles 

Downstream 0 to 12 5/16/11

11, pp. 5, 7; 23; 

25, p. 18; Figure 

4b

SD-22 Sediment

Crane River – downstream of the site 

and adjacent to MBTA Right-of-way 

bridge

0.473 miles 

Downstream 0 to 12 5/16/11

11, pp. 4-5; 23; 

25, p. 20; Figure 

4b

SD-23 Sediment

Crane River – downstream of the site 

and adjacent to MBTA Right-of-way 

bridge

0.531 miles 

Downstream 0 to 12 5/16/11

11, pp. 4-5; 23; 

25, p. 21; Figure 

4b

SD-24 Sediment

Crane River – downstream of the site 

and adjacent to Water Street Bridge

0.649 miles 

Downstream 0 to 12 5/16/11

11, pp. 3-5; 23; 

25, p. 22; Figure 

4b

SD-56/

SD-70 Sediment

Crane River – adjacent to the western 

riverbank and Source No. 1

0.020 miles 

Downstream 0 to 12 12/6/11

11, p. 25; 23; 25, 

p. 27; Figure 4b

SD-57 Sediment

Crane River – adjacent to the western 

riverbank and Source No. 1

0.023 miles 

Downstream 2 to 12 12/6/11

11, p. 25; 23; 25, 

p. 28; Figure 4b

SD-59 Sediment

Crane River - adjacent to the western 

riverbank and Source No. 3

0.246 miles 

Downstream 0 to 8 12/6/11

11, p. 25; 23; 25, 

p. 30; Figure 4b

SD-60 Sediment

Crane River – adjacent to the eastern 

riverbank and Source No. 4

0.343 miles 

Downstream 0 to 12 12/6/11

11, p. 24; 23; 25, 

p. 31; Figure 4b

SD-61 Sediment

Crane River – adjacent to the eastern 

riverbank and Source No. 4

0.352 miles 

Downstream 0 to 8 12/6/11

11, p. 24; 23; 25, 

p. 32; Figure 4b

Table 40 – Sediment Sample Description

Sample 

ID Sample Description Reference

SD-04 Wet, dark brown, silt and organics (rootlets), trace fine-to-coarse sand, trace clay. 25, p. 2

SD-06 Wet, black, silt and clay, little organics (rootlets). 25, p. 4

SD-08 Wet, dark gray, silt and clay, trace fine sand, trace organics (rootlets). 25, p. 6

SD-10 Wet, dark gray, clay and silt, trace fine-to-coarse sand, trace organics (rootlets). 25, p. 8

SD-11 Wet, dark gray-to-black, silt, little clay, trace fine-to-coarse sand, trace fine gravel. 25, p. 9

SD-13 Was not described in the field. 25, p. 11

SD-15

Wet, dark brown, silt and organics, little clay, trace fine-to-coarse sand, trace fine-to-medium 

gravel.

25, p. 13

SD-17

Wet, dark brown-to-dark gray, silt and organics, little clay, trace fine-to-coarse sand, trace 

fine-to-medium gravel.

25, p. 15

SD-18 Wet, dark gray-to-brown, clay and silt, little organics (peat, shells), trace fine-to-coarse sand. 25, p. 16
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 99 HRS Documentation Record

MAD001031574 September 2012

Table 40 – Sediment Sample Description (Concluded)

Sample 

ID Sample Description Reference

SD-19

Wet, dark gray-to-black, clay and silt, trace fine-to-coarse sand, trace fine gravel, trace 

organics.

25, p. 17

SD-20

Wet, dark grayish-black, silt and clay, trace fine-to-coarse sand, trace fine gravel, trace 

organics.

25, p. 18

SD-22

Wet, dark gray-to-olive gray, silt, some clay, trace fine-to-coarse sand, trace organics 

(rootlets).

25, p. 20

SD-23

Wet, dark gray-to-dark olive gray, silt, little clay, trace fine-to-coarse sand, trace organics 

(rootlets, shells)

25, p. 21

SD-24 Wet, gray-to-olive gray, silt, little clay, and trace organics (rootlets, shells). 25, p. 22

SD-56/

SD-70

Wet, dark brown, organic-rich clay and silt, trace fine-to-coarse sand, trace debris (glass, 

wood, leather scraps, tile).

25, p. 27

SD-57 Wet, dark brown, organic-rich silt, little fine-to-medium sand, trace clay, trace coarse sand. 25, p. 28

SD-59 Wet, dark brown, clay and silt, little organics (rootlets, plant debris), trace fine-to-coarse sand. 25, p. 30

SD-60 Wet, dark brown, organic-rich silt, trace fine-to-medium sand. 25, p. 31

SD-61

Wet, dark brown, silt and clay, little fine-to-coarse sand, little debris (glass, tile, plastic), little 

fine-to-medium gravel, little organics (roots, plant material).

25, p. 32

Fourteen of the 20 sediment samples (SD-04, SD-06, SD-08, SD-10, SD-11, SD-13, SD-15, SD-17, SD18, SD-19, SD-20, SD-22, SD-23, and SD-24) were submitted to CLP laboratories for dioxin/furan 

analyses following DLM02.2, and for total metals analysis following ISM01.2; while the remaining six 

sediment samples (SD-56, SD-57, SD-59, SD-60, SD-61, and SD-70) were submitted to CLP laboratories 

for dioxin/furan analyses following DLM02.2, and for total metals analysis following ISM01.3. COCs for 

all sediment samples collected as part of the 2011 EPA SR and presented in this HRS Documentation 

Record are provided in References 28 and 29. The applicable COC sections for the surface water pathway 

samples and all corresponding sample identifiers are provided in available COC, field notes reference 

documentation, and sample crosswalk [11, pp. 3-7, 24-25; 13, pp. 12-17, 41-43, 71-85; 28, pp. 1-4, 12; 

29, pp. 1-4, 8]. The dioxin/furan analytical results were manually validated at a stage 4 level in 

accordance with the criteria specified in the USEPA SOW DLM02.2 and EPA Region I’s ESAT 

Dioxin/Furan Data Validation SOP ESAT-01-0007 [50, p. 1; 65, p. 1; 66, p. 1; 67, p. 1]. The total metals 

analytical data were evaluated on a Tier II level in accordance with the Region I Tiered Organic and 

Inorganic Data Validation Guidelines dated November 2008 [68, p. 1; 69, p. 1; 70, p. 1]. The validation of 

dioxin/furan and total metals analytical results was conducted independently by designated chemists who 

were not involved in the sample collection and HRS evaluation [11, pp. 3-7, 24-25; 13, pp. 12-17, 41-43, 

71-85; 25, pp. 2,4,6,8,9,11,13,15-22, 27,28,30-32; 50, pp. 1-3; 65, pp. 1-3; 67, pp. 1-3; 68, pp. 1-7; 69, pp. 

1-7; 70, pp. 1-6].

Among the 20 selected sediment samples: 1,2,3,6,7,8-HxCDD was detected at a maximum concentration 

of 255 ng/Kg in sediment sample SD-60; 1,2,3,7,8,9-HxCDD was detected at a maximum concentration 

of 103 ng/Kg in sediment sample SD-60; 2,3,7,8-TCDF was detected at a maximum concentration of 45.3 

ng/Kg in sediment sample SD-60; 2,3,4,6,7,8-HxCDF was detected at a maximum concentration of 494 

ng/Kg in sediment sample SD-60; 1,2,3,4,6,7,8-HpCDF was detected at a maximum concentration of 

4,850 ng/Kg in sediment sample SD-60; chromium was detected at a maximum concentration of 9,240 J 

EB mg/Kg in sediment sample SD-56; and mercury was detected at a maximum concentration of 9.3 
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 100 HRS Documentation Record

MAD001031574 September 2012

mg/Kg in sediment sample SD-15 [13, pp. 12-16, 41-43, 76-85; 66, p. 5; 67, p. 4; 68, p. 13; 70, p. 10; 87, 

pp. 13, 97; 88, pp. 7, 94; 89, pp. 15, 89; 91, pp. 11, 63]. 

Table 41 - Hazardous Substances Associated with Sediment Samples

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-04 Sediment 5/17/11

Chromium None 763 mg/Kg 2.4 mg/Kg

11, p. 7; 13, pp. 

17, 71; 68, p. 

12; 89, pp. 1-2, 

10, 79

SD-06 Sediment 5/18/11 Chromium None 1,670 mg/Kg 4.5 mg/Kg 11, p. 7; 13, pp. 

17, 72; 68, p. 

12; 89, pp. 1-2, 

Mercury None 3.0 mg/Kg 0.19 mg/Kg 11, 81

SD-08 Sediment 5/17/11 Chromium None 2,140 mg/Kg 7.0 mg/Kg 11, pp. 6-7; 13, 

pp. 16, 72; 68, 

p. 13; 89, pp. 1-

Mercury None 3.4 mg/Kg 0.23 mg/Kg 2, 12, 83

SD-10 Sediment 5/17/11

Chromium None 592 mg/Kg 2.0 mg/Kg

11, p. 6; 13, pp. 

16, 73; 68, p. 

13; 89, pp. 1-2, 

13, 85

SD-11 Sediment 5/17/11

Chromium None 562 mg/Kg 1.4 mg/Kg

11, p. 7; 13, pp. 

16-17, 73; 68, p. 

13; 89, pp. 1-2, 

13, 86

SD-13 Sediment 5/16/11 1,2,3,6,7,8-HxCDD None 76.5 ng/Kg 42.5 ng/Kg 11, p. 4; 13, pp. 

13, 74; 65, p. 4; 

86, pp. 1-2, 9, 

1,2,3,7,8,9-HxCDD None 61.2 ng/Kg 42.5 ng/Kg 100

Chromium Unknown

1,110 J

(860) mg/Kg 2.9 mg/Kg

11, p. 4; 13, pp. 

13, 74; 69, p. 

12; 90, pp. 1-2, 

Mercury None 2.5 mg/Kg 0.19 mg/Kg 9, 72

SD-15 Sediment 5/16/11

1,2,3,6,7,8-HxCDD None 31.4 ng/Kg 16.2 ng/Kg

11, p. 4; 13, pp. 

12-13, 75; 65, p. 

4; 86, pp. 1-2, 

10, 101

Chromium None 766 mg/Kg 3.1 mg/Kg 11, p. 4; 13, pp. 

12-13, 75; 68, p. 

13; 89, pp. 1-2, 

Mercury None 9.3 mg/Kg 0.94 mg/Kg 15, 89
Surface Water Overland Flow

Likelihood of Release

Creese & Cook Tannery (Former) 101 HRS Documentation Record

MAD001031574 September 2012

Table 41 - Hazardous Substances Associated with Sediment Samples (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-17 Sediment 5/16/11 1,2,3,6,7,8-HxCDD None 56.9 ng/Kg 19.0 ng/Kg 11, p. 3; 13, pp. 

16, 76; 65, p. 5; 

86, pp. 1-2, 12, 

1,2,3,7,8,9-HxCDD None 35.8 ng/Kg 19.0 ng/Kg 103

Chromium Unknown

561 J

(435) mg/Kg 1.3 mg/Kg

11, p. 3; 13, pp. 

16, 76; 69, p. 

12; 90, pp. 1-2, 

Mercury None 2.3 mg/Kg 0.15 mg/Kg 10, 74

SD-18 Sediment 5/16/11

Chromium Unknown

340 J

(264) mg/Kg 1.2 mg/Kg

11, p. 5; 13, pp. 

13, 77; 69, p. 

12; 90, pp. 1-2, 

10, 75

SD-19 Sediment 5/16/11 1,2,3,6,7,8-HxCDD None 176 ng/Kg 17.2 ng/Kg 11, p. 5; 13, pp. 

14, 77; 65, p. 5; 

86, pp. 1-2, 14, 

105

1,2,3,7,8,9-HxCDD None 63.4 ng/Kg 17.2 ng/Kg

2,3,4,6,7,8-HxCDF None 21.2 ng/Kg 17.2 ng/Kg

Chromium Unknown

1,890 J

(1465) mg/Kg 4.6 mg/Kg

11, p. 5; 13, pp. 

14, 77; 69, p. 

12; 90, pp. 1-2, 

Mercury None 3.0 mg/Kg 0.22 mg/Kg 11, 76

SD-20 Sediment 5/16/11 1,2,3,6,7,8-HxCDD None 71.9 ng/Kg 15.7 ng/Kg 11, p. 5; 13, pp. 

14, 78; 65, p. 6; 

86, pp. 1-2, 15, 

1,2,3,7,8,9-HxCDD None 32.9 ng/Kg 15.7 ng/Kg 107

Chromium Unknown

1,560 J

(1,210) mg/Kg 3.5 mg/Kg

11, p. 5; 13, pp. 

14, 78; 69, p. 

12; 90, pp. 1-2, 

Mercury None 3.4 mg/Kg 0.32 mg/Kg 11, 77

SD-22 Sediment 5/16/11

Chromium Unknown

929 J

(720) mg/Kg 2.7 mg/Kg

11, p. 4; 13, pp. 

13, 79; 69, p. 

13; 90, pp. 1-2, 

Mercury None 2.1 mg/Kg 0.20 mg/Kg 12, 79

SD-23 Sediment 5/16/11

Chromium Unknown

948 J

(735) mg/Kg 2.0 mg/Kg

11, p. 4; 13, pp. 

13, 79; 69, p. 

13; 90, pp. 1-2, 

13, 80
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

Table 41 - Hazardous Substances Associated with Sediment Samples (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-24 Sediment 5/16/11 1,2,3,6,7,8-HxCDD None 244 ng/Kg 20.4 ng/Kg 11, pp. 3-4; 13, 

pp. 12, 80; 65, 

p. 7; 86, pp. 1-2, 

19, 111

1,2,3,7,8,9-HxCDD None 62.7 ng/Kg 20.4 ng/Kg

2,3,7,8-TCDF None 21.5 ng/Kg 4.08 ng/Kg

2,3,4,6,7,8-HxCDF None 23.6 ng/Kg 20.4 ng/Kg

Chromium Unknown

1,740 J

(1,350) mg/Kg 4.1 mg/Kg

11, pp. 3-4; 13, 

pp, 12, 80; 69, 

p. 13; 90, pp. 1-

Mercury None 3.1 mg/Kg 2, 13, 81 0.22 mg/Kg

SD-56 Sediment 12/6/11 1,2,3,6,7,8-HxCDD None 66.3 ng/Kg 6.38 ng/Kg 11, p. 25; 13, 

pp. 43, 83; 50, 

p. 8; 71, pp. 1-2, 

1,2,3,4,6,7,8-HpCDF None 195 ng/Kg 6.38 ng/Kg 25, 129

Chromium Unknown

9,240 J EB

(7,160) mg/Kg 14.5 mg/Kg

11, p. 25; 13, 

pp. 43, 83; 70, 

p. 10; 91, pp. 1-

2, 11, 63

SD-57 Sediment 12/6/11

Chromium Unknown

466 J EB

(361) mg/Kg 1.7 mg/Kg

11, p. 25; 13, 

pp. 43, 83; 70, 

p. 10; 91, pp. 1-

2, 11, 64

SD-59 Sediment 12/6/11 1,2,3,6,7,8-HxCDD None 28.2 ng/Kg 5.42 ng/Kg 11, p. 25; 13, 

pp. 42, 84; 50, 

p. 9; 71, pp. 1-2, 

1,2,3,4,6,7,8-HpCDF None 191 ng/Kg 5.42 ng/Kg 28, 132

Chromium Unknown

1,320 J EB 

(1,020) mg/Kg 2.3 mg/Kg

11, p. 25; 13, 

pp. 42, 84; 70, 

p. 10; 91, pp. 1-

2, 12, 66

SD-60 Sediment 12/6/11 1,2,3,6,7,8-HxCDD None 255 ng/Kg 93.3 ng/Kg 11, p. 24; 13, 

pp. 42, 85; 67, 

p. 4; 88, pp. 1-2, 

7, 94

1,2,3,7,8,9-HxCDD None 103 ng/Kg 93.3 ng/Kg

2,3,7,8-TCDF None 45.3 ng/Kg 18.7 ng/Kg

2,3,4,6,7,8-HxCDF None 494 ng/Kg 93.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 4,850 ng/Kg 93.3 ng/Kg

Chromium Unknown

2,810 J EB

(2,180) mg/Kg 4.6 mg/Kg

11, p. 24; 13, 

pp. 42, 85; 70, 

p. 10; 91, pp. 1-

2, 13, 67
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

Table 41 - Hazardous Substances Associated with Sediment Samples (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SD-61 Sediment 12/6/11

Chromium Unknown

449 J EB

(348) mg/Kg 1.6 mg/Kg

11, p. 24; 13, 

pp. 41, 85; 70, 

p. 11; 91, pp. 1-

2, 13, 68

SD-70 Sediment 12/6/11 1,2,3,6,7,8-HxCDD None 98.2 ng/Kg 6.37 ng/Kg 11, p. 25; 13, 

pp. 43, 85; 67, 

p. 4; 88, pp. 1-2, 

9, 96

2,3,4,6,7,8-HxCDF None 9.51 ng/Kg 6.37 ng/Kg

1,2,3,4,6,7,8-HpCDF None 298 ng/Kg 6.37 ng/Kg

Chromium Unknown

9,110 J EB

(7,060) mg/Kg 15 mg/Kg

11, p. 25; 13, 

pp. 43, 85; 70, 

p. 11; 91, pp. 1-

2, 14, 69

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

J = The associated numerical value is an estimated quantity [142; 69, pp. 12-13; 70, pp. 10-11].

EB = The associated compound or element was detected in rinsate blank samples collected for 

quality control [70, pp. 10-11]. The potential contribution for carryover from non-dedicated sampling 

equipment has been evaluated. In most cases, the concentration of the analyte or compound observed in a 

sample is significantly greater than the concentration observed in the associated equipment blank. 

Therefore, the sample data can be used with a high degree of certainty to confirm the presence of the 

substance in the samples [44].

* = An explanation for the direction of bias is provided in Reference 71, Table 3; Reference 86, 

Table 3; Reference 88, Table 3; Reference 89, Table 3; Reference 90, Table 3; Reference 91, Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

after adjustment. Analytical adjustments are based on the EPA Fact Sheet, Using Qualified Data to 

Document an Observed Release and Observed Contamination [140, pp. 4-8]. 

Attribution:

During reconnaissances of the property, portions of Source No. 1 (Leather Scrap Pile) and Source No. 4 

(Water Street/MBTA Source) were observed to be inundated by river flow during tidal fluctuations [11, 

pp. 16-20; 22]. Sources materials containing pieces of leather scraps were observed eroding from Source 

Nos. 1 and 4 and depositing directly into the river. Pieces of leather scraps within both the bank materials 

adjacent to the Crane River and within the river sediments adjacent to the riverbank were also observed

[11, pp. 17-19; 12, p. 2; 22]. Chemical analysis of source materials containing leather scraps from Source 

Nos. 1 and 4 indicated hazardous substances (dioxin/furan congeners and total metals) associated with the 

tannery at concentrations significantly exceeding background concentrations (see Source No. 1 and 

Source No. 4 Evaluation Sections of this Documentation Record). Chemical analysis of the Crane River 

sediment samples adjacent to the riverbanks of Source Nos. 1 and 4, within the areas of direct 

observation, also confirmed the presence of hazardous substances (dioxin/furan congeners and total 

metals) at concentrations significantly exceeding background concentrations (see Chemical Analysis 

section above) [11, pp. 24-25; 13, pp. 57-58; 22]. 
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

Historical environmental investigations of the Crane River and properties in the area indentified several 

potential contributors to contamination of the Crane River sediments, including the Creese & Cook 

Tannery (Former) property.

In June 2005, Geological Field Services, Inc. (GFS), completed an assessment of existing site-specific 

and area-wide data to identify additional sources of likely contamination to sediments in the Crane River 

[129, p. 1]. GFS concluded that there are elevated arsenic and chromium concentrations in the sediments 

adjacent to the site and within the estuarine system, and that there were numerous tanneries and farms that 

historically discharged process water and stormwater to the Crane River [129, p. 1]. As part of the 

sediment assessment, GFS summarized existing sediment sampling conducted as part of investigations of 

the western facility property, which indicated elevated levels of arsenic and chromium in sediments 

adjacent to Source No. 1 and Source No. 3 (see Figure 4a) [129, pp. 1-3, 5-6]. In addition, GFS presented 

a study of the Porter River, Danvers River, Crane River, and Water Rivers, completed by REW, which

indicated that the highest concentrations of arsenic and chromium were detected from the samples 

collected from the Crane River [129, pp. 9-16]. GFS further stated that samples representing the lower 

end of the Porter River, Danvers River, and Water Rivers appear to be within the expected background 

range [129, pp. 9-16]. GFS also collected shallow and deep sediment samples from areas adjacent to the 

western facility property which were submitted to Toxikon Corporation for arsenic analysis [129, pp. 2-3, 

5, 8, 74-105]. Analytical results of the sampling indicated elevated concentrations of arsenic in the 

shallow sediments compared to deeper sediments [129, pp. 2-3, 5, 8]. 

In addition, as part of the GFS investigation, a Sanborn Map Report was prepared by Environmental Data 

Resources Inc [129, pp. 103-128]. The Sanborn Map Report indicated the presence of five former 

tanneries along Crane Brook and Beaver Brook, directly upstream of the Creese & Cook Tannery 

(Former) site [129, pp. 104-106]. These five former tanneries existed up until approximately 1916 and 

were located upstream of Purchase Street and the Creese and Cook Tannery (Former) site [19; 129, pp. 

104-106]. Background sediment samples SD-03, SD-50, and SD-51 were collected south of Purchase 

Street, downstream of all identified possible upstream tannery sources to the Crane River (see Table 41) 

[11, pp. 8, 25-26; 13, pp. 50, 57-58; 25, pp. 1, 25-26]. In addition, the Sanborn Map Report identified one 

additional former tannery (Cross & Murphy Morocco) downstream of the Creese & Cook Tannery

(Former) facility properties (which will be discussed further within this section of the Record, see below)

[19; 129, pp.105-106, 111]. 

A review of available information was conducted to identify other potential sources of dioxin, chromium, 

and mercury contamination in the area of the Creese & Cook Tannery (Former) site. As part of the review 

effort, a search of the Searchable Waste Site List/Site Files for the Massachusetts Department of 

Environmental Protection (MassDEP) was conducted [157]. This database allows sites and reportable 

releases to be searched and identified by the following attributes: Town, Address, Release Tracking 

Number (RTN), Site Name, Status, and Licensed Site Professional (LSP) [157]. This service allows users 

to retrieve a report once the data relative to it have been approved by MassDEP for public viewing [157]. 

As part of the potential source search, the database was queried for the following site criteria: Town equal 

to Town of “Danvers”, which identified 238 spill records [157]. 

In July 1995, Gulf of Maine Research Center, Inc. (GMRC), completed a Phase I Assessment 

Comprehensive Subsurface Investigation of the property located at 24 Water Street (RTN 3-10524) and 

the properties 22, 24, and 28 Water Street and 13 & 15 Mill Street (RTN 3-10955) [158, p. 5]. 

Background information concerning the subject properties indicated that one of the buildings on the 

property (Building 3) was used as a leather tannery [158, pp. 12, 54]. A Sanborn Report contracted by 

GFS indicated the presence of the Cross & Murphy Morocco facility in this general area [129, pp. 105, 

108]. Soil samples collected as part of the Subsurface Investigation indicated arsenic concentrations up to 
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

14.8 mg/Kg and total chromium up to 1,200 mg/Kg in samples collected in and around Building 3 [158, 

pp. 26-27, 55]. In August 2010, Tighe & Bond (T&B) prepared a Release Abatement Measure (RAM) 

Plan outlining the proposed handling and management of potentially impacted soil and ground

water/surface water during the repair of a damaged seawall along the Crane River at the property located 

at 24 Water Street, which was subject to an Activity and Use Limitation (AUL) (Sept 2002 for RTN 3-

10955) [160, pp. 3, 7]. Subsurface soil sampling indicated arsenic at a concentration of 34 mg/Kg [160, p. 

8].

In September 1999, Haley & Aldrich, Inc.(H&A) assembled a Phase II Comprehensive Site Assessment 

to summarize investigative, risk assessment, and risk reduction activities undertaken by the Massachusetts 

Electric Company, Northborough, MA, the Responsible Party/Owner for response actions at the Danvers 

Manufactured Gas Plant (MGP) facility [159, p. 4]. The facility, located on the eastern side of the Crane 

River, was formerly used as a manufactured coal gas plant from approximately 1860 to 1906, and appears 

to have served as a gas storage and distribution facility from approximately 1906 through 1956, and then 

as residential properties until the time of the Phase II Comprehensive Site Assessment [159, p. 4, 173]. 

The Phase II Comprehensive Site Assessment identifies a former gas holder present at the MGP which 

contained materials contaminated with tannery byproducts exhibiting significant levels of chromium and 

high pH. H&A concluded these materials were typical of tannery effluent [159, p. 4]. Typical site 

contaminants for the MGP included polyaromatic hydrocarbons and free-phase coal tar products [159, p. 

5]. H&A suggested that the superstructure of the gas holder was razed, possibly buried in place, and 

additional materials were imported to the site to backfill the holder [159, p. 49]. Within the gas holder an 

organic silt fill, approximately 4 feet thick, which contained varying amounts of sand, brick, clinker, 

metal, and ash particles and specks, was observed [159, p. 49]. H&A commented that this material 

resembled typical organic silt, as would be found offshore in the intertidal zone of the Crane River, and 

the organic silt fill may be dredge spoils used to initially backfill the holder during decommissioning 

[159, p. 49]. According to observations, this dredge fill exhibited a strong odor of decomposition and 

decay, and several soil samples examined contained apparent animal hairs and fibers [159, p. 49]. 

Analytical results of the organic fill layer within the gas holder indicated metals, including chromium at 

10,000 parts per million (ppm), while the highest results of site wide soil samples indicated chromium at 

65 ppm [159, pp. 50, 52]. In addition, the organic layer within the gas holder contained a maximum pH of 

12.82, which led H&A to further support their supposition of the material being derived from tannery 

operations [159, p. 50]. 

H&A conducted an extent of contamination study of the Crane River, in order to reconstruct the 

depositional history of the estuary adjacent to the MGP site and to assist in delineating the areal limits of 

free-phase coal tar [159, p 33]. A local long-term resident told H&A that effluent discharged from the 

operating, adjacent Creese & Cook tannery lead to noxious, unpleasant odors (and reduction in water 

quality for swimming) in the Crane River [159, p. 34]. Several pushcores completed in the Crane River 

identified leather scraps, animal hairs, material interpreted to be leather buffings (part of the tanning 

process), or organic silt sediments exhibiting odors of "wet leather" within the industrialized subhorizon 

[159, pp. 34, 126]. Analytical results of sediment sample SD-11, collected from the Crane River directly 

adjacent to the former MGP facility, indicated chromium at a concentration of 562 mg/Kg [11, pp. 6-7; 

13, pp. 16-17, 73; 25, p. 9; 68, p. 13; 89, pp. 13, 86]. In 2007, ARCADIS, submitted a Partial Response 

Action Statement in which they stated that a condition of no substantial hazard exists at the property and 

that all identified sources have been characterized and contained [171, pp. 1, 3]. 

On 2 December 2011, Tetra Tech, Inc. (Tetra Tech) completed a Comprehensive Site Assessment (Phase 

II) report, on behalf of the Massachusetts Department of Transportation (MassDOT) [161, p. 6]. During 

reconfiguration construction of the on-and off-ramps for MA Route 128, soil material was identified that 

was inconsistent with those in the surrounding area (granules of a white, powder-like substance) [162, pp. 

6-7]. X-Ray Fluorescence (XRF) screening results of the white material indicated arsenic at a 
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

concentration of 6,757 mg/Kg [162, p. 7]. Laboratory analysis of the white material indicated arsenic 

concentrations at 3,900 mg/Kg and chromium at 40 mg/Kg [162, p. 7]. Tetra Tech concluded that the 

arsenic-containing white material is generally present beneath topsoil at depths ranging from 6 inches to 3

feet below the ground surface, and that its source is unknown [162, p. 18]. White material was observed 

between the railroad tracks and the High Street/Route-128 on/off ramps more frequently on steeper slopes 

than on shallower slopes of highway embankments [162, p. 18]. In addition, the white material was not 

observed beneath the paved highway ramps or other permanent roadway structures, which suggests that it 

may have been placed at some point after the highway was constructed in the early 1940s [162, p. 18]. 

Grid sampling of the highway project area indicated elevated arsenic concentrations within the MassDOT 

Right of Way from approximately High Street to just southwest of the Crane River, with the most heavily 

impacted areas identified as the steep embankments of the highway from the Route-128/High Street 

interchange ramps down toward the railroad tracks (cells H3, H4, I3, H6, I6, I7 and J7) [162, pp. 18-19, 

33]. As a part of the release response, approximately 11,479 tons of soil has been excavated from the 

highway interchange, and disposed of off-site [161, p. 16]. Tetra Tech noted that elevated arsenic 

concentrations in soil at the highway interchange property, which abuts the Crane River, have been 

identified [162, p. 20]. It was also noted that arsenic-contaminated soil related to the highway 

construction was generally present at depths from 6 inches to 3 feet under vegetative cover and a layer of 

topsoil [162, p. 20]. Tetra Tech concluded that while sediment impacts as a result of the arseniccontaminated materials are possible, any impacts are expected to be negligible compared to impacts from 

the documented releases at the former Creese & Cook tannery [162, p. 20]. Analytical results of sediment 

sample SD-07, collected from the Crane River directly adjacent to the highway on-ramp property, did not 

indicate site related hazardous substances significantly above background [11, p. 7; 13, pp. 17, 72; 25, p. 

5; 66, p. 6; 68, p. 12; 87, pp. 14, 98; 89, p. 11, 82].

Pentachlorophenol (PCP) is a synthetic general biocide which does not occur naturally in the environment 

and has been used extensively as a fungicide, bactericide, herbicide, molluscicide, algaecide, and 

insecticide by industries such as textiles [104, p. 10; 105, p. 21]. The production of PCP for wood 

preserving began in the 1930s [104, p. 12; 115, p. 1]. PCP was one of the most widely used biocides in 

the U.S. prior to regulatory actions to cancel and restrict certain non-wood preservative uses of 

pentachlorophenol in 1987 [104, p. 12; 105, p. 21]. Biocides, such as PCP, were used to prevent damage 

of the skin by bacterial growth during the soaking period of the tanning process [102, p. 2; 104, p. 10; 

111, p. 6; 115, p. 1]. Based on regulatory action, PCP was not used for leather preservation after the late 

1980s [107, p. 1; 115, p. 1; 116, p. 9]. PCP also contains chlorinated dibenzodioxins and chlorinated 

dibenzofurans as contaminants, formed during the manufacture of the chemical [104, p. 10; 110, pp. 22, 

389]. All six tanneries documented by the GFS investigation within the Sanborn Map Report (five 

upstream and one downstream) were no longer operational after at least 1916; and many were not 

represented on the 1909 Sanborn Maps [129, p. 106]. As noted above, this pre-dates the use of PCP in 

tannery operations and associated chlorinated dibenzodioxins and chlorinated dibenzofurans releases. 

Furthermore, only the Creese & Cook Co. continued operating in the vicinity of the Crane River and used 

biocides after 1930. 

Through salinity observations, tidal influence has been documented to extend up to a location slightly 

south of the Purchase Street Bridge, at sediment sample locations SD-03, SD-50, and SD-51 [11, pp. 18-

20]. A Massachusetts Division of Marine Fisheries study on rainbow smelt populations in the Crane River 

indicated the sluiceway just north of Purchase Street is located less than 100 meters upstream of the tidal 

interface of the Danvers River estuary [149, p. 5]. Based on analytical results of sediment samples 

presented in this HRS Documentation Record, a zone of actual contamination has been documented both 

upstream and downstream of site sources. Source materials containing pieces of leather scraps were

observed to be in contact with and released directly into the Crane River [11, pp. 17-19; 12, p. 2; 22]. In 

addition, the presence of hazardous substances at elevated concentrations in the sources and the observed 

releases of these substances to the surface water pathway support at least partial attribution of the 
Surface Water Overland Flow

Likelihood of Release

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MAD001031574 September 2012

hazardous substances to release from the site (see Source Nos. 1 through 4 Sections of this Evaluation and 

the Surface Water Pathway Likelihood of Release section above).

Therefore, as presented above, the Creese & Cook Tannery (Former) site is at least partially attributable 

to the release to the surface water pathway, based on the following: the direct observation of leather scrap 

material from sources depositing into the river sediments; the lack of sites with similar hazardous 

substances documented to have released to the river; and the documentation of former tanneries which did 

not operate while PCP was being used and which have been accounted for in sampling of background 

sediments.

Hazardous Substances Released

1,2,3,6,7,8-HxCDD (by Direct Observation and Chemical Analysis)

1,2,3,7,8,9-HxCDD (by Direct Observation and Chemical Analysis)

2,3,7,8-TCDF (by Direct Observation and Chemical Analysis)

2,3,4,6,7,8-HxCDF (by Direct Observation and Chemical Analysis)

1,2,3,4,6,7,8-HpCDF (by Direct Observation and Chemical Analysis)

Chromium (by Direct Observation and Chemical Analysis) 

Mercury (by Direct Observation and Chemical Analysis) 

Surface Water Observed Release Factor Value: 550
Surface Water Overland Flow

Drinking Water Threat Targets

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MAD001031574 September 2012

4.1.2.3 Drinking Water Threat Targets

Drinking Water Threat targets have not been identified for the Surface Water Overland Flow pathway; 

therefore, the Drinking Water Threat was not scored as part of this evaluation. 
Surface Water Overland Flow

Human Food Chain Threat Waste Characteristics

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4.1.3.2 Human Food Chain Threat Waste Characteristics

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The Toxicity Factor Value, the Persistence Factor Value, and the Bioaccumulation Factor Value are 

assigned to the hazardous substances associated with the sources and releases at the Creese & Cook 

Tannery (Former) site based on the values presented in SCDM [4, pp. A-84, A-186, A-202, A-204, A212, A-236, A-332]. Since the upstream and downstream hazardous substance migration pathways are 

comprised of salt water bodies, toxicity and bioaccumulation factor values for salt water are used. In 

addition, since the upstream and downstream hazardous substance migration pathways are comprised of 

rivers, persistence values for rivers are also used.

Table 42 - Toxicity, Persistence, Bioaccumulation Values

Hazardous 

Substance

Source 

Nos.

Toxicity 

Factor 

Value

Persistence 

Factor 

Value

Bioaccumulation 

Value

Toxicity/Persistence/

Bioaccumulation 

Factor Value 

[1, Table 4-16] References

1,2,3,6,7,8-

HxCDD 1-4 10,000 1.0 5,000 5 × 107 4, A-202

1,2,3,7,8,9-

HxCDD 1-4 10,000 1.0 50,000 5 × 108 4, A-204

2,3,7,8-TCDF 1, 4 10,000 1.0 50,000 5 × 108 4, A-332

2,3,4,6,7,8-

HxCDF 1, 2, 4 10,000 0.4 0.5 2,000 4, A-212

1,2,3,4,6,7,8-

HpCDF 1-4 10,000 1.0 50,000 5 × 108 4, A-186

Chromium 1-4 10,000 1.0 500 5 × 106 4, A-84

Mercury 1-4 10,000 1.0 50,000 5 × 108 4, A-236

HxCDD= Hexachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

From HRS Table 4-12, a Toxicity Factor Value of 10,000 and a Persistence Factor Value of 1.0 for 

1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 1,2,3,4,6,7,8-HpCDF, and mercury are assigned a 

Toxicity/Persistence Factor Value of 10,000 [1, p. 51613, Table 4-12]. From HRS Table 4-16, a 

Toxicity/Persistence Factor Value of 10,000 and a Bioaccumulation Factor Value of 50,000 for

1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 1,2,3,4,6,7,8-HpCDF, and mercury are assigned a 

Toxicity/Persistence/Bioaccumulation Factor Value of 5 × 108 [1, p. 51619].

Toxicity/Persistence/Bioaccumulation Factor Value: 5 × 108
Surface Water Overland Flow

Human Food Chain Threat Waste Characteristics

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MAD001031574 September 2012

4.1.3.2.2 Hazardous Waste Quantity

Table 43 - Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Pile 547.31

2 Pile 462.23

3 Surface Impoundment 1,124.23

4 Contaminated Soil 3.36

Sum of Values: 2,137.13

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for 

one or more sources and if any target for the surface water pathway is subject to Level I or Level II 

concentrations, a factor value is assigned from Table 2-6 or a value of 100, whichever is greater, as the 

Hazardous Waste Quantity Factor Value for that pathway [1, pp. 51591-51592 (Section 2.4.2.2, Table 2-

6)].

Hazardous Waste Quantity Factor Value [1, Table 2-6]: 100

4.1.3.2.3 Waste Characteristics Factor Category Value

The Toxicity/Persistence Factor Value (10,000) for 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 1,2,3,4,6,7,8-

HpCDF, and mercury is multiplied by the Hazardous Waste Quantity Factor Value for the watershed 

(100) in order to determine the Waste Characteristics Product, subject to a maximum value of 1 × 108 [1, 

pp. 51591, 51620 (Section 4.1.3.2.3)]. 10,000 × 100 = 1 × 106

. 

Toxicity/Persistence Factor Value × 

Hazardous Waste Quantity Factor Value: 1 × 106

The product of the Toxicity/Persistence Factor Value and the Hazardous Waste Quantity Factor Value for 

the watershed is multiplied by the Bioaccumulation Potential Factor Value for 1,2,3,7,8,9-HxCDD, 

2,3,7,8-TCDF, 1,2,3,4,6,7,8-HpCDF, and mercury (50,000), subject to a maximum value of 1 × 1012 [1, p. 

51620 (Section 4.1.3.2.3)]. (1 × 106

) × 50,000 = 5 × 1010.

(Toxicity/Persistence × Hazardous Waste Quantity)

× Bioaccumulation Potential Factor Value: 5 × 1010

From HRS Table 2-7, a Waste Characteristics Product of 5 × 1010 is assigned a Waste Characteristics 

Factor Category Value of 320 [1, pp. 51592 (Section 2.4.3.1, Table 2-7)].

Waste Characteristics Factor Category Value [1, Table 2-7]: 320 
Surface Water Overland Flow

Human Food Chain Threat Targets

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MAD001031574 September 2012

4.1.3.3 Human Food Chain Threat Targets

Based on observations in August 2011 during the Creese & Cook Co. (Former) 1 SR, a man was 

interviewed and confirmed the presence of a recreational fishery occurring in the Crane River near the 

MBTA Bridge [151]. According to an interviewed fisherman, stripers (also referred to as striped bass) are 

taken from the Crane River and consumed if they meet the state regulations on size limit (greater than 24 

inches) [151]. In addition, an interview with other local residents indicated that fishing occurs at the 

upstream side of the Water Street Bridge where anglers departed with the fish that were caught [152]. 

Additionally, studies of rainbow smelt spawning and reintroduction in the Crane River have been 

conducted and indicate that the upstream portion of the Crane River is a smelt run [149, 150, pp. 32-33]. 

The annual harvest information for the above species was not found in available file information, but is 

greater than zero (> 0) pounds based on the documentation of the interviewed fisherman consuming fish 

from the fishery.

Actual Human Food Chain Contamination

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and by sediment sample analytical results (See Section 4.1.2.1.1 of this evaluation). Based on 

the analytical results of sediment samples SD-04, SD-06, SD-08, SD-10, SD-11, SD-13, SD-15, SD-17, 

SD-18, SD-19, SD-20, SD-22, SD-23, SD-24, SD-56, SD-57, SD-59, SD-60, SD-61, and SD-70, the 

following hazardous substances attributed to Source Nos. 1 through 4 have been detected at 

concentrations significantly above background in sediments: 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 

2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, chromium, and mercury (see Section 4.1.2.1.1 

Observed Release). The sediment samples presented, which define the zone of actual contamination, were 

collected from the Crane River. The Crane River is actively fished according to direct observation along

with interviews with local residents and a fisherman (see Figure 4b) [151; 152].

Table 44 - Actual Human Food Chain Contamination

Sample 

ID

Sample 

Medium

Distance from 

PPE (miles)

Hazardous 

Substance

Bioaccumulation

Factor Value References

SD-04 Sediment 0.057 Chromium 500 4, p. A-84; 23, p. 2

SD-06 Sediment 0.011 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

2,3,7,8-TCDF 50,000 4, p. A-236; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-08 Sediment 0.163 Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-10 Sediment 0.212 Chromium 500 4, p. A-84; 23, p. 2

SD-11 Sediment 0.129 Chromium 500 4, p. A-84; 23, p. 2

SD-13 Sediment 0.168 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2
Surface Water Overland Flow

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MAD001031574 September 2012

Table 44 - Actual Human Food Chain Contamination (Continued)

Sample 

ID

Sample 

Medium

Distance from 

PPE (miles)

Hazardous 

Substance

Bioaccumulation

Factor Value References

SD-15 Sediment 0.230 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-17 Sediment 0.324 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-18 Sediment 0.262 Chromium 500 4, p. A-84; 23, p. 2

SD-19 Sediment 0.308 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-20 Sediment 0.366 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-22 Sediment 0.473 Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-23 Sediment 0.531 Chromium 500 4, p. A-84; 23, p. 2

SD-24 Sediment 0.649 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

2,3,7,8-TCDF 50,000 4, p. A-232; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

Mercury 50,000 4, p. A-236; 23, p. 2

SD-25 Sediment 0.579 Chromium 500 4, p. A-84; 23, p. 2

SD-56 Sediment 0.020 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,4,6,7,8-HpCDF 50,000 4, p. A-186; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

SD-57 Sediment 0.023 Chromium 500 4, p. A-84; 23, p. 2
Surface Water Overland Flow

Human Food Chain Threat Targets

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MAD001031574 September 2012

Table 44 - Actual Human Food Chain Contamination (Concluded)

Sample 

ID

Sample 

Medium

Distance from 

PPE (miles)

Hazardous 

Substance

Bioaccumulation

Factor Value References

SD-59 Sediment 0.246 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,4,6,7,8-HpCDF 50,000 4, p. A-186; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

SD-60 Sediment 0.343 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,7,8,9-HxCDD 50,000 4, p. A-204; 23, p. 2

2,3,7,8-TCDF 50,000 4, p. A-232; 23, p. 2

1,2,3,4,6,7,8-HpCDF 50,000 4, p. A-186; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

SD-61 Sediment 0.352 Chromium 500 4, p. A-84; 23, p. 2

SD-70 Sediment 0.020 1,2,3,6,7,8-HxCDD 5,000 4, p. A-202; 23, p. 2

1,2,3,4,6,7,8-HpCDF 50,000 4, p. A-186; 23, p. 2

Chromium 500 4, p. A-84; 23, p. 2

HxCDD= Hexachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

Closed Fisheries:

No closed downstream fisheries have been identified. 

Table 45 - Closed Fisheries

Identity of Fishery Sample ID

Distance from 

PPE Hazardous Substance References

Benthic Tissue:

Table 46 - Benthic Tissue

Identity of Fishery

Sample 

ID

Distance 

from PPE Hazardous Substance Organism References

Level I Concentrations

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and sediment sample analytical results (See Section 4.1.2.1.1 of this evaluation). However, 

fish tissue samples are not available for comparison to applicable health-based benchmarks; therefore, the 

fishery in Crane River is evaluated as subject to Level II actual contamination [1, p. 51620 (Section 

4.1.3.3)]. No Level I fisheries have been identified.
Surface Water Overland Flow

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Table 47 - Level I Concentrations

Sample 

ID

Sample 

Medium

Hazardous 

Substance

Hazardous 

Substance 

Concentration

Benchmark 

Concentration Benchmark References

NS

NS = Not Scored. 

Most Distant Level I Sample

Sample ID:

Distance from Probable Point of Entry:

Reference:

Level I Fisheries:

Table 48 - Level I Fisheries

Identity of Fishery

Extent of Level I Fishery

(Relative to PPE) Reference

NS

NS = Not Scored.

Most Distant Level II Sample

The observed release of 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 

1,2,3,4,6,7,8-HpCDF, chromium, and mercury to sediment from the Creese & Cook Tannery (Former) 

site is established by direct observation and chemical analysis of sediment samples (See Section 4.1.2.1.1 

of this Evaluation). On 16 through 18 May 2011 and 6 December 2011, as part of the EPA SR of the 

Creese & Cook Co. (Former) 1 property, sediment sampling activities were conducted at locations both 

upstream and downstream of the Creese & Cook Tannery (Former) site [11, pp. 2-9, 24-26; 13, pp. 10-21, 

41-44]. Twenty of the sediment samples collected (SD-04, SD-06, SD-08, SD-10, SD-11, SD-13, SD-15, 

SD-17, SD-18, SD-19, SD-20, SD-22, SD-23, SD-24, SD-56, SD-57, SD-59, SD-60, SD-61, and SD-70) 

document observed contamination to Crane River sediments (See Section 4.1.2.1.1 of this Evaluation). 

Sediment sample SD-04 was collected 0.057 miles upstream of the most upstream PPE on the north side 

of the MA Route 128 Bridge (see Figure 4b) [11, p. 7; 13, pp. 17, 71; 23, p. 2; 25, p. 2]. Sediment sample 

SD-06 was collected 0.011 miles downstream of the PPE adjacent to Source No. 1 (see Figure 4b) [11, p. 

7; 13, pp. 17, 72; 23, p. 2; 25, p. 4]. Sediment sample SD-56 was collected 0.020 miles downstream of the 

PPE adjacent to Source No. 1 in an area of leather scrap deposition into the Crane River (see Figure 4b) 

[11, p. 25; 13, pp. 43, 83; 23, p. 2; 25, p. 27]. Sediment sample SD-60 was collected 0.246 miles 

downstream of the PPE adjacent to Source No. 4 in an area of leather scrap deposition into the Crane 

River (see Figure 4b) [11, p. 24; 13, pp. 42, 85; 23, p. 2; 25, p. 31]. Sediment sample SD-24 was collected 

0.649 miles downstream of the PPE and east of the Water Street Bridge (see Figure 4b) [11, p. 3-5; 13, 

pp. 12, 80; 23, p. 2; 25, p. 22]. 

Sample ID: SD-04

Distance from the PPE: 0.057 miles upstream

Reference: 23, p. 2
Surface Water Overland Flow

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MAD001031574 September 2012

Sample ID: SD-06

Distance from the PPE: 0.011 miles downstream

Reference: 23, p. 2

Sample ID: SD-56

Distance from the PPE: 0.020 miles downstream

Reference: 23, p. 2

Sample ID: SD-60

Distance from the PPE: 0.246 miles downstream

Reference: 23, p. 2

Sample ID: SD-24

Distance from the PPE: 0.649 miles downstream

Reference: 23, p. 2

Level II Fisheries

Table 49 - Level II Fisheries

Identity of 

Fishery

Extent of Level II Fishery

(Relative to PPE or Level II Fishery) References

Crane River Level II concentrations of dioxin/furan congeners, chromium, and mercury 

are present in sediment samples collected from upstream of the most upstream 

PPE (SD-04) through the area of the documented fishery, to the most 

downstream release sample (SD-24), located 0.649 miles from PPE No. 1.

See Section 

4.1.2.1.1; 11, pp. 

3-7; 13, pp. 12, 17, 

71, 80; 23, p. 2; 

25, pp. 2-22

4.1.3.3.1 Food Chain Individual

The Crane River fishery is subject to actual contamination based on the observed release of hazardous 

substances by direct observation and chemical analysis (1,2,3,6,7,8-HxCDD; 1,2,3,7,8,9-HxCDD; 

2,3,7,8-TCDF; 2,3,4,6,7,8-HxCDF; 1,2,3,4,6,7,8-HpCDF chromium, and mercury) of sediment samples 

(SD-04, SD-06, SD-56, SD-60, and SD-24) (See Section 4.1.2.1.1). An observed release of attributable 

hazardous substances (1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 1,2,3,4,6,7,8-HpCDF, 

chromium, and mercury), having a Bioaccumulation Factor Value of 500 or greater (maximum value 

50,000), to the in-water segment for the watershed containing fisheries has been established [4, pp. A-84, 

A-186, A-202, A-204, A-236]. However, fish tissue samples are not available for comparison to 

applicable health-based benchmarks; therefore, the fishery in Crane River is evaluated as subject to Level 

II actual contamination [1, p. 51620 (Section 4.1.3.3)].As a result, a Food Chain Individual Factor Value 

of 45 is assigned [1, p. 51620 (Section 4.1.3.3.1)]. 

Sample ID: SD-04

Level I/Level II/or Potential: Level II

Hazardous Substance: Chromium 

Bioaccumulation Potential: 500 

Sample ID: SD-06

Level I/Level II/or Potential: Level II

Hazardous Substance: 1,2,3,6,7,8-HxCDD/1,2,3,7,8,9-HxCDD/2,3,7,8-TCDF/chromium/ mercury
Surface Water Overland Flow

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MAD001031574 September 2012

Bioaccumulation Potential: 5,000/50,000/50,000/500/50,000 

Sample ID: SD-56

Level I/Level II/or Potential: Level II

Hazardous Substance: 1,2,3,6,7,8-HxCDD/1,2,3,4,6,7,8-HpCDF/chromium 

Bioaccumulation Potential: 5,000/50,000/500

Sample ID: SD-60

Level I/Level II/or Potential: Level II

Hazardous Substance: 1,2,3,6,7,8-HxCDD/1,2,3,7,8,9-HxCDD/2,3,7,8-TCDF/1,2,3,4,6,7,8-

HpCDF/chromium 

Bioaccumulation Potential: 5,000/50,000/50,000/50,000/500

Sample ID: SD-24

Level I/Level II/or Potential: Level II

Hazardous Substance: 1,2,3,6,7,8-HxCDD/1,2,3,7,8,9-HxCDD/2,3,7,8-TCDF/chromium/ mercury 

Bioaccumulation Potential: 5,000/50,000/50,000/500/50,000

Table 50 - Food Chain Individual

Identity of Fishery

Type of Surface Water 

Body

Dilution Weight 

(Ref. 1,Table 4-13) References

Crane River upstream of 

Water Street Bridge Small to moderate stream 0.1 41; 150, p. 134

If Potential Contamination, Dilution Weight x 20:

Food Chain Individual Factor Value: 45

[1, p. 51620 (Section 4.1.3.3.1)]

4.1.3.3.2 Population

4.1.3.3.2.1 Level I Concentrations

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and chemical analysis of sediment samples (See Section 4.1.2.1.1 of this evaluation). 

However, fish tissue samples are not available for comparison to applicable health-based benchmarks; 

therefore, the fishery in Crane River is evaluated as subject to Level II actual contamination [1, p. 51620 

(Section 4.1.3.3)]. No Level I fisheries have been identified.

Level I Population Concentrations

Table 51 - Level I Human Food Chain Population Value

Identity of Fishery

Annual Production 

(pounds) References

Human Food Chain

Population Value

[1, Table 4-18]

NS

Sum of Level I Human Food Chain Population Values: NS
Surface Water Overland Flow

Human Food Chain Threat Targets

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MAD001031574 September 2012

Sum of Level I Human Food Chain Population Values × 10: 

Level I Concentrations Factor Value: Not Scored

4.1.3.3.2.2 Level II Concentrations

Level II Population Targets

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and chemical analysis of sediment samples (See Section 4.1.2.1.1 of this evaluation). 

However, fish tissue samples are not available for comparison to applicable health-based benchmarks; 

therefore, the fishery in Crane River is evaluated as subject to Level II actual contamination [1, p. 51620 

(Section 4.1.3.3)].

Table 52 - Level II Human Food Chain Population Value

Identity of 

Fishery

Annual 

Production 

(pounds) References

Human Food Chain

Population Value

[1, Table 4-18]

Crane River > 0 1, p. 51620 (Section 4.1.3.3); 151; 152 0.03

Sum of Level II Human Food Chain Population Values: 0.03

Level II Concentrations Factor Value: 0.03 
Surface Water Overland Flow

Potential Human Food Chain Threat Targets

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4.1.3.3.2.3 Potential Human Food Chain Contamination

Potential Population Targets

Table 53 - Potential Population Targets

Identity 

of 

Fishery

Annual 

Production 

(pounds)

Type of 

Surface 

Water Body

Average 

Annual 

Flow (cfs) References

Population 

Value (Pi) 

[1, Table 4-

18]

Dilution 

Weight (Di) 

[1, Table 4-

13]

Pi x 

Di

NS

Sum of Pi x Di: 

(Sum of Pi x Di)/10: 

Potential Human Food Chain Contamination Factor Value: Not Scored
Surface Water Overland Flow

Environmental Threat Waste Characteristics

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MAD001031574 September 2012

4.1.4.2 Environmental Threat Waste Characteristics

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

The Ecosystem Toxicity Factor Value, the Persistence Factor Value, and the Environmental 

Bioaccumulation Factor Value are assigned to the hazardous substances associated with the sources and 

releases at the Creese & Cook Tannery (Former) site based on the values presented in SCDM [4, pp. A84, A-186, A-202, A-204, A-212, A-236, A-332]. Since the upstream and downstream hazardous 

substance migration pathways are comprised of salt water bodies, toxicity and bioaccumulation factor 

values for salt water are used. In addition, since the upstream and downstream hazardous substance 

migration pathways are comprised of rivers, persistence values for rivers are also used. 

Table 54 - Ecosystem Toxicity, Persistence, and Bioaccumulation

Hazardous 

Substance

Source 

Nos.

Ecosystem 

Toxicity 

Factor 

Value

Persistence 

Factor 

Value

Environmental 

Bioaccumulation 

Value

Ecosystem 

Toxicity/

Persistence/

Environmental 

Bioaccumulation 

Factor Value [1, 

Table 4-21] References

1,2,3,6,7,8-

HxCDD 1-4 0 1.0 5,000 0 4, A-202

1,2,3,7,8,9-

HxCDD 1-4 0 1.0 50,000 0 4, A-204

2,3,7,8-

TCDF 1, 4 0 1.0 50,000 0 4, A-332

2,3,4,6,7,8-

HxCDF 1, 2, 4 0 0.4 0.5 0 4, A-212

1,2,3,4,6,7,8-

HpCDF 1-4 0 1.0 50,000 0 4, A-186

Chromium 1-4 100 1.0 500 50,000 4, A-84

Mercury 1-4 10,000 1.0 50,000 5 × 108 4, A-236

HxCDD= Hexachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

The Environmental Threat Waste Characteristic is evaluated for mercury. From HRS Table 4-21, a 

Ecosystem Toxicity/Persistence Factor Value of 10,000 and an Environmental Bioaccumulation Factor 

Value of 50,000 for mercury are assigned an Ecosystem Toxicity/Persistence/ Bioaccumulation Factor 

Value of 5 × 108 [1, p. 51623].

Ecosystem Toxicity/Persistence/Environmental Bioaccumulation Factor Value: 5 × 108
Surface Water Overland Flow

Environmental Threat Waste Characteristics

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MAD001031574 September 2012

4.1.4.2.2 Hazardous Waste Quantity

Table 55 - Hazardous Waste Quantity

Source No. Source Type Source Hazardous Waste Quantity

1 Pile 547.31

2 Pile 462.23

3 Surface Impoundment 1,124.23

4 Contaminated Soil 3.36

Sum of Values: 2,137.13

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for 

one or more sources and if any target for the surface water pathway is subject to Level I or Level II 

concentrations, a factor value is assigned from Table 2-6 or a value of 100, whichever is greater, as the 

Hazardous Waste Quantity Factor Value for that pathway [1, pp. 51591-51592 (Section 2.4.2.2, Table 2-

6)].

Hazardous Waste Quantity Factor Value [1, Table 2-6]: 100

4.1.4.2.3 Waste Characteristics Factor Category Value

The Ecosystem Toxicity Factor Value (10,000) and the Persistence Factor Value (1.0) for mercury are 

multiplied in order to determine the Ecosystem Toxicity/Persistence Factor Value (10,000) [1, p. 51624, 

Section 4.1.4.2.1.4, Table 4-20]. The Ecosystem Toxicity/Persistence Factor Value for the watershed 

(10,000) is multiplied by the Hazardous Waste Quantity Factor Value for the watershed (100) in order to 

determine the Waste Characteristics Product, subject to a maximum value of 1 × 108 [1, pp. 51592,

Section 2.4.3.1, 51624, Section 4.1.4.2.3]. 10,000 × 100 = 1 x 106

.

Ecosystem Toxicity/Persistence Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 100

Ecosystem Toxicity/Persistence Factor Value × Hazardous Waste Quantity Factor Value: 1 x 106

The Waste Characteristics Product for the watershed (subject to a maximum value of 1 × 108

) is 

multiplied by the Bioaccumulation Potential Factor Value (50,000) for mercury, to generate a second 

product, subject to a maximum value of 1 × 1012 [1, p. 51624, Section 4.1.4.2.3]. (1 x 106

) × 50,000 = 

50,000,000,000 (5 × 1010).

(Ecosystem Toxicity/Persistence × Hazardous Waste Quantity) ×

Bioaccumulation Potential Factor Value: 5 × 1010

From HRS Table 2-7, the second Waste Characteristics Product (5 × 1010

) is assigned a Waste 

Characteristics Factor Category Value of 320 [1, pp. 51592 (Section 2.4.3.1), 51624 (Section 4.1.4.2.3)].

Waste Characteristics Factor Category Value (1, p. 51592, Table 2-7): 320
Surface Water Overland Flow

Environmental Threat Targets

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4.1.4.3 Environmental Threat Targets

The Creese & Cook Co. Tannery (Former) site is located within the Crane River System, which is located 

in the Beverly Harbor Drainage Area and is part of the North Shore Coastal Watersheds [144, pp. 1, 12, 

69, 86]. Source areas associated with former tannery operations at the site are located within the Crane 

River System, designated as segment MA93-41, which extends from the outlet pump house sluiceway, on 

Purchase Street, to the confluence with the Danvers River [144, p. 86]. The Crane River segment MA93-

41 is classified as an estuary and designated by the state Integrated List of Waters as a Category 5, which 

denotes the segment as impaired and requiring one or more Total Maximum Daily Load studies [145, p. 

22, 134; 147, p. 33]. The Integrated List of Waters was compiled in response to Section 303(d) of the 

Clean Water Act (CWA) and the implementing regulations at 40 CFR 130.7, which requires states to 

identify those water bodies that are not expected to meet surface water quality standards after the 

implementation of technology-based controls and to prioritize and schedule them for the development of a 

Total Maximum Daily Load [145, p. 5]. Based on direct observation and chemical analysis, an observed 

release has been documented to CWA-protected water body sensitive environment (Crane River segment 

MA93-41) [1, p. 51624 (Table 4-23)].

According to a wetland delineation completed by an EPA Senior Wetland Scientist, there is wetland 

frontage located along the Crane River and extends from the area of the upstream background sediment 

samples to the Water Street Bridge [24, pp. 3-4, 9 (Figure 4)]. Based on analytical results of sediment 

samples, the wetland frontage along the Crane River from sediment sample SD-04 through sediment 

sample SD-24 is subject to actual contamination and documents impacts to a sensitive environment (see 

Figure 4 and Section 4.2.1.2.1 of this evaluation) [24, pp. 2-3, 8-9 (Figures 3 and 4)]. 

Level I Concentrations

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and chemical analysis of sediment samples (See Section 4.1.2.1.1 of this evaluation). 

Sensitive Environments that are determined to be actual contamination targets based on sediment sample 

analytical results, but for which no ecological-based benchmarks are applicable, are evaluated as subject 

to actual contamination at Level II [1, p. 51625 (Section 4.1.4.3.1)]. Therefore, no Level I sensitive 

environments have been identified.

Table 56 - Level I Concentrations

Sample 

ID

Sample 

Medium

Hazardous

Substance

Hazardous 

Substance 

Concentration

Benchmark 

Concentration Benchmark References

Most Distant Level I Sample

Sample ID:

Distance from the probable point of entry:

Reference:

Most Distant Level II Sample

The observed release of 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 

1,2,3,4,6,7,8-HpCDF, chromium, and mercury to sediment from the Creese & Cook Co. Tannery 
Surface Water Overland Flow

Environmental Threat Targets

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MAD001031574 September 2012

(Former) site is established by direct observation and chemical analysis of sediment samples (See Section 

4.1.2.1.1 of this Evaluation). On 16 through 18 May 2011 and 6 December 2011, as part of the EPA SR

of the Creese & Cook Co. (Former) 1 property, sediment sampling activities were conducted at locations 

both upstream and downstream of the Creese & Cook Co. Tannery (Former) site [11, pp. 2-9, 24-27; 13, 

pp. 10-21, 41-44]. Twenty of the sediment samples collected (SD-04, SD-06, SD-08, SD-10, SD-11, SD13, SD-15, SD-17, SD-18, SD-19, SD-20, SD-22, SD-23, SD-24, SD-56, SD-57, SD-59, SD-60, SD-61, 

and SD-70) document observed contamination to Crane River sediments (See Section 4.1.2.1.1 of this 

Evaluation). Sediment sample SD-04 was collected 0.057 miles upstream of the most upstream PPE on 

the north side of the MA Route 128 Bridge (see Figure 4b) [11, p. 7; 13, pp. 17, 71; 23, p. 2; 25, p. 2, 4, 6, 

8-9, 11, 13, 15-18, 20-22, 27-28, 30-32]. Sediment sample SD-06 was collected 0.011 miles downstream 

of the PPE adjacent to Source No. 1 (see Figure 4b) [11, p. 7; 13, pp. 17, 72; 23, p. 2; 25, p. 4]. Sediment 

sample SD-56 was collected 0.020 miles downstream of the PPE adjacent to Source No. 1 in an area of 

leather scrap deposition into the Crane River (see Figure 4b) [11, p. 25; 13, pp. 43, 83; 23, p. 2; 25, p. 27]. 

Sediment sample SD-60 was collected 0.246 miles downstream of the PPE adjacent to Source No. 4 in an 

area of leather scrap deposition into the Crane River (see Figure 4b) [11, p. 24; 13, pp. 42, 85; 23, p. 2; 

25, p. 31]. Sediment sample SD-24 was collected 0.649 miles downstream of the PPE adjacent and east of 

the Water Street Bridge (see Figure 4b) [11, pp. 3-5; 13, pp. 12, 80; 23, p. 2; 25, p. 22]. 

Sample ID: SD-04

Distance from the PPE: 0.057 miles upstream

Reference: 23, p. 2

Sample ID: SD-06

Distance from the PPE: 0.011 miles downstream

Reference: 23, p. 2

Sample ID: SD-56

Distance from the PPE: 0.020 miles downstream

Reference: 23, p. 2

Sample ID: SD-60

Distance from the PPE: 0.246 miles downstream

Reference: 23, p. 2

Sample ID: SD-24

Distance from the PPE: 0.649 miles downstream

Reference: 23, p. 2

4.1.4.3.1 Sensitive Environments

4.1.4.3.1.1 Level I Concentrations

The observed release to sediment from the Creese & Cook Tannery (Former) site is established by direct 

observation and chemical analysis of sediment samples (See Section 4.1.2.1.1 of this evaluation). 

Sensitive Environments that are determined to be actual contamination targets based on sediment sample 

analytical results, but for which no ecological-based benchmarks are applicable, are evaluated as subject 

to actual contamination at Level II [1, p. 51625 (Section 4.1.4.3.1)]. Therefore, no Level I sensitive 

environments have been identified.
Surface Water Overland Flow

Environmental Threat Targets

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MAD001031574 September 2012

Level I Sensitive Environment Targets

Table 57 - Level I Sensitive Environment Targets

Sensitive 

Environment

Distance from PPE to Nearest 

Sensitive Environment References

Sensitive Environment 

Value [1, Table 4-23]

NS

Sum of Level I Sensitive Environments Value: NS

Level I Wetland Frontages

Table 58 - Level I Wetland Frontages

Wetland Wetland Frontage (miles) References

NS

Sum of Level I Wetland Frontages: NS

Wetlands Value (Ref. 1, Table 4-24): NS

Sum of Level I Sensitive Environments Value + Wetlands Value: NS

(Sum of Level Sensitive Environments Value + Wetlands Value) x 10: NS

Level I Concentrations Factor Value: NS

4.1.4.3.1.2. Level II Concentrations

Sensitive environments that were determined to be actual contamination targets based on direct 

observation and chemical analysis of sediment samples are evaluated using Level II concentrations [1, p. 

51625 (Section 4.1.4.3.1)]. An observed release to sediment from the Creese & Cook Tannery (Former) 

site has been established for a portion of Crane River, from 0.057 miles upstream (SD-04) to 0.649 miles 

downstream (SD-24) of the PPE for Source No. 1 (See Section 4.1.2.1.1 of this evaluation) [11, pp. 3-5, 

7; 13, pp. 12, 17, 71, 80; 23, p. 2].

Level II Sensitive Environment Targets

The Crane River segment MA93-41 is classified as an estuary and designated by the state Integrated List 

of Waters as a Category 5 [145, p. 24, 134; 147, p. 47]. The Integrated List of Waters was compiled in 

response to Section 303(d) of the CWA and the implementing regulations at 40 CFR 130.7, which 

requires states to identify those water bodies that are not expected to meet surface water quality standards 

after the implementation of technology-based controls and to prioritize and schedule them for the 

development of a total maximum daily load (TMDL) [145, p. 5]. Crane River segment MA93-41 is listed 

as a class SA water body which denotes an excellent habitat for fish, other aquatic life and wildlife, 

including for their reproduction, migration, growth and other critical functions, and for primary and 

secondary contact recreation [146, p. 12; 147, p. 47]. Based on direct observation and chemical analysis 

of sediment samples, an observed release has been documented to a CWA-protected water body sensitive 

environment (Crane River segment MA93-41) [1, p. 51624 (Table 4-23)]. 
Surface Water Overland Flow

Environmental Threat Targets

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MAD001031574 September 2012

Table 59 - Level II Sensitive Environment Targets

Sensitive 

Environment

Distance from PPE to Nearest 

Sensitive Environment References

Sensitive 

Environment Value 

(Ref. 1, Table 4-23)

CWA-Protected Water 

Body (Crane River) 0

1, p. 51624, Table 

4-23 5

Sum of Level II Sensitive Environments Value: 5

Level II Wetland Frontages

According to a wetland delineation completed by an EPA Senior Wetland Scientist, there is wetland 

frontage located along the Crane River, extending from the upstream background sediment samples to the 

Water Street Bridge [24, pp. 2-3, 9 (Figure 4)]. The United States Fish and Wildlife Service (USFWS) 

National Wetland Inventory (NWI) indicates numerous wetland types along the area of documented 

contamination within the Crane River [24, p. 3]. The HRS uses the definition of a wetland presented in 40 

CFR 230.3, which differs from the USFWS definition in that, under normal circumstances, the wetland 

should support a prevalence of rooted emergent hydrophytes [24, p. 3]. Therefore, the NWI maps present 

some wetland types that may be used in HRS scoring depending on the presence of these rooted 

hydrophytes [24, p. 3]. The wetland delineation, completed by an EPA Senior Wetland Scientist on 2 

November 2011, indicated the presence of Estuarine Intertidal Emergent wetlands along the facility 

properties on both the eastern and western banks of the Crane River and from the Water Street Bridge up 

to and including sediment sample SD-04 (see Figure 4b) [24, pp. 4, 9 (Figure 4)]. Based on analytical 

results of sediment samples, the wetland frontage along the Crane River from sediment sample SD-04 

through sediment sample SD-24 is subject to actual contamination and documents impacts to a sensitive 

environment (see Figure 4 and Section 4.2.1.2.1 of this evaluation) [24, pp. 2-3, 9 (Figure 4)]. Chromium 

was detected in sediment samples SD-04 and SD-24 at concentrations significantly above background, 

and mercury was detected in sediment samples SD-06 and SD-24 at concentrations significantly above 

background (see Section 4.2.1.2.1 of this evaluation). The distance from the southern side of the MA 

Route 128 Bridge to the upstream (eastern) side of the Water Street Bridge, which is contained between 

sediment samples SD-04 and SD-24, is evaluated as containing impacted wetland frontage. From the 

wetland delineation this includes Wetland ID Nos. 1 through 21 [24, pp. 2-3, 9, 19]. Therefore, based on 

the HRS eligible wetland delineation, performed by an EPA Senior Wetland Scientist, a wetland frontage 

distance of 1.287 miles is documented as a Level II actual observed release environmental target [24, pp. 

2-3, 9 19]. 

Sum of Level II Wetland Frontages: 1.287

Wetlands Value [1, Table 4-24]: 50

Sum of Level II Sensitive Environments Value + Wetlands Value: 55

Level II Concentrations Factor Value: 55

Table 60 – Wetland Frontage

Wetland

Wetland Frontage 

(miles) References

Crane River Impacted Wetlands 1.287 Section 4.2.1.2.1, 24, pp. 2-3, 9, 19
Surface Water Overland Flow

Environmental Threat Targets

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MAD001031574 September 2012

4.1.4.3.1.3 Potential Contamination

Potential Contamination Factor Value: Not Scored
Soil Exposure – General

Area A

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MAD001031574 September 2012

5.0 SOIL EXPOSURE PATHWAY

5.0.1 GENERAL CONSIDERATIONS

Letter by which this area is to be identified: A

Name of area: Contaminated Soil Associated with the Water Street/MBTA Source

Location and description of area (with reference to a map of the site):

The surface soil area documented to contain site-related hazardous substances associated with operations 

on the Creese & Cook Tannery facility is referred to as Area A and is located on the eastern side of the 

Crane River. This area is defined by the areal extent of Source No. 4: contained on portions of three 

separate properties, consisting of the 33 Water Street parcel the adjacent MBTA Right-of-way parcel, and 

the 20 Cheever street parcel; and is outlined by 12 shallow surface soil samples (SS-12A, SS-02A, SS18A, SS-05A, SS-20A/SS-20C, SS-21A, SS-11A, SS-22A, SS-23A/SS-35A, SO-63, SO-62, and SS-26A)

(see Figure 5) [17]. In addition, sampling of surface materials within Area A (SS-03A, SS-04A/SS-04C, 

SS-06A, SS-07A, SS-08A, SS-09A/SS-33A, SS-10A, SS-12A, SS-18A, SS-24A/SS-24C, and SS-25A) 

has indicated the presence of site-related hazardous substances significantly above background (see 

Source No. 4 Evaluation). The 33 Water Street portion of Area A is located on a parcel containing 

residential population targets, while the adjacent MBTA Right-of-Way and the Cheever Street parcel are 

not residential and have no associated residential targets [12, p. 17; 163]. 

- Background Concentrations:

On 5 December 2011, as part of the EPA SR of the Creese & Cook Co. (Former) 1 facility, background 

surface soil sampling activities were conducted [11, pp.20-24; 13, pp. 36-41]. The background surface 

soil samples were collected in accordance with the EPA-approved Site-Specific QAPP, dated 18 April 

2011, and the Site-Specific QAPP Addendum, dated 22 November 2011 [8, pp. 29,50; 9, pp. 2-3, 8 

(Figure 3); 13, pp. 37] Two background surface soil samples (SO-52 and SO-53) were collected from an 

area directly adjacent to the exterior side of the granite stone wall marking the Endicott-Russell Family 

Cemetery ( located at 25 Clinton Avenue) [11, p. 21; 13, pp. 37-38, 53, 56-57, 66, 135; 19]. The samples 

were collected to document background soil concentrations in natural materials in the vicinity of the site 

[11, p. 21; 13, pp. 37-38, 40]. The samples were collected from an area presumed to be outside the area 

influenced by waste disposal practices from the tannery. The Endicott-Russell Family Cemetery pre-dates 

the tannery operations [11, p. 21; 13, pp. 37-38]. START personnel noted grave markers dating back to 

the mid-1700s (including Mrs. Margaret Endicott – 1759 and Capt. Samuel Endicott - 1766) [11, p. 21; 

13, pp. 37-38].

Table 61 - Background Surface Soil Sample Location Description

Sample ID Sample Medium Depth (inches) Date References

SO-52 Soil 8 to 18 12/5/2011 11, p. 21; 13, pp. 37, 66; 26, p. 24

SO-53 Soil 8 to 24 12/5/2011 11, p. 21; 13, pp. 38, 66; 26, p. 25

Two background surface soil samples (SO-52 and SO-53) were collected from less than 2 feet below 

ground surface (bgs) from similar depth intervals and contained soil matrix material similar to the surface 

soil samples associated with release samples presented as part of the Soil Exposure Evaluation – Area A 

[11, pp. 21, 23; 12, pp. 4-17; 13, pp. 37-38; 14, pp. 12-30; 26, pp. 24-25; 27, pp. 4, 7-8, 10-12, 16-17, 20-

21, 24, 28, 31, 34, 37, 53, 57-69]. Background surface soil samples were collected within the same 
Soil Exposure – General

Area A

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MAD001031574 September 2012

general time period (7 months) as those release samples presented as part of the Soil Exposure evaluation 

[11, p. 21; 12, pp. 4-17; 13, pp. 52, 56; 14, pp. 12-30]. Reconnaissance observations during the time 

period between sampling events did not indicate any change to the source area identified here as Area A 

[11, p. 26; 13, pp. 34].

Table 62 – Background Surface Soil Sample Description

Sample 

ID Sample Description Reference

SO-52 Brown-to-orange brown, silt and fine-to-coarse sand, trace fine gravel, trace organics. 26, p. 24

SO-53 Brown, silt and fine-to-medium sand, trace fine-to-medium gravel, trace clay, trace organic. 26, p. 25

Background surface soil sample SO-53 was submitted to CLP laboratories for dioxin/furan analysis 

following DLM02.2, and for total metals analysis following ISM01.3; while background surface soil 

sample SO-52 was submitted to a CLP laboratory for total metals analysis only, following ISM01.3 [11, 

pp. 21, 27; 13, pp. 36-38, 57-58, 66; 28, p. 11; 29, p. 7; 50, pp. 1, 4; 57, pp. 1, 13; 71, pp. 12, 107; 78, pp. 

11, 87-88]. COCs for all source samples collected as part of the 2011 EPA SR and presented in this HRS 

Documentation Record are provided in References 28 and 29. The applicable COC sections for the 

background surface soil samples and all corresponding sample identifiers are provided in available COC, 

field notes reference documentation, and sample crosswalk [11, p. 21; 13, pp. 36-38, 66; 26, pp. 24-25; 

28, p. 11; 29, p. 7]. The dioxin/furan analytical results were manually validated at a stage 4 level in 

accordance with the criteria specified in the USEPA SOW DLM02.2 and EPA Region I’s ESAT 

Dioxin/Furan Data Validation SOP ESAT-01-0007 [50, p. 1]. The total metals analytical data were 

evaluated on a Tier II level in accordance with the Region I Tiered Organic and Inorganic Data Validation 

Guidelines dated November 2008 [57, p. 1]. The validation of dioxin/furan and total metals analytical 

results was conducted independently by designated chemists who were not involved in the sample 

collection and HRS evaluation [11, pp. 21, 23; 13, pp. 36-38, 40, 66, 69; 50, pp. 1-3; 57, pp. 1-8].

Based on an examination of the two background surface soil samples collected and submitted for total 

metals analysis, the highest background hazardous substance comparison concentrations are presented in 

Table 63. See below for further evaluation of background concentrations utilized in this HRS evaluation 

to determine observed contamination for the Soil Exposure pathway. 

Table 63 - Hazardous Substances Associated with Background Surface Soil Samples

Sample 

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-53 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 0.371 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107

SO-53 Soil 12/5/11 1,2,3,7,8,9-HxCDD None 0.425 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp.1-2, 12, 

107
Soil Exposure – General

Area A

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MAD001031574 September 2012

Table 63 - Hazardous Substances Associated with Background Surface Soil Samples (Concluded)

Sample 

ID

Sample

Type Date

Hazardous 

Substance Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDD None 21.2 ng/Kg 4.81 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107

SO-53 Soil 12/5/11 2,3,7,8-TCDF None 0.259 EMPC ng/Kg 0.961 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12,

107

SO-53 Soil 12/5/11 2,3,4,6,7,8-HxCDF None 0.338 U ng/Kg 4.81 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107

SO-53 Soil 12/5/11 1,2,3,4,6,7,8-HpCDF None

1.77 J

(1.77) ng/Kg 4.81 ng/Kg

11, p. 21; 13, p. 

38, 66; 50, p. 4; 

71, pp. 1-2, 12, 

107

SO-52 Soil 12/5/11 Arsenic None 11.4 mg/Kg 1.2 mg/Kg

11, p. 21; 13, p. 

36-37, 66; 57, p. 

13; 78, pp. 1-2, 

11, 87

SO-53 Soil 12/5/11 Barium None

21.2 J

(21.2) mg/Kg 23.6 mg/Kg

11, p. 21; 13, p. 

38, 66; 57, pp. 

11, 13; 78, pp. 1-

2, 11, 88

SO-52 Soil 12/5/11 Chromium None 17.3 mg/Kg 1.2 mg/Kg

11, p. 21; 13, p. 

36-37, 66; 57, p. 

13; 78, pp. 1-2, 

11, 87

SO-53 Soil 12/5/11 Mercury None

0.040 J

(0.04) mg/Kg 0.12 mg/Kg

11, p. 21; 13, p. 

38, 66; 57, pp. 

11, 13; 78, pp. 1-

2, 11, 88

CRQL = Contract Required Quantitation Limit. ng/Kg = Nanograms per kilogram.

mg/Kg = Milligrams per kilogram. HpCDF= Heptachlorodibenzofuran.

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

U = The compound or element was analyzed for, but not detected. The associated numerical value 

is the sample-adjusted CRQL [141, p. B-21; 50, p. 7].

J = The associated numerical value is an estimated quantity [141, p. B-20; 50, p. 4; 142, p. B-21; 

57, p. 11].

EMPC = Estimated Maximum Possible Concentration based on a failure of the ion abundance ratio. The 

EMPC is a worst case estimate of the sample concentration that the signal would represent if it did meet 

all the identification criteria [141, p. D-4]. 

* = An explanation for the direction of bias is provided in Reference 71, Table 3; Reference 86, 

Table 3; Reference 88, Table 3; Reference 89, Table 3; Reference 90, Table 3; Reference 91, Table 3.
Soil Exposure – General

Area A

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MAD001031574 September 2012

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

after adjustment. Analytical adjustments are based on the EPA Fact Sheet, Using Qualified Data to 

Document an Observed Release and Observed Contamination [140, pp. 4-8]. 

Based on an examination of the one background surface soil sample submitted for dioxin/furan analysis 

and the two background surface soil samples submitted for total metals analysis, the highest numerical 

comparison background value concentrations are presented in Table 63. These are used to establish 

specific analyte background comparison concentrations to determine observed contamination of Area A 

for the Soil Exposure evaluation. 

Dioxin/furan congeners 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, and 2,3,4,6,7,8-HxCDF in background 

surface soil samples were non-detect; therefore, observed contamination is established when the 

contaminated surface soil sample concentration equals or exceeds the sample-adjusted CRQL [1, p. 51589 

(Table 2-3)]. 

Dioxin congener 1,2,3,4,6,7,8-HpCDD was detected in the background surface soil sample at a 

concentration exceeding the sample-adjusted CRQL; therefore, observed contamination is established 

when the contaminated surface soil sample’s concentration is three times or more above the background 

concentration [1, p. 17 (Table 2-3)]. In addition, arsenic and chromium were each detected in background 

surface soil samples at a concentration exceeding the sample-adjusted CRQL; therefore, observed 

contamination is established when the contaminated surface soil sample concentration is three times or 

more above the background concentration [1, p. 51589 (Table 2-3)]. 

Furan congener 1,2,3,4,6,7,8-HpCDF was detected in the background surface soil sample at a 

concentration below the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. Observed contamination is 

established when this furan congener concentration is three times or more above the background 

concentration [1, p. 51589 (Table 2-3)]. In addition, barium and mercury were each detected in 

background surface soil samples at concentrations below the sample-adjusted CRQL [1, p. 51589 (Table 

2-3)]. Observed contamination is established for these total metals when the surface soil sample 

concentration is three times or more above the background concentration [1, p. 51589 (Table 2-3)]. 

Furan congener 2,3,7,8-TCDF in the background surface soil sample was detected at concentrations 

below the sample-adjusted CRQL. This furan congener is considered above background when the source 

sample concentration is greater than the sample-adjusted CRQL [1, p. 51589 (Table 2-3)]. This approach 

provides the highest possible background comparison value.

- Contaminated Samples

Area Letter: A

On 18 through 22 April 2011, as part of the EPA SI, and on 5 December 2011, as part of the EPA SR, 

surface soil samples were collected from Area A [11, pp. 20-24; 12, pp. 4-17; 13, pp. 36-41; 14, pp. 12-

30]. All surface soil source samples were collected in accordance with the EPA-approved Site-Specific 

QAPP for the Creese & Cook Co. (Former) 2 SI, dated 21 January 2011, and/or the EPA-approved SiteSpecific QAPP, dated 18 April 2011, and the Site-Specific QAPP Addendum, dated 22 November 2011 

for the Creese & Cook Co. (Former) 1 SR [8, pp. 29, 50; 9, pp. 2-3, 8 (Figure 3), 11; 10, pp. 24, 27-32; 

13, p. 37; 14, pp. 12-30]. As part of the Area A characterization, 26 surface soil samples (SS-02A, SS03A, SS-04A, SS-04C, SS-05A, SS-06A, SS-07A, SS-08A, SS-09A, SS-10A, SS-11A, SS-12A, SS-18A, 

SS-20A, SS-20C, SS-21A, SS-22A, SS-23A, SS-24A, SS-24C, SS-25A, SS-26A, SS-33A, SS-35A, SO62, and SO-63) were collected from various locations throughout the contaminated soil Area A (see 

Figure 5) [12, pp. 4-17; 14, pp. 12-30; 27, pp. 4, 7, 10-12, 16, 20, 24, 28, 31, 34, 37, 53, 57-69].
Soil Exposure – General

Area A

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MAD001031574 September 2012

Table 64 – Surface Soil Samples Associated with Area A

Sample ID Sample Medium Depth (inches) Date References

SS-02A Surface Soil 0 to 12 4/18/2011 14, p. 14, 48 (Table 1); 27, p. 4

SS-03A Surface Soil 4 to 12 4/19/2011 14, pp. 15, 48 (Table 1); 27, p. 7

SS-04A Surface Soil 0 to 12 4/21/2011 14, pp. 24, 49 (Table 1); 27, p. 10

SS-04C Surface Soil 12 to 18 4/21/2011 14, pp. 24, 49 (Table 1); 27, p. 11

SS-05A Surface Soil 6 to 20 4/20/2011 14, pp. 20, 49 (Table 1); 27, p. 12

SS-06A Surface Soil 0 to 24 4/19/2011 14, pp. 16, 50 (Table 1); 27, p. 16

SS-07A Surface Soil 6 to 20 4/19/2011 14, pp. 17, 50 (Table 1); 27, p. 20

SS-08A Surface Soil 0 to 12 4/20/2011 14, pp. 19-20, 50 (Table 1); 27, p. 24

SS-09A Surface Soil 0 to 12 4/21/2011 14, pp. 23, 51 (Table 1); 27, p. 28

SS-10A Surface Soil 7 to 24 4/21/2011 14, pp. 24, 51 (Table 1); 27, p. 31

SS-11A Surface Soil 0 to 12 4/21/2011 14, pp. 25, 51 (Table 1); 27, p. 34

SS-12A Surface Soil 0 to 24 4/22/2011 14, pp. 28, 55 (Table 1); 27, p. 37

SS-18A Surface Soil 0 to 12 4/19/2011 14, pp. 15, 52 (Table 1); 27, p. 53

SS-20A Surface Soil 0 to 12 4/20/2011 14, pp. 20, 53 (Table 1); 27, p. 57

SS-20C Surface Soil 12 to 18 4/20/2011 14, pp. 20, 53 (Table 1); 27, p. 58

SS-21A Surface Soil 0 to 12 4/20/2011 14, pp. 19, 53 (Table 1); 27, p. 59

SS-22A Surface Soil 0 to 12 4/21/2011 14, pp. 24, 54 (Table 1); 27, p. 61

SS-23A Surface Soil 0 to 24 4/21/2011 14, pp. 23, 58 (Table 1); 27, p. 63

SS-24A Surface Soil 12 to 18 4/21/2011 14, pp. 23, 58 (Table 1); 27, p. 65

SS-24C Surface Soil 18 to 24 4/21/2011 14, pp. 23, 58 (Table 1); 27, p. 66

SS-25A Surface Soil 0 to 24 4/20/2011 14, pp. 19, 58 (Table 1); 27, p. 67

SS-26A Surface Soil 0 to 24 4/19/2011 14, pp. 16, 59 (Table 1); 27, p. 69

SS-33A Surface Soil 0 to 12 4/21/2011 14, pp. 23, 54 (Table 1); 27, p. 28

SS-35A Surface Soil 0 to 24 4/21/2011 14, pp. 23, 59 (Table 1); 27, p. 63

SO-62 Surface Soil 0 to 12 12/5/2011 13, pp. 39-40, 69; 26, p. 34

SO-63 Surface Soil 0 to 12 12/5/2011 13, pp. 40, 69; 26, p. 35
Soil Exposure – General

Area A

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MAD001031574 September 2012

Table 65– Surface Soil Sample Description

Sample 

ID Sample Description Reference

SS-02A

Brown, fine-to-coarse sand, some fine-to-coarse gravel (rocks), debris (metal slag, leather, and 

brick), trace silt, and trace roots. 27, p. 4

SS-03A

Black, fine-to-medium gravel and fine-to-coarse sand, trace silt, trace clay, and trace debris 

(concrete). 27, p. 7-8

SS-04A Brown, fine-to-medium sand and silt, trace fine-to-coarse gravel, and trace organics. 27, p. 10

SS-04C

Brown, fine sand, some silt, little fine-to-coarse gravel (up to 5-inch cobble), trace debris (brick, 

plastic, glass, ceramic, and slag), and trace organics. 27, p. 11

SS-05A

Light brown-to-brown, fine-to-coarse gravel (up to 10-inch cobble), little fine-to-coarse sand, 

trace silt. 27, p. 12

SS-06A

Combination of three distinct intervals: Interval 1 = dark brown-to-black, fine-to-coarse sand and 

silt, some fine-to-medium gravel, trace clay, trace debris (brick), trace organics (roots); Interval 2 

= fine-to-medium gravel; and Interval 3 = medium-to-dark brown, fine-to-coarse sand and silt, 

some debris (brick, cement), trace fine gravel.

27, p. 16-

17

SS-07A Brown, fine-to-medium sand and silt, little debris (brick, concrete, and glass).

27, p. 20-

21

SS-08A Light brown, fine-to-medium sand, little silt, little fine-to-coarse gravel, trace roots. 27, p. 24

SS-09A/

SS-33A

Light brown-to-brown, fine-to-coarse sand, little fine-to-coarse gravel, trace silt, and trace 

organics. 27, p. 28

SS-10A

Combination of two distinct intervals: Interval 1 = dark brown-to-greyish black, fine-to-coarse 

sand, some silt, trace debris (brick); Interval 2 = black silt, some fine-to-coarse sand, little debris 

(burned materials, apparent roofing and tar material), trace gravel, and contained a petroleumlike/creosote-like odor throughout the interval.

27, p. 31-

32

SS-11A

Combination of two distinct intervals: Interval 1 = dark brown silt, trace fine-to-coarse sand, 

trace debris (glass), trace organics (rootlets); Interval 2 = dark brown, fine-to-coarse sand and silt, 

some fine-to-medium gravel, little debris (brick, ash material, clinkers), trace clay, and was 

moist. 27, p. 34

SS-12A

Dark brown silt and debris (glass, brick, wood, metal, and ash), trace fine-to-coarse sand, and 

trace rootlets. 27, p. 37

SS-18A

Combination of two distinct intervals: Interval 1=dark brown, sand and silt, little organics; 

Interval 2= light brown sand (fill), and was moist. 27, p. 53

SS-20A

Dark brown, fine-to-coarse sand and gravel (up to 5-inch cobble), and trace organics (roots and 

mulch). 27, p. 57

SS-20C Dark brown, fine-to-coarse sand and gravel (up to 3-inch cobble), and trace organics. 27, p. 58

SS-21A

Brown, fine-to-medium sand, some silt, trace gravel (up to 1-inch, brick debris), and trace 

organics. 27, p. 59

SS-22A Light brown, clay, some silt, trace fine sand, trace fine-to-coarse gravel, and organics (roots). 27, p. 61

SS-23A/

SS-35A

Dark brown, fine-to-medium sand and silt, some clay, trace fine-to-coarse gravel, trace debris and 

plastic, and trace organics. 27, p. 63
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 132 HRS Documentation Record

MAD001031574 September 2012

Table 65– Surface Soil Sample Description (Concluded)

Sample 

ID Sample Description Reference

SS-24A

Dark brown, fine sand and silt, some debris (leather and plastic), trace fine-to-coarse gravel, trace 

clay, and trace organics. 27, p. 65

SS-24C Dark brown, fine sand and silt, trace gravel, trace clay, trace debris (plastic), and trace organics. 27, p. 66

SS-25A

Dark brown, fine-to-coarse sand, little gravel (up to 1-inch cobble, plastic, leather debris, possible 

coal slag), trace organics. 27, p. 67

SS-26A

Dark brown-to-black, fine-to-coarse sand, little gravel (up to 1-inch cobble, leather, glass, metal), 

trace organics. 27, p. 69

SO-62 Dark brown, organic-rich silt, little fine-to-coarse sand, trace fine gravel. 26, p. 34

SO-63 Dark brown, silt and fine-to-coarse sand, little organics, trace fine-to-medium gravel, trace clay. 26, p. 35

Twenty-one surface soil samples (SS-02A, SS-03A, SS-04A, SS-05A, SS-06A, SS-07A, SS-08A, SS09A, SS-10A, SS-11A, SS-12A, SS-18A, SS-20A, SS-21A, SS-22A, SS-23A, SS-24A, SS-25A, SS-26A, 

SS-33A, and SS-35A) collected from Area A were submitted to CLP laboratories for dioxin/furan 

analyses following DLM02.2, and for total metals analysis following ISM01.2 [12, pp. 4-17; 14, pp. 12-

30; 28, pp. 13, 15, 17, 19; 29, pp. 9, 15, 16, 24, 26, 27; 53, p. 1; 54, p. 1; 55, p. 1; 56, p. 1; 60, p. 1; 62, 

p.1, 64, p. 1]. Two surface soil samples (SO-62 and SO-63) were submitted to CLP laboratories for 

dioxin/furan analyses following DLM02.2, and total metals analysis following ISM01.3 [11, p. 27; 13, p. 

57; 28, p. 11; 29, p. 7; 50, p. 2; 57, p. 1]. Three surface soil samples (SS-04C, SS-20C, and SS-24C) were 

submitted to a CLP laboratory for only total metals analysis following ISM01.2 [12, pp. 10, 12, 13; 14, 

pp. 20, 23-24; 29, pp. 20, 23; 61, p.1; 63, p. 1]. The dioxin/furan analytical results were manually 

validated at a stage 4 level in accordance with the criteria specified in the USEPA SOW DLM02.2 and 

EPA Region I’s ESAT Dioxin/Furan Data Validation SOP ESAT-01-0007 [50, p. 1; 53, p. 1; 54, p. 1; 55, 

p. 1; 56, p. 1]. The total metals analytical data were evaluated on a Tier II level in accordance with the 

Region I Tiered Organic and Inorganic Data Validation Guidelines dated November 2008 [57, p. 1; 60, p. 

1; 61, p. 1; 62, p. 1; 63, p. 1; 64, p. 1].

Table 66 - Hazardous Substances Associated with Area A

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-02A Soil 4/18/11 1,2,3,6,7,8-HxCDD None 7.61 ng/Kg 4.91 ng/Kg 12, p. 5; 14, p. 

14; 53, p. 4; 74, 

p. 1-2, 12, 112 1,2,3,4,6,7,8-HpCDD None 223 ng/Kg 4.91 ng/Kg

2,3,7,8-TCDF None 3.14 ng/Kg 0.982 ng/Kg

1,2,3,4,6,7,8-HpCDF None 41.1 ng/Kg 4.91 ng/Kg

Barium None 73.4 mg/Kg 20.7 mg/Kg 12, p. 5; 14, p. 

14; 60, p. 11; 

81, pp. 1-2, 11, 

84

Chromium None 94.6 mg/Kg 1.0 mg/Kg

Mercury None 0.23 mg/Kg 0.10 mg/Kg
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 133 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-03A Soil 4/19/11 1,2,3,7,8,9-HxCDD None 5.37 ng/Kg 4.10 ng/Kg 12, pp. 6-8; 14, 

pp. 15; 53, p. 4; 

74, pp. 1-2, 13, 

113

1,2,3,4,6,7,8-HpCDD None 687 ng/Kg 4.10 ng/Kg

1,2,3,4,6,7,8-HpCDF None 77.1 ng/Kg 4.10 ng/Kg

Barium None 86.1 mg/Kg 20.4 mg/Kg 12, pp. 6-8; 14, 

pp. 15-16; 60, p. 

11; 81, pp. 1-2, 

12, 85

Chromium None 491 mg/Kg 1.0 mg/Kg

Mercury None 0.29 mg/Kg 0.10 mg/Kg

SS-04A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 21.6 ng/Kg 4.82 ng/Kg 12, p. 13; 14, p. 

24; 56, p. 4; 77, 

pp. 1-2, 9, 104 1,2,3,7,8,9-HxCDD None 5.09 ng/Kg 4.82 ng/Kg

1,2,3,4,6,7,8-HpCDD None 694 ng/Kg 4.82 ng/Kg

2,3,7,8-TCDF None 5.75 ng/Kg 0.964 ng/Kg

1,2,3,4,6,7,8-HpCDF None 101 ng/Kg 4.82 ng/Kg

Chromium High

861 J

(667) mg/Kg 1.9 mg/Kg

12, p. 13; 14, p. 

24; 62, p. 13; 

83, pp. 1-2, 17, 

Mercury None 0.31 mg/Kg 0.11 mg/Kg 91

SS-04C Soil 4/21/11

Chromium Unknown

871 J

(675) mg/Kg 2.6 mg/Kg

12, pp. 13-14; 

14, p. 24; 61, p. 

8; 82, pp. 1-2, 

11, 66

SS-05A Soil 4/20/11 1,2,3,4,6,7,8-HpCDD None 141 ng/Kg 4.83 ng/Kg 12, p. 10; 14, p. 

20; 54, p. 4; 75, 

1,2,3,4,6,7,8-HpCDF None 19.9 ng/Kg 4.83 ng/Kg pp. 1-2, 11, 106

Chromium None 196 mg/Kg 0.8 mg/Kg 12, p. 10; 14, p. 

20; 60, p. 11; 

81, pp. 1-2, 12, 

Mercury None 0.23 mg/Kg 0.10 mg/Kg 86

SS-06A Soil 4/19/11 1,2,3,4,6,7,8-HpCDD None 1,160 ng/Kg 43.0 ng/Kg 12, pp. 7-8; 14, 

p. 16; 53, p. 5; 

74, pp. 1-2, 14, 

1,2,3,4,6,7,8-HpCDF None 134 ng/Kg 43.0 ng/Kg 114

Barium None 67.8 mg/Kg 15.0 mg/Kg 12, pp. 7-8; 14, 

p. 16; 60, p. 11; 

81, pp. 1-2, 13, 

87

Chromium None 337 mg/Kg 0.7 mg/Kg

Mercury None 7.2 mg/Kg 1.08 mg/Kg

SS-24C Soil 4/21/11

Chromium None 152 mg/Kg 1.1 mg/Kg

12, pp. 12, 14; 

14, p. 23-24; 63, 

p. 8; 84, pp. 1-2, 

9, 60
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 134 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-07A Soil 4/19/11 1,2,3,4,6,7,8-HpCDD None 885 ng/Kg 36.3 ng/Kg 12, pp. 7-8; 14, 

p. 17; 54, p. 4; 

75, p. 1-2, 12, 

1,2,3,4,6,7,8-HpCDF None 96.2 ng/Kg 36.3 ng/Kg 107

Arsenic None 50 mg/Kg 0.8 mg/Kg 12, pp. 7-8; 14, 

p. 17; 60, p. 11; 

81, pp. 1-2, 13, 

88

Chromium None 623 mg/Kg 2.3 mg/Kg

Mercury None 0.7 mg/Kg 0.11 mg/Kg

SS-08A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 7.78 ng/Kg 4.82 ng/Kg 12, pp. 9-10; 14, 

pp. 19-20; 54, p. 

4; 75, pp. 1-2, 

13, 108

1,2,3,4,6,7,8-HpCDD None 231 ng/Kg 4.82 ng/Kg

1,2,3,4,6,7,8-HpCDF None 42.7 ng/Kg 4.82 ng/Kg

Chromium High

93.1 J

(72.2) mg/Kg 0.8 mg/Kg

12, pp. 9-10; 14, 

pp. 19-20; 62, p. 

12; 83, pp. 1-2, 

Mercury None 0.15 mg/Kg 0.11 mg/Kg 11, 92

SS-09A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 90.4 ng/Kg 4.83 ng/Kg 12, pp. 12-13; 

14, p. 23; 55, p. 

4; 76, pp. 1-2, 9, 

95

2,3,7,8-TCDF None 1.62 ng/Kg 0.967 ng/Kg

1,2,3,4,6,7,8-HpCDF None 14.2 ng/Kg 4.83 ng/Kg

Mercury Unknown

0.7 J

(0.38) mg/Kg 0.10 mg/Kg

12, pp. 12-13; 

14, p. 23; 64, p. 

11; 85, pp. 1-2, 

9, 76

SS-10A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 313 ng/Kg 49.1 ng/Kg 12, p. 13; 14, p. 

24; 56, p. 4; 77, 

1,2,3,4,6,7,8-HpCDF None 55.1 ng/Kg 49.1 ng/Kg pp. 1-2, 10, 105

Barium None 68.5 mg/Kg 19.2 mg/Kg 12, p. 13; 14, p. 

24; 62, p. 13; 83, 

pp. 1-2, 17, 93 Chromium High

79.9 J

(61.9) mg/Kg 1.0 mg/Kg

Mercury None 0.39 mg/Kg 0.11 mg/Kg

SS-11A Soil 4/21/11

1,2,3,4,6,7,8-HpCDF None 8.02 ng/Kg 4.83 ng/Kg

12, pp. 13-14; 

14, p. 25; 56, p. 

4; 77, pp. 1-2, 

11, 106

Chromium High

175 J

(136) mg/Kg 0.8 mg/Kg

12, pp. 13-14; 

14, p. 25; 62, p. 

14; 83, pp. 1-2, 

Mercury None 0.21 mg/Kg 0.11 mg/Kg 18, 94
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 135 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-12A Soil 4/22/11 1,2,3,6,7,8-HxCDD None 52.5 ng/Kg 4.84 ng/Kg 12, pp. 15-16; 

14, p. 28; 55, p. 

4; 76, pp. 1-2, 

10, 96

1,2,3,7,8,9-HxCDD None 25.4 ng/Kg 4.84 ng/Kg

1,2,3,4,6,7,8-HpCDD High

1,000 EB

(100) ng/Kg 4.84 ng/Kg

2,3,7,8-TCDF None 8.82 ng/Kg 0.969 ng/Kg

2,3,4,6,7,8-HxCDF None 31.4 ng/Kg 4.84 ng/Kg

1,2,3,4,6,7,8-HpCDF None 1,050 ng/Kg 4.84 ng/Kg

Barium None 859 mg/Kg 20.2 mg/Kg 12, pp. 15-16; 

14, p. 28; 64, p. 

11; 85, pp. 1-2, 

9, 77

Chromium None 91.1 mg/Kg 1.0 mg/Kg

Mercury Unknown

0.63 J

(0.34) mg/Kg 0.13 mg/Kg

SS-18A Soil 4/19/11

1,2,3,4,6,7,8-HpCDD None 105 ng/Kg 52.0 ng/Kg

12, pp. 6, 8; 14, 

p. 15; 53, p. 6; 

74, pp. 1-2, 19, 

119

Chromium None 72.5 mg/Kg 0.9 mg/Kg 12, pp. 6, 8; 14, 

p. 15; 60, p. 12; 

81, pp. 1-2, 16, 

Mercury None 0.24 mg/Kg 0.11 mg/Kg 93

SS-20A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 16.1 ng/Kg 4.80 ng/Kg 12, pp. 10-11; 

14, p. 20; 56, p. 

5; 77, pp. 1-2, 

12, 107

1,2,3,4,6,7,8-HpCDD None 523 ng/Kg 4.80 ng/Kg

1,2,3,4,6,7,8-HpCDF None 71.1 ng/Kg 4.80 ng/Kg

Barium None 164 mg/Kg 17.2 mg/Kg 12, pp. 10-11; 

14, p. 20; 62, p. 

14; 83, pp. 1-2, 

18, 95

Chromium High

169 J

(131) mg/Kg 0.9 mg/Kg

Mercury None 0.32 mg/Kg 0.10 mg/Kg

SS-20C Soil 4/20/11

Chromium Unknown

216 J

(167) mg/Kg 0.9 mg/Kg

12, pp. 10-11; 

14, p. 20; 61, p. 

10; 82, pp. 1-2, 

12, 79
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 136 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-21A Soil 4/20/11 1,2,3,4,6,7,8-HpCDD None 1,010 ng/Kg 54.4 ng/Kg 12, pp. 9-10; 14, 

p. 19; 54, p. 5; 

75, pp. 1-2, 14, 

1,2,3,4,6,7,8-HpCDF None 132 ng/Kg 54.4 ng/Kg 109

Barium None 73.6 mg/Kg 20.9 mg/Kg 12, pp. 9-10; 14, 

p. 19; 60, p. 12; 

81, pp. 1-2, 17, 

95

Chromium None 117 mg/Kg 1.0 mg/Kg

Mercury None 0.47 mg/Kg 0.10 mg/Kg

SS-22A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 105 ng/Kg 4.72 ng/Kg 12, pp. 12-13; 

14, p. 24; 56, p. 

5; 77, pp. 1-2, 

1,2,3,4,6,7,8-HpCDF None 6.62 ng/Kg 4.72 ng/Kg 13, 108

Barium None 74.6 mg/Kg 17.9 mg/Kg 12, pp. 12-13; 

14, p. 24; 64, p. 

11; 85, pp. 1-2, 

Chromium None 53.5 mg/Kg 0.9 mg/Kg 10, 79

SS-23A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 13.2 ng/Kg 4.82 ng/Kg 12, pp. 12-13; 

14, p. 23; 56, p. 

5; 77, pp. 1-2, 

14, 109

1,2,3,4,6,7,8-HpCDD None 258 ng/Kg 4.82 ng/Kg

2,3,7,8-TCDF None 2.7 ng/Kg 0.965 ng/Kg

1,2,3,4,6,7,8-HpCDF None 57.8 ng/Kg 4.82 ng/Kg

Mercury None 0.80 mg/Kg 0.11 mg/Kg

12, pp. 12-13; 

14, p. 23; 62, p. 

14; 83, pp. 1-2, 

19, 96

SS-24A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 768 ng/Kg 75.6 ng/Kg 12, pp. 12-13; 

14, p. 23; 56, p. 

6; 77, pp. 1-2, 

15, 110

1,2,3,7,8,9-HxCDD None 205 ng/Kg 75.6 ng/Kg

1,2,3,4,6,7,8-HpCDD None 17,000 ng/Kg 75.6 ng/Kg

2,3,4,6,7,8-HxCDF None 116 ng/Kg 75.6 ng/Kg

1,2,3,4,6,7,8-HpCDF None 2,440 ng/Kg 75.6 ng/Kg

Barium None 165 mg/Kg 32.5 mg/Kg 12, pp. 12-13; 

14, p. 23; 62, p. 

14; 83, pp. 1-2, 

19, 97

Chromium High

4430 J

(3,430) mg/Kg 16.2 mg/Kg

Mercury None 1.4 mg/Kg 0.16 mg/Kg

SS-24C Soil 4/21/11

Chromium None 152 mg/Kg 1.1 mg/Kg

12, pp. 12, 14; 

14, p. 23-24; 63, 

p. 8; 84, pp. 1-2, 

9, 60
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 137 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Continued)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SS-25A Soil 4/20/11 1,2,3,6,7,8-HxCDD None 159 ng/Kg 65.3 ng/Kg 12, pp. 9-10; 14, 

p. 19; 54, p. 5; 

75, pp. 1-2, 15, 

110

1,2,3,7,8,9-HxCDD None 135 ng/Kg 65.3 ng/Kg

1,2,3,4,6,7,8-HpCDD None 4,600 ng/Kg 65.3 ng/Kg

2,3,4,6,7,8-HxCDF None 94.5 ng/Kg 65.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 970 ng/Kg 65.3 ng/Kg

Arsenic None 45.2 mg/Kg 1.1 mg/Kg 12, pp. 9-10; 14, 

p. 19; 60, p. 12; 

81, pp. 1-2, 17, 

96

Barium None 71.2 mg/Kg 21.6 mg/Kg

Chromium None 1,030 mg/Kg 3.2 mg/Kg

Mercury None 0.85 mg/Kg 0.14 mg/Kg

SS-26A Soil 4/19/11 1,2,3,6,7,8-HxCDD None 382 ng/Kg 61.8 ng/Kg 12, pp. 7-8; 14, 

p. 16; 54, p. 5; 

75, pp. 1-2, 16, 

111

1,2,3,7,8,9-HxCDD None 140 ng/Kg 61.8 ng/Kg

1,2,3,4,6,7,8-HpCDD None 12,100 ng/Kg 61.8 ng/Kg

2,3,4,6,7,8-HxCDF None 84.8 ng/Kg 61.8 ng/Kg

1,2,3,4,6,7,8-HpCDF None 1,840 ng/Kg 61.8 ng/Kg

Barium None 173 mg/Kg 20.2 mg/Kg 12, pp. 7-8; 14, 

p. 16; 62, p. 12; 

83, pp. 1-2, 11, 

98

Chromium High

2,770 J

(2,150) mg/Kg 10.1 mg/Kg

Mercury None 0.97 mg/Kg 0.13 mg/Kg

SS-33A Soil 4/21/11 1,2,3,4,6,7,8-HpCDD None 145 ng/Kg 4.75 ng/Kg 12, pp. 12-13; 

14, p. 23; 55, p. 

6; 76, pp. 1-2, 

1,2,3,4,6,7,8-HpCDF None 17.8 ng/Kg 4.75 ng/Kg 14, 101

Chromium None 59.3 mg/Kg 0.9 mg/Kg

12, pp. 12-13; 

14, p. 23; 64, p. 

12; 85, pp. 1-2, 

12, 84

SS-35A Soil 4/21/11 1,2,3,6,7,8-HxCDD None 7.92 ng/Kg 4.89 ng/Kg 12, pp. 12-13; 

14, p. 23; 56, p. 

6; 77, pp. 1-2, 

17, 112

1,2,3,4,6,7,8-HpCDD None 157 ng/Kg 4.89 ng/Kg

2,3,7,8-TCDF None 1.92 ng/Kg 0.979 ng/Kg

1,2,3,4,6,7,8-HpCDF None 35 ng/Kg 4.89 ng/Kg

Mercury None 0.69 mg/Kg 0.12 mg/Kg

12, pp. 12-13; 

14, p. 23; 62, p. 

14; 83, pp. 1-2, 

20, 100
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 138 HRS Documentation Record

MAD001031574 September 2012

Table 66 - Hazardous Substances Associated with Area A (Concluded)

Sample

ID

Sample

Type Date

Hazardous 

Substance 1 Bias*

Hazardous 

Substance 

Concentration

SampleAdjusted 

CRQL Reference

SO-62 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 776 ng/Kg 75.3 ng/Kg 11, pp. 23, 25; 

13, p. 39-40, 69; 

50, p. 7; 71, pp. 

1-2, 22, 120

1,2,3,7,8,9-HxCDD None 391 ng/Kg 75.3 ng/Kg

1,2,3,4,6,7,8-HpCDD None 21,900 ng/Kg 75.3 ng/Kg

2,3,4,6,7,8-HxCDF None 126 ng/Kg 75.3 ng/Kg

1,2,3,4,6,7,8-HpCDF None 2,840 ng/Kg 75.3 ng/Kg

Barium None 114 mg/Kg 36.9 mg/Kg 11, pp. 23, 25; 

13, p. 39-40, 69; 

57, p. 14; 78, 

pp. 1-2, 19, 97

Chromium None 10,700 mg/Kg 18.5 mg/Kg

Mercury None 1.3 mg/Kg 0.18 mg/Kg

SO-63 Soil 12/5/11 1,2,3,6,7,8-HxCDD None 167 ng/Kg 4.87 ng/Kg 11, pp. 23-24; 

13, p. 40, 69; 

50, p. 7; 71, pp. 

1-2, 23, 121-122

1,2,3,7,8,9-HxCDD None 34.8 ng/Kg 4.87 ng/Kg

1,2,3,4,6,7,8-HpCDD None 3,260 ng/Kg 24.3 ng/Kg

2,3,7,8-TCDF None 3.59 ng/Kg 0.973 ng/Kg

2,3,4,6,7,8-HxCDF None 53.8 ng/Kg 4.87 ng/Kg

1,2,3,4,6,7,8-HpCDF None 829 ng/Kg 4.87 ng/Kg

Chromium None 768 mg/Kg 1.2 mg/Kg 11, pp. 23-24; 

13, p. 40, 69; 

57, p. 14; 78, 

Mercury None 0.67 mg/Kg 0.12 mg/Kg pp. 1-2, 19, 98

CRQL = Contract Required Quantitation Limit.

ng/Kg = Nanograms per kilogram. mg/Kg = Milligrams per kilogram.

HxCDD= Hexachlorodibenzodioxin.

HpCDD= Heptachlorodibenzodioxin. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran. TCDF = Tetrachlorodibenzofuran.

J = The associated numerical value is an estimated quantity [61, pp. 6, 8-11; 62, pp. 10, 12-15; 64, 

p. 11; 142, p. B-21].

EB = The associated compound or element was detected in rinsate blank samples collected for 

quality control [55, p. 4]. The potential contribution for carryover from non-dedicated sampling 

equipment has been evaluated. In most cases, the concentration of the analyte or compound observed in a 

sample is significantly greater than the concentration observed in the associated equipment blank. 

Therefore, the sample data can be used with a high degree of certainty to confirm the presence of the 

substance in the samples to confirm the presence of the substance in the samples [44].

* = An explanation for the direction of bias is provided in Reference 71, Table 3; Reference 74, 

Table 3; Reference 75, Table 3; Reference 76, Table 3; Reference 77, Table 3; Reference 78; Reference 

81, Table 3; Reference 82, Table 3; Reference 83, Table 3; Reference 84, Table 3; and Reference 85, 

Table 3.

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

after adjustment. Analytical adjustments are based on the EPA Fact Sheet, Using Qualified Data to 

Document an Observed Release and Observed Contamination [140, pp. 4-8]. 
Soil Exposure – General

Area A

Creese & Cook Tannery (Former) 139 HRS Documentation Record

MAD001031574 September 2012

Among the 26 selected surface soil samples: 1,2,3,6,7,8-HxCDD was detected at a maximum 

concentration of 776 ng/Kg in surface soil sample SO-62; 1,2,3,7,8,9-HxCDD was detected at a 

maximum concentration of 391 ng/Kg in surface soil sample SO-62; 1,2,3,4,6,7,8-HpCDD was detected 

at a maximum concentration of 21,900 ng/Kg in surface soil sample SO-62; 2,3,7,8-TCDF was detected 

at a maximum concentration of 8.82 ng/Kg in surface soil sample SS-12A; 2,3,4,6,7,8-HxCDF was 

detected at a maximum concentration of 126 ng/Kg in surface soil sample SO-62; 1,2,3,4,6,7,8-HpCDF 

was detected at a maximum concentration of 2,840 ng/Kg in surface soil sample SO-62; arsenic was 

detected at a maximum concentration of 50 mg/Kg in surface soil sample SS-07A; barium was detected at 

a maximum concentration of 859 mg/Kg in surface soil sample SS-12A; chromium was detected at a 

maximum concentration of 10,700 mg/Kg in surface soil sample SO-62; and mercury was detected at a 

maximum concentration of 7.2 mg/Kg in surface soil sample SS-06A [13, pp. 39-40, 69; 14, pp. 16-17, 

28; 50, p. 7; 55, p. 4; 57, p. 14; 60, p. 11; 64, p. 11; 71, pp. 23, 121-122; 76, pp. 10, 96; 78, pp. 19, 98; 81, 

pp. 12, 87-88; 85, pp. 9, 77]. For the purpose of this evaluation, shallow soil sample concentrations which 

are significantly above background for the respective hazardous substances have been used to associate 

hazardous substances with Area A [1, pp. 51588 (Section 2.2.2), 51589 (Table 2-3)].

Attribution

Based on the operational history of the leather tannery and common contaminants detected at leather 

tanneries, the following hazardous substances are considered hazardous substances associated with the 

contaminated soil area: dioxin/furans (1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 

2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF) and chromium (see Contaminated Samples 

section above) [32, p. 7; 113, p. 5; 164, p. 1; 165, p. 3]. Chromium is the most common heavy metal 

waste from the tanning process, which employs chromium salts in the tanning process [34, pp. 7-12; 164 

p. 7; 166, pp. 2-4]. Dioxin was not used in the tanning process, but it is a common impurity in chlorinated 

phenols, commonly used in the tanning process as a fungicide [164, pp. 1, 7]. Other heavy metals, 

including arsenic, mercury and barium, are also used in the tanning industry and detected in the 

wastestream on other leather tanning sites [167, p. 42; 168, p. 1; 169, p. 4-5]. 

For the purpose of this evaluation, 26 shallow soil samples collected from Area A in April 2011 and 

December 2011 were selected to document observed contamination in Area A. Among the 26 selected 

soil samples, the presence of the following hazardous substances as been documented (maximum 

concentration in parentheses): 1,2,3,6,7,8-HxCDD (776 ng/Kg), 1,2,3,7,8,9-HxCDD (391 ng/Kg), 

1,2,3,4,6,7,8-HpCDD (21,900 ng/Kg), 2,3,7,8-TCDF (8.82 ng/Kg), 2,3,4,6,7,8-HxCDF (126 ng/Kg), 

1,2,3,4,6,7,8-HpCDF (2,840 ng/Kg), arsenic (50 mg/Kg), barium (859 mg/Kg), chromium (10,700 

mg/Kg), and mercury (7.2 mg/Kg) (see Contaminated Samples section above). The concentrations of each 

of these substances were detected at greater than or equal to three times the highest respective background 

soil sample in the aforementioned shallow soil samples collected from Area A (see Contaminated 

Samples section above). Chromium was detected in 24 of the 26 aforementioned shallow soil samples 

collected from Area A, with a maximum concentration of 10,700 mg/Kg in shallow surface soil/source 

sample SO-62 (see Contaminated Samples section above). The analytical results for these samples are 

used to attribute hazardous substances to this area (see Contaminated Samples section above) [1, pp. 

51588 (Section 2.2.2), 51589 (Table 2-3)]. 

Table 67 – Hazardous Substances Associated with Surface Soil/Source Samples

Hazardous Substance Evidence References

1,2,3,6,7,8-HxCDD Analytical results see Contaminated Samples section
Soil Exposure – General

Area A

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Table 67 – Hazardous Substances Associated with Surface Soil/Source Samples (Concluded)

Hazardous Substance Evidence References

1,2,3,7,8,9-HxCDD Analytical results see Contaminated Samples section

1,2,3,4,6,7,8-HpCDD Analytical results see Contaminated Samples section

2,3,7,8-TCDF Analytical results see Contaminated Samples section

2,3,4,6,7,8-HxCDF Analytical results see Contaminated Samples section

1,2,3,4,6,7,8-HpCDF Analytical results see Contaminated Samples section

Arsenic Analytical results see Contaminated Samples section

Barium Analytical results see Contaminated Samples section

Chromium Analytical results see Contaminated Samples section

Mercury Analytical results see Contaminated Samples section

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran.

Area Hazardous Waste Quantity

The Hazardous Waste Quantity of Area A was calculated based on the Area Factor Value of contaminated

soil. The Hazardous Constituent Quantity and Hazardous Wastestream Quantity values were not 

evaluated for Area A because insufficient information was available [1, p. 51647, Table 5-2]. An area of 

“contaminated soil” cannot be evaluated for Hazardous Waste Quantity for the Soil Exposure Pathway 

based on its volume [1, p. 51647 (Table 5-2)].

Hazardous Constituent Quantity:

Description

The hazardous constituent quantity for Area A could not be adequately determined according to the HRS

requirements; that is, the total mass of all CERCLA hazardous substances in the source is not known and 

cannot be estimated with reasonable confidence [1, pp. 51590-51591 (Section 2.4.2.1.1)]. There are 

insufficient historical and current data (Manifests, PRP records, State records, Permits, Waste 

concentration data, etc.) available to adequately calculate the total mass of all CERCLA hazardous 

substances in the source and the associated releases from the source. Therefore, there is insufficient 

information to evaluate the associated releases from the source to calculate the hazardous constituent 

quantity for Area A with reasonable confidence.
Soil Exposure – General

Area A

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Table 68 - Hazardous Constituent Quantity for Area A

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds): 

Hazardous Constituent Quantity Assigned Value: Not Scored

Hazardous Constituent Quantity Complete? No

Hazardous Wastestream Quantity:

Description

The hazardous wastestream quantity for Area A could not be adequately determined according to the 

HRS requirements; that is, the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and releases from the source is not known and cannot be estimated with 

reasonable confidence [1, p. 51591 (Section 2.4.2.1.2)]. There are insufficient historical and current data 

(Manifests, PRP records, State records, Permits, Waste concentration data, Annual reports, etc.) available 

to adequately calculate the total mass of all hazardous wastestreams and CERCLA pollutants and 

contaminants for the source and the associated releases from the source. Therefore, there is insufficient 

information to adequately calculate or extrapolate the hazardous wastestream quantity for Area A with 

reasonable confidence.

Table 69 - Hazardous Wastestream Quantity for Area A

Hazardous Substance Constituent Quantity (pounds) References

NS (insufficient information)

NS = Not Scored.

Sum (pounds):

Wastestream Quantity/5,000 [1, p. Table 5-2):

Hazardous Wastestream Quantity Assigned Value: Not Scored

Volume:

Description

Since a volume measurement of Area A is not applicable for the Soil Exposure Pathway, a value of 0 is 

assigned [1, pp. 51591 (Section 2.4.2.1.3), 51647 (Section 5.1.2.2, Table 5-2)].
Soil Exposure – General

Area A

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Table 70 - Volume of Area A

Source Type

Description

(# drums or dimensions)

Units

(yd3/gal) References

NS (insufficient information)

NS = Not Scored.

Sum (yd3

/gal):

Equation for Assigning Value (Ref. 1, Table 5-2):

Volume Assigned Value: 0

Area:

Description

The area of Area A was determined by considering the sampling locations which document observed 

contamination of 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 

2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, arsenic, barium, chromium, and mercury, and the area lying 

between such locations, with the exception of the portions of Area A which are covered with maintained 

asphalt paving and building footprints [1, p. 51646 (Section 5.0.1); 21]. 

Area A is contained on portions of three separate properties, the 33 Water Street parcel, the adjacent 

MBTA Right-of-way parcel, and the 20 Cheever street parcel defined by 12 shallow surface soil samples 

(SS-12A, SS-02A, SS-18A, SS-05A, SS-20A, SS-21A, SS-11A, SS-22A, SS-23A, SS-25A, SS-24A, and 

SS-26A) (see Figure 5) [17]. Based on GPS documentation of the Water Street/MBTA Source observed 

during the EPA SI and SR, the area of observed contamination (Area A) was determined to be 

approximately 114,099 ft2 (see Figure 5) [12, pp. 4-17; 21]. 

The portion of the 33 Water Street parcel contained within Area A which is covered by permanent, or 

otherwise maintained, essentially impermeable cover (asphalt pavement and buildings) must be excluded 

in evaluating the Soil Exposure Pathway [1, p. 51646 (Section 5.0.1)]. The area occupied by buildings 

and maintained asphalt pavement was determined for the Water Street portion of Area A by measuring 

the area of the on-site condominium buildings and asphalt using digital orthophotographs and ESRI 

ArcGIS Desktop 10.0 version 10.0 [21]. The area of the on-site condominium building and asphalt 

(maintained engineered cover) located within the Water Street portion of Area A was determined to be 

approximately 37,272 ft2 [21]. The area of observed contamination (Area A) available for resident 

population target evaluation was determined to be 76,827 ft2 [21].

114,099 ft2 (total area) – 37,272 ft2 (area of condominium buildings and paved parking area) = 76,827 ft2

Area A therefore comprises 76,827 ft2 of contaminated soil where hazardous waste generated from on-site 

activities has been disposed of or has come to be located and meets the criteria for observed 

contamination [1, p. 51646 (Section 5.0.1); 21].
Soil Exposure – General

Area A

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Table 71 - Area

Source Type Units (ft2) References

Contaminated Soil 76,827 Figure 5; 21

Sum (ft2

): 76,827

Equation for Assigning Value [1, Table 5-2]: Area ÷ 34,000

Area Assigned Value: 2.26

Area Hazardous Waste Quantity Value:

The Hazardous Waste Quantity Value for Area A was assigned based on the Area Factor Value (2.26) [1, 

pp. 51591 (Section 2.4.2.1.5), 51646 (Section 5.0.1), 51647 (Table 5-2)].
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

5.1 RESIDENT POPULATION THREAT

There are 52 residents located on the 33 Water Street parcel, which has been documented to contain an 

area of observed contamination (Area A) with the following hazardous substances attributable to the site 

and present at concentrations significantly above background concentrations: 1,2,3,6,7,8-HxCDD, 

1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, 

arsenic, barium, chromium, and mercury (see Contaminated Sample section) [21; 163]. There are four 

residential condominium buildings (Buildings A through D) located on the Water Street property, all

located within 200 feet of shallow surface soil samples collected within Area A (see Figure 5) [163]. 

Chromium was detected above its respective reference dose value in five surface soil samples (SS-03A, 

SS-04A, SS-04C, SS-06A, and SS-07A), while arsenic was detected above its respective reference dose 

and cancer risk screening value in one surface soil/source sample (SS-07A) (see Contaminated Sample 

section) [4, pp. A-30, A-84]. In addition, hazardous substances attributable to the site and present at 

concentrations significantly above background were detected at 10 surface soil sample locations 

encompassing 12 shallow surface soil samples (SS-02A, SS-05A, SS-08A, SS-09A, SS-10A, SS-11A, 

SS-18A, SS-20A, SS-20C, SS-21A, SS-22A, and SS-33A) which did not exceed either the reference dose 

and cancer risk screening value[4, pp. A-30, A-34, A-84, A-184, A-186, A-202, A-204, A-212, A-236, A332].

5.1.1 LIKELIHOOD OF EXPOSURE

During activities conducted as part of the EPA SI and SR, residents of the Water Street parcel were 

documented to reside within the four residential condominium buildings and to utilize the common area 

within the area of observed contamination (Area A) [12, pp. 1, 17; 163]. Based on GPS documentation of 

the location of soil samples collected on the Water Street property during the EPA SI, the distance of each 

surface soil sample documenting observed contamination to the four condominium buildings was 

determined [163]. The unobstructed linear distance (travel distance) from each sample location to the 

Water Street condominium buildings (Condominium Buildings A through D) was determined using 

digital orthophotographs and ESRI ArcGIS Desktop 10.0 version 10.0 [163]. Each of the 14 surface 

source samples presented as part of the Soil Exposure Pathway evaluation was within 200 unobstructed 

feet of at least one of the condominium buildings, and 13 of the 14 samples were within 200 unobstructed 

feet of multiple condominium buildings [163]. Table 72 is a summary of the surface source samples 

presented in this evaluation whose unobstructed linear distance (travel distance) to the various 

condominium buildings is less than 200 feet. 

Table 72 - Resident Population Threat Likelihood of Exposure Factor

Sample ID Distance of Population/Resource from Area of Observed Contamination References

SS-02A 8.41 feet from Building C, 72.91 feet from Building D 163

SS-03A

164.56 feet from Building B, 29.65 feet from Building C, 187.07 feet from Building 

D

163

SS-04A/SS-04C 28.0 feet from Building B, 12.16 feet from Building C, 173.61 feet from Building D 163

SS-05A 9.26 feet from Building B, 97.15 feet from Building C 163

SS-06A

145.02 feet from Building A, 83.91 feet from Building B, 92.69 feet from Building 

C

163

SS-07A 146.54feet from Building A, 27.01 feet from Building B, 42.54 feet from Building C 163

SS-08A 139.10 feet from Building A, 11.85 feet from Building B 163
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

Table 72 - Resident Population Threat Likelihood of Exposure Factor (Concluded)

Sample ID Distance of Population/Resource from Area of Observed Contamination References

SS-09A/SS-33A

41.39 feet from Building A, 17.58 feet from Building B, 151.25 feet from Building 

C

163

SS-10A 25.40 feet from Building A, 126.10 feet from Building B 163

SS-11A 4.57 feet from Building A, 185.19 feet from Building B 163

SS-18A

136.91 feet from Building B, 21.59 feet from Building C, 68.90 feet from Building 

D

163

SS-20A/SS-20C 88.40 feet from Building A, 68.59 feet from Building B 163

SS-21A 62.95 feet from Building A, 133.01feet from Building B 163

SS-22A 31.08 feet from Building A 163

An area of observed contamination (Area A) is located on and within 200 feet of the residences; therefore 

a Resident Population Threat Likelihood of Exposure Factor Category Value of 550 is assigned [1, p. 

51646 (Section 5.1.1)].

Resident Population Threat Likelihood of Exposure Factor Category Value: 550

5.1.2 WASTE CHARACTERISTICS

Source samples collected from source areas throughout the Creese & Cook Tannery (Former) site have 

documented the presence of the following hazardous substances: 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-

HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, arsenic, 

barium, chromium, and mercury (see Source Nos. 1 through 4 characterization). In addition, surface 

source samples collected from Soil Contamination Area A document observed contamination of these 

same substances (see Contaminated Samples section above). 

5.1.2.1 Toxicity

Table 73 - Toxicity Factor

Hazardous Substance Toxicity Factor Value References

1,2,3,6,7,8-HxCDD 10,000 4, p. A-202

1,2,3,7,8,9-HxCDD 10,000 4, p. A-204

1,2,3,4,6,7,8-HpCDD 10,000 4, p. A-184

2,3,7,8-TCDF 10,000 4, p. A-332

2,3,4,6,7,8-HxCDF 10,000 4, p. A-212

1,2,3,4,6,7,8-HpCDF 10,000 4, p. A-186

Arsenic 10,000 4, p. A-30

Barium 10,000 4, p. A-34

Chromium 10,000 4, p. A-84

Mercury 10,000 4, p. A-236

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran.

The hazardous substances with the highest toxicity (1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 

1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, arsenic, barium, 

chromium, or mercury) is used to assign the value to the Toxicity Factor for the Residential Population 

Threat [1, p. 51646, Section 5.1.2.1].

Toxicity Factor Value: 10,000

5.1.2.2 Hazardous Waste Quantity

The Hazardous Waste Quantity Factor Value was assigned as specified in Sections 2.4.2 and 5.1.2.2, 

based on the Area Factor Value for Area A.

Table 74 - Hazardous Waste Quantity Factor

Area Letter Source Type Area Hazardous Waste Quantity

A Contaminated Soil 2.26

Sum of Values: 1.79

Based on HRS Section 2.4.2.2, if the Hazardous Constituent Quantity is not adequately determined for 

one or more areas and if any target for the Soil Exposure Pathway is subject to Level I or Level II 

concentrations, a factor value is assigned from Table 2-6 or a value of 10, whichever is greater, as the 

Hazardous Waste Quantity Factor Value for that pathway [1, pp. 51591, 51592, Section 2.4.2.2].

Hazardous Waste Quantity Factor Value (1, p. 51591, Table 2-6): 10

5.1.2.3 Calculation of Waste Characteristics Factor Category Value

The Toxicity Factor Value for 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-

TCDF, 2,3,4,6,7,8-HxCDF, 1,2,3,4,6,7,8-HpCDF, arsenic, barium, chromium, or mercury (10,000) is 

multiplied by the Hazardous Waste Quantity Factor Value for the site (10) in order to determine the 

Waste Characteristics Product, subject to a maximum value of 1 × 108 [1, p. 51592, Section 2.4.3.1]. 

10,000 × 10 = 1 × 105

Toxicity Factor Value: 10,000

Hazardous Waste Quantity Factor Value: 10

Toxicity Factor Value × Hazardous Waste Quantity Factor Value: 1 × 105

From HRS Table 2-7, a Waste Characteristics Product of 1 × 105 is assigned a Waste Characteristics 

Factor Category Value of 18 [1, p. 51592, Section 2.4.3.1].

Waste Characteristic Factor Category Value [1, Table 2-7]: 18
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

5.1.3 TARGETS

Level I Concentrations

The five shallow surface soil samples presented, which document Level I concentrations of site associated 

hazardous substances, are located within the documented area of observed contamination (Area A) and 

within 200 feet of one or more of the on-site condominium buildings (see Contaminated Samples section 

above) [163]. The shallow surface soil samples presented which document Level I concentrations and are 

located within 200 feet of the following on-site building area as follows: SS-03A, SS-04A, and SS-04C 

are located within 200 feet of Condominium Buildings B through D; and SS-06A and SS-07A are located 

within 200 feet of Condominium Buildings A through C [163]. Chromium was detected above its 

respective reference dose value in five shallow surface soil samples (SS-03A, SS-04A, SS-04C, SS-06A, 

and SS-07A), while arsenic was detected above its respective reference dose and cancer risk screening 

value in one shallow surface soil sample (SS-07A) [4, pp. A-30, A-84].

Sample ID: SS-03A

Area Letter: A

Reference for Benchmark: 4, pp. A-34, A-84, A-236

Table 75 – Hazardous Substance Benchmark Concentrations in SS-03A

Hazardous 

Substance

Hazardous Substance 

Concentration

[See Table 93]

Benchmark 

Concentration Benchmark

Barium 86.1 mg/Kg 5,500 mg/Kg Reference Dose

Chromium 491 mg/Kg 230 mg/Kg Reference Dose

Mercury 0.29 mg/Kg 23 mg/Kg Reference Dose

mg/Kg = Milligrams per kilogram.

Sample ID: SS-04A

Area Letter: A

Reference for Benchmark: 4, pp. A-84, A-236

Table 76 – Hazardous Substance Benchmark Concentrations in SS-04A

Hazardous 

Substance

Hazardous Substance 

Concentration 

[See Table 93]

Benchmark 

Concentration Benchmark

Chromium

861 J

(667) mg/Kg 230 mg/Kg Reference Dose

Mercury 0.31 mg/Kg 23 mg/Kg Reference Dose

mg/Kg = Milligrams per kilogram.

J = The associated numerical value is an estimated quantity [142; 61, p. 9].
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

after adjustment. Analytical adjustments are based on the EPA Fact Sheet, Using Qualified Data to 

Document an Observed Release and Observed Contamination [140]. 

Sample ID: SS-04C

Area Letter: A

Reference for Benchmark: 4, p. A-84

Table 77 – Hazardous Substance Benchmark Concentrations in SS-04C

Hazardous 

Substance

Hazardous Substance 

Concentration 

[See Table 93]

Benchmark 

Concentration Benchmark

Chromium

871 J

(675) mg/Kg 230 mg/Kg Reference Dose

mg/Kg = Milligrams per kilogram.

J = The associated numerical value is an estimated quantity [142; 61, p. 9].

( ) = For hazardous substance concentrations, denotes concentration of the compound or element 

after adjustment. Analytical adjustments are based on the EPA Fact Sheet, Using Qualified Data to 

Document an Observed Release and Observed Contamination [140]. 

Sample ID: SS-06A

Area Letter: A

Reference for Benchmark: 4, pp. A-34, A-84, A-236

Table 78 – Hazardous Substance Benchmark Concentrations in SS-06A

Hazardous 

Substance

Hazardous Substance 

Concentration 

[See Table 93]

Benchmark 

Concentration Benchmark

Barium 67.8 mg/Kg 5,500 mg/Kg Reference Dose

Chromium 337 mg/Kg 230 mg/Kg Reference Dose

Mercury 7.2 mg/Kg 23 mg/Kg Reference Dose

mg/Kg = Milligrams per kilogram.
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

Sample ID: SS-07A

Area Letter: A

Reference for Benchmark: 4, pp. A-30, A-84, A-236

Table 79 – Hazardous Substance Benchmark Concentrations in SS-07A

Hazardous 

Substance

Hazardous Substance 

Concentration 

[See Table 93]

Benchmark 

Concentration Benchmark

Arsenic 50 mg/Kg 23 mg/Kg Reference Dose

Chromium 623 mg/Kg 230 mg/Kg Reference Dose

Mercury 0.7 mg/Kg 23 mg/Kg Reference Dose

mg/Kg = Milligrams per kilogram.

Sample ID: SS-07A

Area Letter: A

Reference for Benchmark: 4, pp. A-30, A-184, A-186

Table 80 – Hazardous Substance Benchmark Concentrations in SS-07A

Hazardous 

Substance

Hazardous Substance 

Concentration 

[See Table 93]

Benchmark 

Concentration Benchmark

1,2,3,4,6,7,8-HpCDD 885 ng/Kg 4,300 ng/Kg Cancer Risk

1,2,3,4,6,7,8-HpCDF 96.2 ng/Kg 4,300 ng/Kg Cancer Risk

Arsenic 50 mg/Kg 0.43 mg/Kg Cancer Risk

HpCDD= Heptachlorodibenzodioxin. HpCDF= Heptachlorodibenzofuran.

mg/Kg = Milligrams per kilogram. ng/Kg = Nanograms per kilogram.

5.1.3.1 Resident Individual

The concentrations of hazardous substances detected in the five shallow surface soil samples which were 

collected from within 200 feet of the on-site condominium buildings are used to document Level I 

Residential Population Targets [1, p. 51647 (Section 5.1.3); 4, pp. A-30, A-34; 163]. At least one resident 

individual is subject to Level I concentrations; therefore, a Resident Individual Factor Value of 50 is 

assigned [1, p. 51647 (Section 5.1.3.1)].

Area Letter: A

Level of Contamination (Level I/Level II): Level I

Reference: 4, pp. A-30, A-84; 163

Resident Individual Factor Value: 50
Soil Exposure

Area A - Resident Population Threat

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MAD001031574 September 2012

5.1.3.2 Resident Population

The population of the on-site residences (condominium buildings) was determined by conducting an 

interview with the condominium representative [163].

5.1.3.2.1 Level I Concentrations

There are 52 resident individuals located within 200 feet of the area of observed contamination (Area A) 

that are subject to Level I concentrations of chromium and arsenic (see Contaminated Samples section 

above) [4, pp. A-30, A-84; 163].

Level I Resident Population Targets

The population of the on-site residence was determined by conducting an interview the condominium 

representative [163]. The condominium representative stated the following occupancy rates for each of 

the four condominium buildings: Building A contains 10 residents; Building B contains 12 residents; 

Building C contains 12 residents; and Building D contains 18 residents [163]. Based on GPS coordinates 

of shallow surface soil samples presented to document Level I residential population targets, shallow 

surface soil samples SS-03A, SS-04A and SS-04C are located within 200 feet of condominium Buildings 

B, C, and D; and surface soil samples SS-06A and SS-07A are located within 200 feet of condominium 

Buildings A, B, and C [163]. Therefore, all four residential condominium buildings are within 200 feet of 

a Level I soil exposure sample [163].

Table 81 – Level I Concentration Factor

Area 

Letter Sample ID

Number of 

Residences

County 

Multiplier

Total No. of 

Residents References

A SS-03A 3 NA 42 12, pp. 6-8; 163

A SS-04A 3 NA 42 12, p. 13; 163

A SS-04C 3 NA 42 12 pp. 13-14; 163

A SS-06A 3 NA 34 12, pp. 7-8; 163

A SS-07A 3 NA 34 12, pp. 7-8; 163

NA = Not Applicable.

Sum of individuals subject to Level I concentrations: 52

Sum of individuals subject to Level I concentrations x 10: 520

Level I Concentrations Factor Value: 520
Soil Exposure

Area A - Resident Population Threat

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5.1.3.2.2 Level II Concentrations

Level II Samples

Fifteen samples document Level II hazardous substance concentrations. Dioxin/furan congeners are 

compared against Cancer Risk Screening Concentrations, while the three total metals are compared 

against Reference Dose and/or Cancer Risk Screening Concentrations (see Tables 74 to 79 above) [4, pp. 

A-30, A-34, A-84, A-184, A-186, A-202, A-204, A-212, A-236, A-332]. 

Table 82 - Level II Samples and Hazardous Substance

Sample ID Hazardous Substance

SS-02A

1,2,3,6,7,8-HxCDD, 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and 

mercury

SS-03A

1,2,3,6,7,8-HxCDD, 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and 

mercury

SS-04A

1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,4,6,7,8-HpCDD, 2,3,7,8-TCDF, 

1,2,3,4,6,7,8-HpCDF

SS-05A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, chromium, and mercury

SS-06A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and mercury

SS-08A 1,2,3,6,7,8-HxCDD, 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, chromium, and mercury

SS-09A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, and mercury

SS-10A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and mercury

SS-11A 1,2,3,4,6,7,8-HpCDF, chromium, and mercury

SS-18A 1,2,3,4,6,7,8-HpCDD, chromium, and mercury

SS-20A

1,2,3,6,7,8-HxCDD, 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and 

mercury

SS-20C Chromium

SS-21A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, chromium, and mercury

SS-22A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, barium, and chromium

SS-33A 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, and chromium

HxCDD= Hexachlorodibenzodioxin. HpCDD= Heptachlorodibenzodioxin.

TCDF = Tetrachlorodibenzofuran. HxCDF= Hexachlorodibenzofuran.

HpCDF= Heptachlorodibenzofuran.

Level II Resident Population Targets

Based on information provided by the condominium representative, 52 individuals reside within the 

buildings located less than 200 feet from the area of observed contamination (Area A) (see Contaminated 

Samples section above) [163]. The 52 residents have been scored as Level I Target Populations (see 

above) and are not evaluated further. 
Soil Exposure

Area A - Resident Population Threat

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Table 83 – Level II Concentration Factor

Area 

Letter Sample ID

Number of 

Residences

County 

Multiplier

Total No. of 

Residents References

NS

NS = Not Scored. 

Sum of individuals subject to Level II concentrations: 0

Level II Concentrations Factor Value: 0

5.1.3.3 Workers

No known regular worker population has been identified in the available file information reviewed for the 

area of observed contamination. However, contracted landscapers are suspected to work on the area of 

observed contamination. Due to a lack of information pertaining to workers regularly working on the area 

of observed contamination and the occasional/transient nature of landscaping work, no regular worker 

population could be documented. Since a regular worker population has not been identified, the Resource 

Factor Value was not evaluated.

Table 84 – Workers

Area Letter Number of Workers References

NS

NS = Not Scored. 

Total Workers: 0

Workers Factor Value [1, p. 51647 (Table 5-4)]: 0
Soil Exposure

Area A - Resources

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5.1.3.4 Resources

No known resources were documented to be impacted in the available file information reviewed for the 

area of observed contamination and therefore the Resource Factor Value is not evaluated.

Description of Resource(s): 

Resources Factor Value [1, p. 51647 (Section 5.1.3.5)]: 0
Soil Exposure

Area A – Terrestrial Sensitive Environments

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5.1.3.5 Terrestrial Sensitive Environments

No known terrestrial sensitive environments were documented in the available file information reviewed 

for the area of observed contamination and therefore the Terrestrial Sensitive Environments Factor Value 

is not evaluated.

Table 85 - Terrestrial Sensitive Environments

Area Letter Terrestrial Sensitive 

Environments

Assigned Value

[1, Table 5-5]

References

NS

NS = Not Scored. 

Terrestrial Sensitive Environments Factor Value: Not Scored
Soil Exposure 

Nearby Population Threat

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5.2 NEARBY POPULATION THREAT

The nearby population threat for the area of observed contamination (Area A) is not evaluated as part of 

this documentation record.