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STATE OF MAINE
September 24, 2004 Ann Thayer
RE: Solid Waste Facility Inspection - 08/31/04 Dear Ms. Thayer: On August 31, 2004, Richard Heath, Project Geologist, and I met with you regarding the waste clinker and CKD storage areas at the Dragon Products Company (Dragon) facility in Thomaston. Following that meeting, an inspection of the storage areas was conducted. You accompanied us during this inspection. Below, are some of the items discussed during our meeting: 1. It is still Dragon's plan to use CKD from the storage pile and reintroduce it back into the new dry process. Dragon began this trial in June 2004 and plans to use approximately 5,000 tons of CKD during the trial. At the end of this trial period, Dragon will assess the feasibility of reusing CKD in the dry process. 2. Likewise, it is still Dragon's intention to mine waste clinker and reintroduce it back into the dry process. At this time, Dragon does not know when this trial will take place. Once it does begin, Dragon plans to use approximately 10,000 tons of waste clinker during the trial. At the end of this trial period, Dragon will assess the feasibility of reusing waste clinker in the dry process. If it is found that the material is not suitable for the dry process, we discussed the need for closure of the waste clinker area. 3. Both Richard Heath and I expressed concern about the fate of leachate and wastewater now that Dragon has switched to the dry process. When Dragon was using the wet process, it was Dragon's contention that all leachate and wastewater were being re-circulated for process water. That amounted to approximately 225 gallons/minute, of which approximately 70-80 gallons were leachate. You were unsure how many gallons/minute were being used at this time but you informed us that you believed that you required more process water than is currently generated as leachate and wastewater. You also asserted that Dragon is using a basin for extra storage capacity if needed, but that you are still pumping at the same rate from Quarry ---------------------------------------- Page 2 #4 that you were prior to switching to the dry process. You were going to check into it and let me know the rate at which you are using water now. 4. While we were discussing my letter dated June 23, 2004, regarding the groundwater issues at the site, you concurred that the CKD storage pile was the cause of the upward trends observed in monitoring well B2. You also agreed to begin Assessment Monitoring at this well and possibly other B-series wells with the October sampling. The list of parameters to be included will be based on knowledge of process and the Department may reduce the number of parameters based on recommendations from Richard Heath. You agreed to contact Richard and discuss this prior to the October sampling event. 5. Additionally, you and Richard Heath discussed the need for a background monitoring well since there currently is not one in your monitoring program. Maps were consulted and a site was agreed upon. Dragon must install this background well as soon as possible and prior to the April 2005 sampling event. 6. You expressed some concern about submitting your monitoring data in the EDD format. You agreed that Dragon would do this if it does not cost a great deal of money. Please be aware that the Department plans to require this format in the near future. If you are concerned about the legality of the Department requiring data in this format, please contact Richard Heath directly and he will furnish you with all pertinent information. During our inspection of the facility, it did not appear that fugitive dust was a problem at the CKD storage area. It has not been a dry summer and this likely aids in the control of fuaitive dust. During our inspection, use of a "spray-on" intermediate cover was discussed for use on the CKD pile. Dragon intends to investigate this option if Assessment Monitoring data reveals the need for Corrective Action. Additionally, no leachate was observed leaving the established leachate collection basins. I have attached inspection photographs to this letter. If you have any questions please call me at (207) 287-8491, write to me at the Augusta mailing address, or you may e-mail me at carla.j.hopkinsCmaine.gov. Sincerely Carla J. Hopkins Bureau of Remediation and Waste Management Division of Solid Waste Management Encl: Inspection Photos - 08/31/04 Pc: Richard Heath. MDEP Project Geologist Page 2 of 2 END ------------------------------------ |