PB95-963716
EPA/ROD/R01-95/116
March 1996
EPA Superfund
Record of Decision:
Raymark Industries, Inc.,
Operable Unit 1, CT
7/3/1995
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EPA-NEW ENGLAND
RECORD OF DECISION
RAYMARK INDUSTRIES, INC. SUPERFUND SITE
STRATFORD, CONNECTICUT
REMEDIAL ACTION FOR SOURCE CONTROL
RAYMARK INDUSTRIES, INC. FACILITY
OPERABLE UNIT #1
JUNE 1995
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RECORD OF DECISION
RAYMARK INDUSTRIES, INC. FACILITY
STRATFORD, CONNECTICUT
TABLE OF CONTENTS
Contents Page Number
DECLARATION FOR THE RECORD OF DECISION iv
I. SITE NAME, LOCATION, AND DESCRIPTION 1
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 3
A. Land Use and Response History 3
B. Enforcement History 4
III. COMMUNITY PARTICIPATION 6
IV. SCOPE AND ROLE OF THE OPERABLE UNIT 7
V. SUMMARY OF SITE CHARACTERISTICS 9
VI. SUMMARY OF SITE RISKS . . . 12
VII. DEVELOPMENT AND SCREENING OF ALTERNATIVES 17
A. Statutory Requirements/Response objectives . . 17
B. Technology and Alternative Development and
Screening 17
VIII. DESCRIPTION OF SOURCE CONTROL ALTERNATIVES 19
IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES . . 23
X. THE SELECTED SOURCE CONTROL REMEDY 32
A. Description of Remedial Components 32
XI. STATUTORY DETERMINATIONS 37
A. The Selected Remedy is Protective of Human
Health and the Environment 37
B. The Selected Remedy Attains ARARs 37
C. The Selected Remedy, is Cost-Effective 39
D. The Selected Remedy Utilizes Permanent
Solutions and Alternative Treatment
or Resource Recovery Technologies to the
Maximum Extent Practicable 40
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E. The Selected Remedy Does Not Fully Satisfy the
Preference for Treatment as a Principal
Element . 41
XII. DOCUMENTATION OF SIGNIFICANT CHANGES . . . 42
XIII. STATE ROLE . 43
FIGURES
TABLES
APPENDIX A (RESPONSIVENESS SUMMARY)
APPENDIX B (STATE OF CONNECTICUT CONCURRENCE LETTER)
111
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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Raymark Industries, Inc. Superfund Site
75 East Main Street
Stratford, Connecticut
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
source control (operable unit #1) for the Raymark Industries, Inc.
Superfund Site (the "Site"), in Stratford, Connecticut. This decision
document was developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA), as amended by the Superfund Amendments and Reauthorization
Act of 1986 (SARA) and with the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP).
The remedy selected in this document will address the following
principal threats to human health and the environment posed by the
Site: (1) direct exposures to the contaminated soil-waste materials,
(2) leaching of contaminants to groundwater from on-site source area-s,
and (3) inhalation exposures to airborne asbestos and/or volatilized
organic compounds.
This decision is based upon the contents of the Administrative Record
for this Site. A copy of the Administrative Record is available at
the Stratford Public Library, located at 2203 Main Street in
Stratford, Connecticut and at the United States Environmental
Protection Agency (EPA), Waste Management Division, Records Center,
located at 90 Canal Street in Boston, MA.
The Connecticut Department of Environmental Protection (CT DEP)
concurs with the first operable unit remedial action for source
control at this Site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substance from this Site,
if not addressed by implementing the response action selected in this
Record of Decision (ROD), may present a current or potential threat to
human health and the environment.
DESCRIPTION OF SELECTED REMEDY
The selected remedy is the first operable unit for the Site. The
selected remedy addresses the source(s) of contamination at Raymark
Industries, Inc. Site by eliminating or reducing the risks posed by
the Site, as set forth above.
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The major components of EPA's selected source control remedial action
include:
Decontamination and demolition of all Raymark Facility
buildings and structures.
Backfilling low-lying areas within the Raymark Facility with
demolition materials and/or with those materials placed on
the Raymark Facility from the residential and Wooster Junior
High School excavations.
Compacting those materials noted above and grading the
Raymark Facility to provide the appropriate slopes for the
base of the cap.
Removal of highly concentrated pockets of liquid (solvent)
contamination from contact with groundwater from known areas
of the Raymark Facility.
Covering the entire Raymark Facility with an multi-layered,
impermeable cap (barrier).
Ensuring the long-term integrity of the cap through an
adeguate operation and maintenance program and institutional
controls (deed restrictions).
Conducting routine monitoring of groundwater and surface
water, and air monitoring, at the facility.
Five year reviews of this source control operable unit are
also included as part of this selected remedy.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment,
complies with Federal and State requirements that are legally
applicable or relevant and appropriate to this source control remedial
action, and is cost-effective. This source control remedial action
utilizes permanent solutions and'alternative treatment or resource
recovery technologies to the maximum extent practicable for this Site.
However, because treatment of the principal threats at the Site was
not found to be practicable, the selected remedy does not fully
satisfy the statutory preference for remedies that employ treatment
that reduce the toxicity, mobility, or volume as a principal element.
The selected remedy will reduce mobility of contaminants through its
containment and non-aqueous phase liquid removal features. Because
this remedy will result in hazardous substances remaining at the Site,
the source control remedial action .will be reviewed to the extent
required by law to ensure that it continues to provide adequate
protection of human health and the environment.
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FUTURE RESPONSE ACTIONS
In addition, EPA is currently undertaking investigations within Ferry
Creek, the Housatonic River and several ecological areas within the
Town of Stratford where Raymark contamination has come to be located.
These investigations will allow EPA, in consultation with the CT DEP,
to identify and evaluate potential cleanup options for these
ecologically-sensitive areas. Currently, a second operable unit ROD
is anticipated to be prepared which will address the selected remedy
for these areas of the Site.
Finally, additional groundwater studies will be required to further
evaluate the extent of the groundwater contamination on and migrating
from the Raymark Facility. The purpose of these studies will be to
determine whether this groundwater contamination is impacting or may
in the future impact any human and/or environmental receptors. This
information, in conjunction with the results of the groundwater
monitoring required for the source control remedial action, will be
used to identify and evaluate potential groundwater remedial
alternatives for the Site. EPA, in consultation with CT DEP,
anticipate that a third operable unit ROD for the Site will be
prepared which will address, and will represent the final response
action for the Site.
The following represents the selection of a remedial action for source
control (operable unit #1) by the United States Environmental
Protection Agency, Region I, with concurrence of the Connecticut
Department of Environmental Protection, for the Raymark Industries,
Inc. Superfund Site.
/// < ' ' '
By: SL li * < / t t.js, Date: 'j <&,- . '
- s ,/
Linda M. Murphy, Director
Waste Management Division
VI
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RECORD OF DECISION
REMEDIAL ACTION FOR SOURCE CONTROL
RAYMARK INDUSTRIES, INC. FACILITY
OPERABLE UNIT #1
I. SITE NAME, LOCATION, AND DESCRIPTION
The Raymark Industries, Inc. Facility is located at 75 East Main
Street in Stratford, Fairfield County, Connecticut at latitude
41° 12'02.5"N, longitude 73° 07'14.0"W. The Facility is located
approximately 1,200 feet west of the Housatonic River, outside the
100- and 500-year floodplains.
The Raymark Facility contains no wetland areas or areas of ecological
concern; however, current Facility storm water and drainage ultimately
discharges into Ferry Creek and eventually into the Housatonic River.
Groundwater in and around the Raymark Facility is classified "GB" by
the State of Connecticut which means that the designated uses are for
industrial process water and cooling waters and presumed not suitable
for direct human consumption without treatment. Based on a survey
conducted by the CT DEP, there are no public wells and only one
private water supply well located within 1-mile, upgradient of the
Raymark Facility. Figures 1-1 and 1-2, attached hereto, depict the
location of the Raymark Industries, Inc. Facility and its environs.
The Raymark Industries, Inc. Facility property consists of 33.4 acres
of land upon which approximately 15 acres of primarily, inactive
office and manufacturing buildings/structures exist, with much of the
remainder of the Facility consisting of paved parking areas (see
Figure 1-3 attached hereto). Two (2) of the buildings/structures on
the property are currently occupied; one by Raymark Industries, Inc.,
and the other by the Connecticut Carting & Salvage Co. The property
is zoned as commercial/light industrial, and is identified as Property
#48.1400 on Tax Map F-2 within the Town of Stratford. The properties
abutting the Raymark Facility are a mix of residential, commercial,
industrial, and road and railroad rights-of-way. The Raymark Facility
is bordered on the northwest by railroad tracks, a commercial metal
plating company (a RCRA1-regulated facility) , as well as the former
Raybestos Memorial baseball field (a removal action under CERCLA2 was
conducted in 1993 at this location). The southern end of the property
1 RCRA means the Solid Waste Disposal Act, as amended by the
Resource Conservation and Recovery Act of 1976, as amended, 42
U.S.C, section 6901 et seq..
2 CERCLA mean's the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986.
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is bordered by Longbrook Avenue and a small commercial lot with
several small retail stores. Barnum Avenue and Interstate 95 lie to
the southeast; and on the northeastern end of the property is East
Main Street (Connecticut Highway 110), with residential homes, a
gasoline station, and another commercial lot with many retail stores.
In addition, two other facilities (subject to RCRA regulations) are
located within a quarter-mile of the Raymark Facility.
A more complete description of the Site can be found in the Remedial
Investigation (RI) Report and Feasibility Study (FS) Report which are
dated April 1995. These documents are part of the Administrative
Record which is available at the EPA, Waste Management Division,
Records Center, 90 Canal Street, Boston, MA, and the Stratford Public
Library, 2203 Main Street, Stratford, CT.
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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Land Use and Response History
Raymark Industries, Inc., was formerly named the Raybestos-
Manhattan Company. The Raymark Industries, Inc. Facility
manufactured automotive and heavy vehicle friction parts as well
as adhesives and resins from approximately 1919 until September
1989 when operations ceased. The friction materials contained
asbestos and non-asbestos materials, metals, and phenol-
formaldehyde resins. The primary products were gasket material,
sheet packing and friction materials including clutch facings,
auto transmission plates, disc brakes, drum brakes, and brake
linings. As a result of these activities, the Raymark .Facility
has become contaminated with asbestos, lead, copper,
polychlorinated biphenyls (PCBs) , volatile and semivolatile
organic compounds, and other contaminants.
During the Raymark Facility's 70 years of operation, it was
common practice for the company to dispose of manufacturing waste
in several lagoons located on their 33.4-acre East Main Street-
property. As their property was filled and developed upon with
additional buildings and paved parking areas, new lagoons were
built in other areas of the property. Periodically,
manufacturing waste from these lagoons was also dredged and used
as "fill" throughout the Town of Stratford. In addition, "off-
specification" material was taken directly from the Raymark
manufacturing processes and also disposed of as "fill" in
locations off the Raymark property. The four (4) existing
lagoons on the Facility are located in the southern and
southwestern parts along Barhum and Longbrook Avenues. These
lagoons have been drained and temporarily covered with gravel and
topsoil by Raymark in accordance with an administrative order
issued by EPA under CERCLA.
A number of spills have also occurred on the Raymark Facility
over the many years of operation. One of the largest spills was
the release of an unknown quantity of toluene that leaked from a
10,000 gallon underground tank in 1984. The Connecticut
Department of Environmental Protection (CT DEP) ordered Raymark
to remove the tank and excavate the contaminated soil. Also in
1984, approximately 6,000 gallons of 1,1,1-trichloroethane
(1,1,1-TCA) spilled from an aboveground tank.
Spent acids were also disposed of at three (3) unlined acid
neutralization pits located in the southwestern part of the
Raymark Facility. In the mid-1970's, an acid treatment plant was
constructed, in the central portion of the Facility, to
neutralize the spent acids generated and eliminate the need for
the acid neutralization -pits.
EPA is currently conducting response actions at a number of
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locations off the Raymark property where Raymark's manufacturing
waste has come to be located. Approximately 40 of these
locations are residential properties which are being addressed by
EPA through time-critical3 removal actions (excavations) to
abate the public health threat that may exist. The excavated
material from these residential properties is currently being
placed at the Raymark Facility. Additionally, "fill" from the
Raymark Facility was also disposed of at several commercial and
municipal properties, as well as in and along Ferry Creek and
other wetlands areas within Stratford. Several of these
properties are currently under investigation by EPA. One
municipal property, the Woos-ter Junior High School, will be
excavated by the CT DEP and the contaminated materials
transported back to the Raymark Facility during the summer of
19.95.
A more detailed description of the Site history can be found in
subsection 1.3 of the Remedial Investigation (RI) Report, dated
April 1995.
B. Enforcement History
Raymark was subject to many environmental enforcement actions
throughout the 1980s for violations of RCRA, and the National
Emissions Standards for Hazardous Air Pollutants (NESHAPs) under
the Clean Air Act (42 U.S.C. 7401 et seq.).
In July 1991, the Department of Justice (DOJ) filed a complaint
in the U.S. District Court of Connecticut for numerous violations
of RCRA including failure to perform an environmental study (RCRA
Facility Investigation or RFI) under Section 3013 of RCRA.
Raymark conducted the environmental investigation and submitted
the RFI Report to EPA on February 15, 1995.
In September 1992, EPA issued Raymark a Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA)
Section 106 Removal Order to abate threats posed by hazardous
substances and conditions at the Site in accordance with the
National Contingency Plan (NCP, 40 CFR Part 300). Pursuant to
the Removal Order, Raymark mitigated the imminent threats at the
Site by; (l) cleaning, removing and abandoning approximately 70
aboveground and underground storage tanks, and removing thousands
of 1 cubic yard bags of asbestos-contaminated materials; (2)
covering the surface of the four currently remaining waste
lagoons; (3) re-routing surface water drainage around Lagoon #4;
(4) placing the toluene-contaminated soil pile in Lagoon #1 and
covering the soil; and (5) enclosing the Facility with fencing,
3 "Time Critical" removal actions are implemented where EPA
determines that there is an urgent need for rapid response in
order to protect the public health, welfare and the environment.
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boarding up the buildings, and installing an electric gate.
In May 1993, the Agency for Toxic Substances and Disease Registry
(ATSDR) issued a Public Health Advisory for hazards associated
with past, present and potential future exposures to waste from
past operations and disposal practices of Raymark Industries,
Inc. As a result of Raymark's past disposal practices at
locations off the Raymark property, EPA has conducted time-
critical removal actions at one commercial property Raybestos
Memorial Field and, by July 1995, EPA will have excavated Raymark
waste from approximately forty (40) residential properties and
transported this material back to the Raymark Facility.
The CT DEP has worked with numerous commercial property owners to
abate imminent threats posed by the presence of Raymark waste on
their properties. These activities have included covering the
Raymark waste with various types of materials and/or installing.
fences and warning signs. The two (2) largest municipal
properties where Raymark waste has come to be located at levels
of concern are Short Beach Park and an athletic field at the
Wooster Junior High School. At these municipal properties, the
CT DEP temporarily covered the Raymark waste with soil and
geofabric to abate the imminent threat. The CT DEP is currently
implementing a permanent response action at the Wooster Junior
High School by excavating the Raymark waste and transporting it
back to the Raymark Facility.
On April 3, 1995, EPA notified two (2) parties, Raymark
Industries, Inc. and Raytech Corporation of their potential
liability with respect to the Site.
Raymark Industries, Inc. has not been directly active in the
remedy selection process. However, Raymark has completed the
RCRA Facility Investigation (RFI) Report that EPA considered in
evaluating the nature and extent of contamination associated with
the Site. Raymark has also submitted technical comments during
the recent public comment period regarding EPA's Proposed Plan
for the Site. Those technical comments made by Raymark
Industries, Inc. are included in the Administrative Record and
are addressed in the Responsiveness Summary attached as Appendix
A of this ROD.
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III. COMMUNITY PARTICIPATION
Since the 1980's, community concern and involvement with the Site has
been very high. Throughout this time period, EPA has kept the
community and other interested parties apprised of the Site activities
through neighborhood forums, informational meetings, fact sheets,
press releases and public meetings.
During February 1995, EPA released a community relations plan which
outlined a program to address community concerns and keep citizens
informed about and involved in activities during all removal and
remedial activities at the Site.
EPA published a notice and brief analysis of the Proposed Plan for
source control remedial action in the Stratford Bard on April 1, 1995,
the Connecticut Post on April 4, 1995, and the Stratford Star on April
5, 1995. The Proposed Plan was also made available to the public
through mailings to the over 1,200 individuals on EPA's Raymark
Facility Site mailing list as of April 3, 1995. On April 8, 1995, EPAj
made the Administrative Record available for public review at EPA's
offices in Boston and at the Stratford Public Library.
On April 8 and April 11, 1995, EPA held open houses/informational
meetings to discuss the results in the RI report, the cleanup
alternatives presented in the FS report, and to present the Agency's
Proposed Plan. Also during this meeting, the Agency answered
questions from the public. From April 8, 1995 to June 8, 1995 the
Agency held a sixty day (60) public comment period to accept public
comments on the cleanup alternatives presented in the FS report and
the Proposed Plan, and on any other documents previously released to
the public. On May 4, 1995, the Agency held a Public Hearing to
accept any oral comments on the Proposed Plan. A transcript of this
hearing and the Agency's response to comments made during the public
comment period are included in the attached Responsiveness Summary at
Appendix A.
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IV. SCOPE AND ROLE OF THE OPERABLE UNIT
As with many Superfund sites, the problems at the Raymark Industries,
Inc. Site are complex. As a result, the EPA has decided to phase the
activities for the Site into several response actions, termed
"operable units."
The selected remedy described in this ROD is the first operable unit
which will address the source(s) of contamination at the Site. The
NCP, at 40 CFR Part 300.5, defines a source control action as "the
construction or installation and start-up of those actions necessary
to prevent the continued release of hazardous substances or pollutants
or contaminants ... into the environment.."
In summary, key components of EPA's selected source control remedial
action include: 1) decontamination and demolition of all Raymark
Facility buildings and structures, 2) removal of highly concentrated
pockets of liquid (solvent) contamination from contact with
groundwater, 3) covering the entire Raymark Facility with an multi-
layered, impermeable cap (barrier), 4) ensuring the long-term
integrity of the cap through an adequate operation and maintenance
program and institutional controls (deed restrictions), and 5)
conducting routine monitoring of groundwater and surface water, and
air monitoring, at the Facility. Five year reviews of this source
control operable unit are also included as part of this selected
remedy, as required by CERCLA.
This source control remedial action will address the following
principal threats to human health and the environment posed by the
Site: (1) direct exposures (incidental ingestion and dermal contact)
to the contaminated soil-waste materials, (2) leaching of contaminants
to groundwater from on-site source areas (i.e., soils and non-aqueous
phase liquids-NAPLs), and (3) inhalation exposures to airborne
asbestos and/or volatilized organic compounds.
EPA is also currently undertaking investigations within Ferry Creek,
the Housatonic River and several ecological areas within the Town of
Stratford .where Raymark contamination has come to be located. These
investigations will allow EPA to identify and evaluate potential
cleanup options for these ecologically-sensitive areas. These
potential cleanup options would be presented to the public in the form
of a Proposed Plan for public comment. Currently, a second operable
unit ROD is anticipated to be prepared between April 1 - June 30, 1996
which will address the selected remedy for these ecologically-
sensitive areas of the Site.
Finally, additional studies will be required to further evaluate the
extent of the groundwater contamination on and migrating from the
Raymark Facility, and determine whether this, groundwater contamination
is impacting or may in the future impact any human and/or
environmental receptors. These additional groundwater studies will
also be used to evaluate the effectiveness of the selected source
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control remedial action described in this ROD. All of this
information will allow the EPA to better identify potential
groundwater cleanup options in the future for the Raymark Facility.
These groundwater cleanup options will also be presented to the public
for comment in the form of a Proposed Plan. The selected groundwater
cleanup remedy will be addressed in the third operable unit ROD for
the Site, which is planned for approximately October 1 - December 31,
1998 and will represent the final response action for the Site.
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V. SUMMARY OF SITE CHARACTERISTICS
Section 1.0 of the Feasibility Study (FS) report contains an overview
of the Remedial Investigation (RI) findings. The significant findings
of the RI are summarized below:
Environmental Investigations
Field investigations were conducted at the Raymark Facility to
characterize the on-site materials and Facility setting. The
investigations were conducted .mainly by Raymark7s contractor
Environmental Laboratories, Inc. (ELI) and were supplemented by EPA
investigations. The investigations focused on characterizing the
geology and hydrogeology of the Site; sampling and analyzing air, .
surface water, sediment, soil, and groundwater; and evaluating
potential continuing sources of contamination such as the buildings,
waste piles, lagoons, spill areas, drainage systems, acid
neutralization pits, and tanks.
Physical Characteristics
Numerous lagoons, located throughout the Facility were used for many
years to settle the solids from the wastewater generated in the
manufacturing operations. The settled material in the lagoons was
used as fill on the Raymark property and periodically dredged and used
as fill material off the property. As the Facility was filled and
developed, old lagoons were filled in and new ones were built in other
areas of the Facility. The buildings at the Facility currently occupy
approximately 45% of the Raymark property. Most of these buildings
were constructed on areas that have been filled, primarily with waste
from past manufacturing operations. A number of solvent spills and
the dumping of acids and solvents occurred on the Facility over the
many years of operation.
Soil and Other Waste Materials
The on-site "process fill" layer, composed primarily of soil-waste
materials that originated from the lagoons, is present under nearly
all of the Raymark Facility, except the northeastern area. Numerous
contaminants, including volatile and semi-volatile organic compounds,
herbicides and pesticides, polychlorinated biphenyls (PCBs), dioxins
and furans, metals, cyanide, and asbestos, have been identified in the
"process fill" layer which ranges in thickness up to 24 feet. 'A total
of approximately 480,000 cubic yards of fill is present on-site and,
of that total, roughly 150,000 cubic yards is located below the water
table.
With respect to contaminant distribution, the fill materials and
underlying natural soils throughout the Facility are heterogeneous.
This is likely the result of the irregular disposal/placement of the
wastewater sludges, and leaks and spills of chemicals in several areas
at the Facility. Table 1-1, attached to this ROD, lists the maximum
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concentration of contaminants detected in the soils at the Facility.
While both organic and inorganic contaminants were detected in the
fill and soil throughout the Facility, several areas within the
property have been identified as containing higher contaminant
concentrations than found in other areas of the Site. These areas all
appear to be present in the vicinity of past solvent disposal and
spill areas. The following areas were identified: the three former
acid neutralization pits located in the southwestern portion of the
Facility; the general area of a spill of 1,1,1-trichloroethane (l,l,l-
TCA) from a tank located in the central portion of the Facility; and
the toluene spill in the northern portion of the Facility.
Overall, these more highly contaminated areas combined with the past
disposal/landfilling of wastewater sludges within the lagoons
throughout the property results in a heterogeneous mixture of
contaminants that are found throughout the entire 33.4 acres of the
Raymark property.
Groundwater
Groundwater underlying the Facility is contaminated by a variety of
organic and inorganic constituents. In particular, groundwater under
the known solvent disposal/spill areas and at locations downgradient
of these areas appears to be more contaminated than groundwater at
other locations within the Facility. All contaminants detected in the
groundwater have also been detected in the fill materials or in
contaminated natural soils. Since the scope of the Raymark RFI was
limited to investigating within the Facility boundaries, no monitoring
wells off the Raymark property were installed as part of the RFI
studies. Therefore, the available data cannot be used, at* this time,
to fully assess the extent of the groundwater contamination present
upgradient and downgradient of the Raymark Facility. However,
contaminants appear to be migrating between the fill/soil and
groundwater throughout the Facility.
A non-aqueous phase liquid (NAPL) layer is currently known to be
present in two well clusters located on the Facility. NAPL will act
as a continuing source of dissolved contaminants to groundwater at the
Facility.
Waste Excavated From Residential and Municipal Properties
As part of EPA's ongoing time-critical removal activities at
approximately 40 residential properties in Stratford, soil-waste
materials contaminated with Raymark waste are being excavated and
transported to the Raymark Facility. The soil-waste materials
excavated from these residential properties has been placed in
buildings and covered piles in the parking lot at the Site. The total
volume of soil-waste materials from the removal actions at residential
properties is expected to be approximately 40,000 cubic yards. In
addition, the soil-waste materials excavated from the Wooster Junior
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High School will be transported to the Raymark Facility. " The waste
from the Wooster Junior High School is expected to total approximately
20,000-30,000 cubic yards.
Finally, drums of investigation-derived waste (IDW) are currently
stored on- site in the former Raymark Facility drum storage area.
These IDW drums contain drilled soil cuttings and
purge/decontamination waters from the many investigations at the
Raymark Facility and ongoing investigations by EPA in Stratford where
Raymark waste has come to be located.
Surface Water and Sediments
Current Site conditions and analytical data indicate that contaminants
may still discharge from the on-site drainage system into Ferry Creek
during storm events. Sediment samples collected during the RFI
investigations indicate that various contaminants, collected in the
on-site drainage system, have been discharging from the Raymark
Facility to Ferry Creek. Diversion of the on-site drainage system,
during the CERCLA removal action at the Raymark Facility, has
minimized the migration of contamination off the property, but the
diversion was not completely effective in reducing all contaminants in
the surface water. Sediment sampling conducted in Ferry Creek under a
separate phase of this project indicates that Ferry Creek is
contaminated with Raymark's waste.
Air
No information is available regarding air monitoring conducted while
the Facility was in operation. Air monitoring performed during RCRA
Facility investigations and cleanup activities conducted between 1992
and 1994 indicates that air guality standards were not exceeded.
A more.complete discussion of Site characteristics can be found in the
Remedial Investigation Report in Sections 3.0, 4.0, and 5.-Q.
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VI. SUMMARY OF SITE RISKS
A Risk Assessment (RA) was performed to estimate the probability and
magnitude of potential adverse human health effects from exposure to
contaminants associated with the Site. Since current use of the
Raymark Industries, Inc. property is zoned commercial/light-industrial
and no substantial change in permitted uses is anticipated in the
future, these conditions at the Raymark property were determined to
provide no habitat and minimal potential for exposure for ecological
receptors. Therefore, an environmental Risk Assessment, which is -
typically conducted together with the human health Risk Assessment,
was not performed for the Raymark Industries, Inc. Facility as part of
this operable unit.
The human health Risk Assessment followed a four step process: 1)
contaminant identification, which identified those hazardous
substances which, given the specifics of the Site, were of significant
concern; 2) exposure assessment, which identified actual or potential
exposure pathways, characterized the potentially exposed populations,
and determined the extent of possible exposure; 3) toxicity
assessment, which considered the types and magnitude of adverse health
effects associated with exposure to hazardous substances, and 4) risk
characterization, which integrated the three earlier steps to
summarize the potential and actual risks posed by hazardous substances
at the Site, including carcinogenic and non-carcinogenic risks. The
results of the human health Risk Assessment for the Raymark
Industries, Inc. Facility are discussed below. Section 6.0 of the RI
report provides more thorough details regarding the Risk Assessment
performed for the Raymark Facility.
Thirty-nine contaminants of concern, listed in Table 6-3 within the RI
report, were selected for evaluation in the Risk Assessment. These
contaminants constituted a representative subset of the more than one-
hundred-forty contaminants identified at the Site during the Remedial
Investigation (RI) . The thirty-nine contaminants of concern were
selected to represent potential Site related hazards based on
toxicity, concentration, frequency of detection, and mobility and
persistence in the environment.
Potential human health effects associated with exposure to these
thirty-nine contaminants of concern were estimated quantitatively or
qualitatively through the development of several hypothetical exposure
pathways. These pathways were developed to reflect the potential for
exposure to hazardous substances based on the present uses, potential
future uses, and location of the Site. The Site is located in an
urban/industrial/residential area of Stratford, Connecticut. Although
the main process areas of the Facility are currently vacant, a few
buildings in the southwestern portion of the Site are currently used
for commercial work. The following is a brief summary of the exposure
pathways evaluated.
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EXPOSURE PATHWAYS EVALUATED
The incidental ingestion and dermal contact with contaminated surface
and subsurface soils was evaluated assuming:
a worker may contact soils 150 days per year for 25 years
trespassers, aged 7 to 18, may contact soils 40 days per
year for 12 years
a construction worker (e.g, repairing the on-site sewer
line) may have more intensive contact for a period of 5
days per week for 6 months
Additional, exposure parameters used in the Risk Assessment can be
found in Table 6-5 of the RI report.
Three exposure areas were considered in the Risk Assessment based.on
the fact that the available soil sampling data suggested that the on^
site contamination was distributed differently across the Site.
Additionally, there currently exists an easement containing an active
town sewer line which cuts through approximately the center of the
Site which 'will require periodic maintenance/repair. The three
exposure areas considered are as follows:
the southwest portion of the Site
the northeast portion of the Site
the easement area in the central portion of the Site
The utility easement area was used only in conjunction with the
construction worker exposure scenario-described above.
For each exposure pathway evaluated, an average exposure and a
reasonable maximum exposure estimate was generated corresponding to
the average and the maximum concentration detected in that particular
medium.
A qualitative discussion of risk was also presented for the potential
inhalation of vapors and dusts from Site contaminants, including
asbestos, to on-site workers and to individuals residing downwind of
the Raymark Facility.
Excess lifetime cancer risks were determined for each exposure pathway
by multiplying the exposure level with the chemical-specific cancer
potency factor. Cancer potency factors have been developed by EPA
from epidemiological or animal studies to reflect a conservative
"upper bound" of the risk posed by potentially carcinogenic compounds.
That is, the true risk is unlikely to be greater than the risk
predicted. The resulting risk estimates are expressed in scientific
notation as a probability (e.g. 1 x 10"6 for 1/1,000,000) and indicate
(using this example), that an average individual is not likely to have
greater that- a one in a million chance of developing cancer over 70
years as a result of Site-related exposure as defined by the compound
at the stated concentration. Current EPA practice considers
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carcinogenic risks to be additive when assessing exposure to a mixture
of hazardous substances.
The hazard quotient was also calculated for each pathway as EPA's
measure of the potential for non-carcinogenic health effects. A
hazard quotient is calculated by dividing the exposure level by the
reference dose (RfD) or other suitable benchmark for non-carcinogenic
health effects for an individual compound. Reference doses have been
developed by EPA to protect sensitive individuals over the course of a
lifetime and they reflect a daily exposure level that is likely to be
without an appreciable risk of an adverse health effect. RfDs are
derived from epidemiological or animal studies and incorporate
uncertainty factors to help ensure that adverse health effects will
not.occur. The hazard quotient is often expressed as a single value
(e.g. 0.3) indicating the ratio of the stated exposure as defined to
the reference dose value (in this example, the exposure as
characterized is approximately one third of an acceptable exposure
level for the given compound). The hazard quotient is only considered"
additive for compounds that have the same or similar toxic endpoint j
and the sum is referred to as the hazard index (HI). (For example:
the hazard quotient for a compound known to produce liver damage
should not be added to a second compound whose toxic endpoint is
kidney damage).
Tables 6-6a through 6-8b of the RI report depict the carcinogenic and
noncarcinogenic risks for workers and trespassers exposed to the
contaminants of concern in soils in the southwest portion of the Site
and the northeast portion; and construction workers exposed to
contaminated soils in the utility easement area. Risks were evaluated
to reflect present and potential future risks corresponding to the
average exposure and the reasonable maximum exposure scenarios.
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SOUTHWEST PORTION OF SITE
Risk estimates for exposure to carcinogenic soil contaminants in the
southwest portion of the Site are outside EPA's acceptable risk range
(10~4 to 10"6) for potential current and future exposures (average and
reasonable maximum) to on-site workers exposed over a 25 year period
and trespassers. The major contaminants contributing to the risk are
polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons
(PAHs), dioxins, arsenic, and trichloroethene. The risks are
summarized in the table below:
CARCINOGENIC RISK ESTIMATE
AVERAGE REASONABLE MAXIMUM
WORKER
TRESPASSER
3.3 X 10'3
1.9 x 1CT3
1.3 X 10'2
9.7 X 10'3
The potential for unacceptable risks via inhalation of asbestos also
exists for both workers and trespassers if the contaminated soil-waste
materials below the ground surface are disturbed. However, these
risks were not quantified for the reasons specified in the Risk
Assessment (Section 6.0 of the RI).
Hazard quotients developed for individual contaminants are below one
for soil exposures in the southwest portion of the Site for both
workers and trespassers.
NORTHEAST PORTION OF SITE
Risk estimates for exposure to carcinogenic soil contaminants in the
northeast portion of the Site are also outside EPA's acceptable risk
range for workers under the reasonable maximum exposure scenario. The
major contaminants contributing to the risk are'polychlorinated
biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAHs), dioxins and
arsenic. The risks are summarized in the table below:
CARCINOGENIC RISK ESTIMATE
AVERAGE REASONABLE MAXIMUM
WORKER
TRESPASSER
4.8 X 1CT4
3.2 X 10'5
1.4 X 10'3
1.4 X ICf4
The potential for unacceptable risks via inhalation of asbestos also
exists for both workers and trespassers if the contaminated soil-waste
materials below the ground surface are disturbed. However, these
risks were not quantified for the reasons specified in the Risk
Assessment (Section 6.0 of the RI).
Hazard quotients developed for individuals contaminant are below one
for soil exposures in the northeast portion of the Site for both
workers and trespassers.
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EASEMENT AREA
Risk estimates for construction worker exposure to carcinogenic soil
contaminants in the utility easement area are within EPA's acceptable
risk range (10~4 to 10"6) . The major contaminants contributing to the
risk are polychlorinated biphenyls(PCBs), polycyclic aromatic
hydrocarbons(PAHs), dioxins and arsenic. The risks are summarized in
the table below:
CARCINOGENIC RISK ESTIMATE
AVERAGE REASONABLE MAXIMUM
WORKER
4.4 X 10'5
7.7 x 10
-5
The Hazard quotient exceeded one for copper as summarized below. All
other Hazard quotients for individual contaminants are below one.
NONCARCINOGENIC RISK ESTIMATE
AVERAGE REASONABLE MAXIMUM
WORKER
1.8
1.8
In summary, actual or threatened releases of hazardous substances from
this Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment. Exposure
to soils via incidental ingestion and dermal contact pose a
potentially unacceptable risk to human health. In addition, the
potential for unacceptable risks via inhalation of asbestos also
exists for both workers and trespassers if the contaminated soil-waste
materials below the ground surface are disturbed.
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VII. DEVELOPMENT AMD SCREENING OF ALTERNATIVES
A. Statutory Requirements/Response Objectives
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that are
protective of human health and the environment. In addition,
Section 121 of CERCLA establishes several other statutory
requirements and preferences,.including: a requirement that EPA's
remedial action, when complete, must comply with all federal and
more stringent state environmental standards, requirements,
criteria or limitations, unless a waiver is invoked; a
requirement that EPA select a remedial action that is cost-
effective and that utilizes permanent solutions and alternative
treatment technologies or resource recovery technologies to the
maximum extent practicable; and a preference for remedies in
which treatment which permanently and significantly reduces the
volume, toxicity or mobility of the hazardous substances is a
principal element over remedies not involving such treatment.
Response alternatives were developed to be consistent with these
Congressional mandates.
Based on the information provided in the RI relating to the types
of contaminants, environmental media of concern, and potential
exposure pathways, EPA identified several source control remedial
action .objectives to aid in the development and screening of
alternatives. These source control remedial action objectives
were developed to mitigate existing and future potential threats
to public health and the environment. These source control
response objectives were: (1) prevent human exposure (incidental
ingestion and dermal contact) to the contaminated soil-waste
materials, (2) minimize leaching of contaminants to groundwater
from pn-site source areas, and (3) prevent human exposure to
contaminants in the buildings, process equipment, and subsurface
drains.
B. Technology and Alternative Development and Screening
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. In accordance with these
requirements, a range of alternatives were developed for the
Site.
The RI/FS developed a range- of alternatives in which treatment
that reduces the toxicity, mobility, or volume of the hazardous
substances is a principal element. This range included an
alternative that removes or destroys hazardous substances to the
maximum extent feasible, eliminating or minimizing to the degree
possible the need for long term management. This range also
included alternatives that treat the principal threats posed by
the Site but vary in the degree of treatment employed and the
quantities and characteristics of the treatment residuals and
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untreated waste that must be managed; alternative(s) that involve
little or no treatment but provide protection through engineering
or institutional controls; and a no action alternative.
As discussed in Section 2.0 of the Feasibility Study, the RI/FS
identified, assessed and screened technologies based on
implementability, effectiveness, and cost. These technologies
were combined into source control (SC) alternatives. Section 3.0
of the Feasibility Study presented the remedial alternatives
developed by combining the technologies identified in the
previous screening process in the categories identified in
Section 300.430(e) (3) of the NCP. The purpose of the initial
screening was to narrow the number of potential remedial actions
for further detailed analysis while preserving a range of
options. Each alternative was then evaluated and screened in
Section 3.0 of the Feasibility Study.
In summary, of the five (5) source control remedial alternatives
screened in Section 3.0 of the FS, all five (5) were retained for
detailed analysis. A description of the five (5) source control
alternatives that underwent a detailed analysis is provided in
the next section of this ROD.
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VIII. DESCRIPTION OP SOURCE CONTROL ALTERNATIVES
This Section provides a brief narrative summary of each source control
(SC) remedial alternative evaluated for the Site, as presented in the
FS and Proposed Plan.
Alternative SC-1 - No Action
The No Action Alternative was developed to serve as a baseline
case for comparison with the other remedial alternatives under
consideration, as required by the NCP. The only activities
conducted under this alternative are long-term monitoring of
grovindwater and storm water to evaluate contaminant migration,
. and a review of Site conditions and risks every five years. The
purpose of this alternative is to evaluate the overall human
health and environmental protection provided by the Site in its
present condition. Key components of Alternative SC-1 are
identified on Figure 3-1 within the FS.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 0 Years
ESTIMATED TIME FOR OPERATION: Not applicable
ESTIMATED CAPITAL COST: £0
ESTIMATED 0 fit M (Present Worth): $5.989.569
ESTIMATED TOTAL COST (Present worth): $5.989.569
Alternative SC-2 - Decontamination, Demolition, NAPL Removal,
Capping, and Institutional Controls
Alternative SC-2 is a containment option that utilizes a multi-
layered, impermeable cap to prevent potential human contact with
the on-site soil-waste contaminants and prevent further
contaminant leaching into groundwater from precipitation, thereby
significantly reducing migration. Decontamination and demolition
of all the on-site buildings and structures would be required to
facilitate capping. The subsurface drains on-site would be
plugged to prevent continued contaminant movement. Soil-waste
materials (from the Facility, from residential properties, and
the Wooster Junior High School) would be consolidated and graded
to achieve the desired slopes prior to cap placement. A vapor
control layer would be installed as part of the cap over all the
soil-waste materials to capture and channel potential gas-phase
VOCs to an off-gas treatment system. Highly concentrated-pockets
of solvent (NAPL) currently found near the former acid
neutralization pits and former toluene spill area would be
removed, to the reasonable extent practicable, and sent off-site
for recycling, treatment or disposal. Institutional controls,
e.g., deed restrictions, would be required to prevent damage or
intrusion into the cap system. Since contaminants would remain
on-site, long-term .groundwater and storm water monitoring and
five-year reviews would be required.
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The key features of Alternative SC-2 are identified on Figure 3-2
within the FS.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 1 to 4 Years
ESTIMATED TIME FOR OPERATION: 30 Years
ESTIMATED CAPITAL COST: $35.926.000
ESTIMATED 0 & M (Present Worth): $5.780.430
ESTIMATED TOTAL COST (Present worth): $41.706.430
Alternative SC-3 - Decontamination, Demolition, Limited
Excavation and Off-Site Treatment/Disposal, NAPL Removal,
Capping, and Institutional Controls
This alternative is similar to Alternative SC-2; however, it
differs in that limited excavation of highly contaminated soils
(primarily, soils in excess of 500 ppm PCBs) above the water
table would be performed in the former acid neutralization pits
area and in the area of soil boring #30 (SB-30). The area
encompassed by the former acid neutralization pits has high
concentrations of VOCs, SVOCs, PCBs, and metals in both the
saturated and unsaturated soils. The area around SB-30 primarily
has high concentrations of PCBs. The excavated soil-waste
materials found above the water table (estimated to be 21,000
cubic yards) would be sent off-site for treatment (incineration)
and disposal.
Decontamination and demolition of the buildings would be required
to facilitate capping and the limited excavation. The subsurface
drains would be plugged to prevent continued contaminant
migration. Soil-waste materials (from the Facility, residential
properties, and the Woqster Junior High School) would be
consolidated and graded to achieve desired slopes prior to
placement of a multi-layered, impermeable cap system. A vapor
control layer would be installed as part of the cap over all the
soil-waste materials to capture and channel potential gas-phase
VOCs to an off-gas treatment system. Highly concentrated pockets
of solvent (NAPL) currently found near the former acid
neutralization pits and former toluene spill area would be
removed, to the reasonable extent practicable, and sent off-site
for recycling, treatment or disposal. Institutional controls,
e.g., deed restrictions, would be required to prevent damage or
intrusion into the cap system. Since contaminants remain on-
site, long-term groundwater and storm water monitoring and five-
year reviews would be required. Key components of this
alternative are identified on Figure 3-5 within the FS.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 2 To 4 Years
ESTIMATED TIME FOR OPERATION: 30 Years
ESTIMATED CAPITAL COST: $107.768.000
ESTIMATED 0 & M (Present Worth): $5.338.650
ESTIMATED TOTAL COST (Present worth): $111.106.650
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Alternative SC-4 - Decontamination/ Demolition, Excavation/ NAPL
Removal, Off-Site Treatment/Disposal, Backfilling/ and
Institutional Controls
Alternative SC-4 features excavation and the use of off-site
incineration to treat the organic-contaminated soil-waste
materials, and solidification to treat the inorganic-contaminated
soil-waste materials. All contaminated materials present above
the water table would be excavated (totalling approximately
330,000 cubic yards) and combined with the approximately 80,000
cubic yards of residential/Wooster Junior High School
contaminated materials. The treated materials would be
ultimately landfilled off-site and the excavated areas on-site
would be backfilled with clean fill and regraded. The on-site
buildings and other structures would be decontaminated and
demolished to facilitate implementation of the excavation
component of this alternative. All subsurface drains would be
removed during excavation and the sewer line bisecting the
property would also need to be addressed. NAPL would be removed
as described under Alternative SC-2. Since contaminated soil-
waste materials would remain below the water table, deed
restrictions would still be required to limit activities that may
result in disturbance of the contaminated materials; long-term
monitoring and five-year reviews would be required. The main
components of Alternative SC-4 are identified on Figure 3-6
within the FS.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 5 To 7 Years
ESTIMATED TIME FOR OPERATION: 30 Years
ESTIMATED CAPITAL COST: $1.088.076.000
ESTIMATED 0 & M (Present Worth): $4.024.754
ESTIMATED TOTAL COST (Present worth): $1.092.100.754
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Alternative SC-5 - Decontamination/ Demolition, Excavation, NAPL
Removal, On-Site Thermal Desorption and Solidification,
Backfilling, and Institutional controls
Alternative SC-5 features excavation of all contaminated
materials present above the water table (totalling approximately
330,000 cubic yards), the use of thermal desorption for on-site
treatment of all organic-contaminated soil-waste materials from
the on-site excavation, residential properties and the Wooster
Junior High School (totalling 410,000 cubic yards), and on-site.
solidification for immobilizing the inorganics and asbestos. All
treated soils would be backfilled on-site. Materials resistant
to treatment would be landfilled off-site, organic treatment
residues would be recycled or incinerated off-site. The on-site
buildings and other structures would be decontaminated and
demolished to allow for the excavation component of this
alternative to be implemented. All subsurface drains would be
removed during excavation and the sewer line bisecting the
property would also need to be addressed. The NAPL would be
removed as noted previously in Alternative SC-2. Since
contaminants would still remain on-site, long-term monitoring and
five-year reviews would be reguired. The main components of
Alternative SC-5 are identified on Figure 3-7 within the FS.
ESTIMATED TIME FOR DESIGN AND CONSTRUCTION: 5 To 7 Years
ESTIMATED TIME FOR OPERATION: 30 Years
ESTIMATED CAPITAL COST: $326.860.000
ESTIMATED 0 & M (Present Worth): $4.041.372
ESTIMATED TOTAL COST (Present worth): $330.901.372
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IX. SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 121(b)(l) of CERCLA presents several factors that, at a
minimum, EPA is required to consider in its assessment of alternative
remedial actions. Building upon these specific statutory mandates,
the National Contingency Plan (NCP) at Section 300.430(e)(9)(iii)
articulates nine evaluation criteria to be used in assessing the
individual remedial alternatives. These nine criteria are summarized
as follows:
Threshold Criteria
The two threshold criteria described below must be met in order
for the alternatives to be eligible for selection in accordance
with the NCP. .
1. Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
pathway are eliminated, reduced or controlled through
treatment, engineering controls, or institutional
controls.
2. Compliance with applicable or relevant and appropriate
requirements (ARARS) addresses whether or not a remedy
will meet all of the ARARs of other Federal and state
environmental laws and/or provide grounds for invoking
a waiver.
Primary Balancing Criteria
The following five criteria are utilized to compare and evaluate
the elements of one alternative to another that meet the
threshold criteria.
3. Long-term effectiveness and permanence addresses the
criteria that are utilized to assess alternatives for
the long-term effectiveness and permanence they afford,
along with the degree of certainty that they will prove
successful.
4. Reduction of toxicity, mobility/ or volume through
treatment addresses the degree to which alternatives
employ recycling or treatment that reduces toxicity,
mobility, or volume, including how treatment is.used to
address the principal threats posed by the Site.
5. Short term effectiveness addresses the period of time
needed to achieve protection and any adverse impacts on
human health and the environment that may be posed
during the construction and implementation period,
until cleanup goals are achieved.
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6. Implementability addresses the technical and
administrative feasibility of a remedy, including the
availability of materials and services needed to
implement a particular option.
7. Cost includes estimated capital and Operation
Maintenance (O&M) costs, as well as present-worth
costs.
Modifying criteria
The modifying criteria are used on the final evaluation of
remedial alternatives generally after EPA has received public
comment on the RI/FS and Proposed Plan.
8. State acceptance addresses the State's position and key
concerns related to the preferred alternative and other
alternatives, and the State's comments on ARARs or the
proposed use of waivers.
9. Community acceptance addresses the public's general
response to the alternatives described in the Proposed
Plan and RI/FS report.
Following the detailed analysis of each individual remedial
alternative, a comparative analysis, focusing on the relative
performance of each alternative against the nine criteria, was
conducted. This comparative analysis is summarized in Table 4-6 of
the Feasibility Study (FS) and discussed below.
NINE CRITERIA FOR EVALUATION
The following presents the nine evaluation criteria, and a narrative
summary of the strengths and weaknesses of each alternative according
to the detailed and comparative analysis.
Overall Protection of Human Health and the Environment
Alternative SC-1 would not be protective of human health and the
environment since no risk reduction is anticipated. All other
source control alternatives evaluated are considered protective
of human health and the environment as discussed herein.
Alternatives SC-2 and SC-3 would offer significantly greater
protection than SC-1 since all the soil-waste materials would be
capped to prevent exposure, further leaching of chemicals by
precipitation would be eliminated, leaching of the highly
concentrated pockets- of solvents (NAPL) by groundwater would be
greatly reduced, and discharge of contaminants from the Facility
drainage system would be eliminated. Alternatives SC-2 and SC-3
would reduce human health risks to within the EPA's acceptable
range (less than 1 x 10"6 carcinogenic risk, and non-carcinogenic
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risks to less than a hazard quotient of 1.0). The overall
protectiveness of Alternatives SC-2 and SC-3 depends largely on
maintenance of the cap system to ensure its integrity and to
prevent potential future exposures. If the cap system is
penetrated in those on-site areas where high concentrations of
PCBs are currently present below the ground surface, Alternative
SC-3 (during cap repair) would offer added, though limited,
short-term protection than Alternative SC-2 because these high
concentration contaminants would no longer be present under
Alternative SC-3, but would remain under Alternative SC-2.
Alternative SC-2 and SC-3 both include deed restrictions which,
if implemented and enforced, will maintain the effectiveness of
the cap system over the long-term.
Alternative SC-4 would be protective of human health and the
environment since all contaminated soil-waste materials above the
water table and the residential and Wboster Junior High School
materials would be transported off-site for treatment/disposal.
Groundwater contamination would be significantly reduced by
preventing additional leaching from the contaminated materials
residing above the water table, since they would no longer be
present on the Site. No long-term maintenance actions are needed
to provide the overall protectiveness of this alternative as is
the case with Alternatives SC-2 and SC-3.
Alternative SC-5 would be protective of human health and the
environment since all soil-waste materials above the water table
and the residential and Wooster Junior High School materials
would be thermally desorbed on-site to remove organics and
solidified with cement on-site to stabilize metals and asbestos.
Under Alternative SC-5, exposure is prevented through treating
and covering the treated residues with soil on-site. Leaching of
organics from above the water table to groundwater is eliminated.
Leaching of metals would be greatly reduced. All organics in the
excavated soils would be addressed; all metals and asbestos would
be stabilized. Long-term maintenance of the soil cover would be
required to prevent potential exposure to the stabilized metals
and asbestos present in the treatment residues left on-site.
Alternatives SC-2 through SC-5 would require institutional
controls to prevent future activities that result in intrusion
into contaminated materials remaining at the Site.
Under all alternatives, approximately 30 percent of the
contaminated soil-waste materials resides below the mean low
water table. Even under Alternatives SC-4 and SC-5, where all
the contaminated soil-waste materials above the water table are
to be excavated, organic and inorganic contaminants below the
water table would continue to migrate with the groundwater off
the Raymark property.
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Compliance with ARARs
Alternative SC-1 would not comply with the RCRA Subtitle C
closure requirements for the surface impoundments (lagoons),
buried materials (landfill) or tanks, and would also not comply
with the general closure and post-closure RCRA requirements.
However, Alternative SC-1 would comply with the long-term
groundwater monitoring requirements of RCRA (40 CFR 265.90-
265.93).
Alternatives SC-2 and SC-3 would comply with the RCRA Subtitle C
ARARs for closure of existing units (i.e., surface impoundments,
buried materials-landfill and tanks) and the long-term
groundwater monitoring requirements. Alternatives SC-2 and SC-3
would also comply with the TSCA disposal and landfill
requirements as specified in 40 CFR 761.60 and 40 CFR 761.75,
respectively, with the exception of subsections 761.75 (b)(1), .
(b)(2), (b)i(3) and (b)(7). Both Alternatives SC-2 and SC-3 would
require waivers pursuant to the TSCA regulations at 40 CFR 761.75i
(c)(4). (Refer to the FS - Section 4.0 for further details
regarding the TSCA waivers noted herein.) Alternatives SC-2 and
SC-3 would comply with the NESHAPs (40 CFR 61, Subpart M) and
State of CT Asbestos Abatement and Licensing and Training
requirements for building demolition, and the handling,
management and disposal of asbestos-containing materials. Both
alternatives would comply with the State's requirements for
discharge of stormwater associated with industrial activity, the
Connecticut Water Quality Standards, and the Connecticut's air
pollution control regulations for stationary sources, fugitive
dust, hazardous air pollutants and odors.
Alternatives SC-4 and SC-5 would comply with RCRA Subtitle C
ARARs for closure of existing units and the long-term groundwater
monitoring requirements. Alternative SC-5 would also comply with
RCRA Subtitle C land treatment, incineration and miscellaneous
treatment unit requirements, and the TSCA storage and disposal
requirements. Alternatives SC-4 and SC-5 would comply with the
NESHAPs and State of CT requirements, noted above for SC-2 and
SC-3, for building demolition, and the handling, management and
disposal of asbestos-containing materials. Both alternatives
would comply with the State's requirements for stormwater
discharges, the Connecticut Water Quality Standards, and the
Connecticut's air pollution control regulations for stationary
sources, fugitive dust, hazardous air pollutants and odors.
Long-Term Effectiveness and Permanence
Alternative SC-1 would not provide any risk reduction or
protection of human health or the environment pver the long-term.
Alternatives SC-2 and SC-3 would reduce the magnitude of the risk
to within EPA's acceptable risk range (carcinogenic risk to below
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10"6 and a hazard index less than 1.0) through capping, and
limited excavation (SC-3 only). With long-term maintenance of
the cap systems firmly established, Alternatives SC-2 and SC-3
will provide long-term protectiveness.
Under Alternatives SC-4 and SC-5, risks would also be reduced to
within EPA's acceptable risk range through excavation and off-
site treatment/disposal (SC-4), or excavation and on-site
treatment of contaminated materials (SC-5). Long-term
maintenance/monitoring measures under SC-4 would be similar to -
those required under SC-5.
All contaminated materials would be left in place under
Alternative SC-1, and existing Site features (e.g., pavement and
foundations) and natural contaminant attenuation mechanisms would
provide marginal controls of the contaminated materials. The
capping system proposed for Alternatives SC-2 and SC-3 would
prevent direct exposures and prevent leaching of contaminants
into the groundwater from the soil-waste materials above the
water table. For Alternatives SC-2 and SC-3, their reliability
of controls is considered to be equivalent, but much more
reliable than SC-1. The reliability of Alternatives SC-2 and SC-
3 is considered very high if the cap is properly maintained and
deed restrictions are enforced to prevent intrusion into .or
damage of the cap system. All contaminated soils above the water
table would be removed for off-site treatment/disposal under
Alternative SC-4, and therefore reliability would also be very
high over the long term. Alternative SC-5 would actively remove
all organics from the soils excavated from above the water table
and would leave treated materials (metals and asbestos) on-site;
the reliability of this alternative would also be very high.
While the reliability of Alternatives SC-4 and SC-5 is fairly
similar, the adequacy and reliability of controls for
Alternatives SC-4 and SC-5 in comparison to Alternatives SC-2 and
SC-3 is much better, and even greater in comparison to
Alternative SC-1.
Alternative SC-1 would not protect the groundwater from future
leaching of organics and metal contaminants since degradation of
the existing pavement and foundations would result in increased
leaching over time. Alternatives SC-2 and SC-3 would eliminate
contaminant leaching through reduction of infiltration using a
cap and removal of NAPL. Alternative SC-3 would, in addition,
provide for removal of some additional highly contaminated soils,
and would, thereby, provide slightly greater reduction in
leaching than Alternative SC-2 from these highly contaminated
soil areas. Both Alternatives SC-4 and SC-5 would prevent the
leaching of organic contaminants to groundwater; SC-4 would also
prevent the leaching of metals while SC-5 would minimize leaching
since metals and asbestos are stabilized on-site. However, none
of the alternatives would reduce or eliminate the leaching of
contaminants from soil-waste materials present below the water
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table.
Reviews every five years will be required for all source control
alternatives evaluated since contaminated soil-waste materials
will remain below the water table. These five-year reviews would
be required to assess contaminant presence and potential leaching
and migration in groundwater.
Reduction of Toxicity. Mobility, or Volume Through Treatment
There is no reduction in toxicity, mobility, or volume through
treatment under Alternative SC-1.
Alternative SC-2 offers limited reduction of toxicity, mobility,
or volume through treatment. Specifically, the NAPLs that can be.
effectively removed from known locations on the Site and
recycled/treated off-site, and/or the VOCs captured by the vapor
control system component of the cap that are recovered and the
condensate that is recycled/treated off-site, will provide some
reduction of contaminant toxicity, mobility, and volume through
treatment.
Under Alternative SC-3, approximately 21,000 cubic yards (or only
approximately 5%) of the total amount of contaminated materials
above the water table would be sent off-site for treatment to
reduce toxicity, mobility and volume prior to off-site disposal,
in addition to the NAPL and vapor collection/treatment.
Alternatives SC-4 and SC-5 would both result in the treatment
(off-site or on-site, respectively) of approximately 410,000
cubic yards of contaminated soil-waste materials found above the
water table.
Overall, Alternatives SC-4 and SC-5 would provide the greatest
reduction of toxicity, mobility, and volume through treatment of
all the alternatives considered.
Short-Term Effectiveness
The use of appropriate engineering controls and personal
protective equipment is expected to minimize adverse impacts to
the community and workers, respectively. Earth moving activities
(consolidation and backfilling) associated with Alternative SC-2
are expected to generate some limited amounts of fugitive dust
and vapor-phase VOCs, but would be easily managed through
engineering controls (such as wetting or use of dust
suppressants). Alternative SC-3 would likely result in greater
short-term impacts (e.g., generation of increased dust and
vehicular traffic) than SC-2 because of the excavation, handling,
and off-site transport of 11,000 cubic yards of highly
contaminated material contemplated under SC-3. Alternatives SC-4
and SC-5 would involve much more excavation and materials
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handling and would likely result in much greater fugitive dust
and vapor-phase VOCs generation than Alternatives SC-2 and SC-3.
The control of fugitive dust and/or vapor-phase VOCs for
alternatives SC-3 through SC-5 through common practices such as
wetting or use of dust suppressants becomes increasing more
difficult as more contaminated materials are excavated. This
would result in added risks to workers and nearby residents.
Substantial management of construction activities under
Alternatives SC-4 and SC-5 would be necessary to minimize
increased short-term risks during implementation. Under
Alternative SC-4, a twenty-fold (i.e., totalling approximately
20,000 truck loads) increase in truck traffic, than would be
required in Alternative SC-3 (the only other alternative
requiring substantial excavation and transport of contaminated
materials off-site) could result in added risks and greater
nuisances for nearby residents and businesses. Alternatives SC-:2
and SC-5 would result in no additional increases in truck traffic
due to the off-site transport of contaminated materials; however,
% Alternative SC-5 would require substantial mitigative measures to
' prevent potential impacts from occurring due to the large
excavation activities involved with this alternative.
Alternative SC-1 would not achieve any of the remedial action
objectives previous identified in Section VII (A) of this ROD.
The time to complete each alternative is also the time required
to attain the remedial action objectives. Alternative SC-2 could
be completed within 1 to 4 years. Alternative SC-3 could be
completed within 2 to 4 years. Both Alternatives SC-4 and SC-5
would require approximately 5 to 7 years to complete.
Implementability
Each of the alternatives would be implementable since companies
with the appropriate personnel, equipment, and resources are
available. Alternative SC-1 is the most easily implemented since
no actions (other than long-term monitoring) are required.
Alternative SC-2 is the most readily implementable of all
alternatives that employ a response action since common
construction techniques are required to demolish the buildings
and install the capping system components. Alternative SC-3 is
less implementable than SC-2 because of inherent technical
difficulties and unknowns associated with the excavation,'
materials handling and off-site treatment and ultimate disposal
of 21,000 cubic yards of highly contaminated soil-waste
materials. Alternative SC-4 is much more difficult to implement
than either SC-2 or SC-3 because of the very large volume of
materials to be excavated, handled, staged, and transported off-
site for treatment and disposal. In addition, the large volume
of contaminated materials requiring off-site treatment and
disposal capacities may pose difficulties in coordinating with
other offices and agencies such a large effort. Alternative SC-5
' 2*
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would also be extremely difficult to implement because of the
large volume of contaminated materials that must be excavated,
handled, staged, treated, and backfilled all within the 33 acre
property.
Deed restrictions would be required for all alternatives except
No Action. These deed restrictions will require significant
coordination among all parties involved with the Site in order
for them to be implemented and enforced.
Alternatives SC-2 through SC-5 require common construction
techniques and equipment for decontamination, demolition,
excavation, consolidation, backfilling, or capping activities.
Thermal desorption and solidification (Alternative SC-5) have
been successfully applied at a number of sites, and a number of
firms are available to implement them. Extensive pilot-scale
testing would still be necessary on the Site under Alternative
SC-5.
Alternatives SC-3 and SC-4 include off-site treatment and
disposal (assumed to be incineration/solidification with
landfilling) of contaminated soil-waste materials. However,
limited nationwide treatment and landfill capacity may pose
difficulty in implementing Alternative SC-4 because of the
disposal volume required (approximately 410,000 cubic yards).
SC-3 would require 21,000 cubic yards of treatment and landfill
capacity; a volume that can be more easily accommodated than the
volume envisioned under Alternative SC-4.
Cost
The costs associated with each of the source control alternatives
are provided in Table 4-6 of the FS. For the containment
(capping) alternatives (SC-2 and SC-3), Alternative SC-2 would
cost approximately $70 Million less than SC-3. This cost
differential is primarily due to the added costs estimated to
excavate, transport off-site, and incinerate the 21,000 cubic
yards of materials containing high concentrations of PCBs
(greater than 500 ppm) and other contaminants also found on-site.
Alternative SC-4, which involves excavation and off-site
treatment/disposal of all soil-waste materials above water table
(and the residential and Wooster Junior High School materials),
would cost the most of all alternatives since the transport and
off-site treatment of such large quantities of contaminated
materials would be very expensive (estimated at over $1 Billion).
Alternative SC-5, on-site treatment and backfilling, would cost
approximately $650 Million less than Alternative SC-4, but
significantly more than either Alternatives SC-2 or SC-3.
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State Acceptance
The State's comments on the Proposed Plan are provided in the
Responsiveness Summary included in Appendix A of this ROD. The
State concurs with the Selected Remedy. The State's letter of
concurrence, documenting it's position on the Selected Remedy is
provided in Appendix B of this ROD.
Community Acceptance
The comments received from the community on the RI/FS and the
Proposed Plan during the public comment period are included as an
attachment to the Responsiveness Summary found in Appendix A of
this ROD.
Based upon the written and oral comments received during the
public comment period, there were both supporting and opposing
views with respect to the Proposed Plan and the other source
control remedial alternatives evaluated in the RI/FS. EPA
responses to all public comments are summarized in the
Responsiveness Summary included in Appendix A of this ROD.
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X. THE SELECTED SOURCE CONTROL REMEDY
The source control remedy selected from the five (5) remedial
alternatives evaluated for this Site is Alternative SC-2 which
essentially involves: decontamination, demolition, NAPL removal,
capping, and institutional controls. The specific components of this
source control remedy are described in further detail below:
A. Description of Remedial Components
Decontamination/Demolition - The on-site buildings and other
structures will be decontaminated and demolished to facilitate
effective implementation of the capping component of this
alternative. EPA will conduct a comprehensive environmental
assessment of these buildings and structures and define specific
decontamination and handling procedures during the remedial
design stage. Likely actions to be conducted for the buildings
and structures include: surface cleaning for metals; removal of
remaining process equipment; demolition; recycling or reusing thei
uncontaminated materials (as feasible); and disposing of
contaminated debris on-site (under the cap) and/or off-site. I-f
possible, salvageable materials such as steel and copper piping,
or structural steel will be recovered. Uncontaminated debris,
e.g., bricks, cinder blocks, will be crushed and used as cover or
fill materials to decrease the volume of clean fill material that
will need to be brought on-site to establish proper cap grades.
The foundations are expected to remain in place under Alternative
SC-2. The subsurface drainage system will be left in place;
however, all subsurface drains will be plugged to prevent
continuing discharges to Ferry Creek.
Engineering controls will be implemented during building
demolition to prevent airborne emissions of asbestos, fugitive
dusts or vapor-phase VOCs. For example, engineering controls
such as dust suppressants (foam) and/or water will be applied to
wet the building materials, as appropriate, to minimize potential
airborne emissions from being generated.
Consolidation/Backfilling - The residential and Wooster Junior
High School soil-waste materials and some of the building
demolition debris will be used to backfill low-lying areas within
the Facility and to achieve proper grades for the cap. As
necessary, contaminated fill immediately outside of and
contiguous to the Raymark Facility's property boundary may need
to be consolidated, where practicable, to facilitate the
placement of the cap.
Engineering controls will be implemented during consolidation and
backfilling to prevent airborne emissions of fugitive dusts
contaminated by SVOCs, PCBs, metals, or asbestos, or emissions of
vapor-phase VOCs. For example, engineering controls such as
moveable enclosed structures (domes), dust suppressants (foam),
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and/or water will be applied to wet the soil-waste materials, as
appropriate, to minimize potential airborne emissions from being
generated. >
Geotechnical Engineering Investigation and Design - A
geotechnical engineering investigation will be conducted
preceding the design of the cap system.
Site Grading After consolidation/placement of all the
residential and Wooster Junior High School contaminated soil-
waste materials on the Site, grading will be required prior to
placement of the cap system. Compaction of the soil-waste
materials/building debris will be performed as needed. The
appropriate slopes for the base of the cap will be determined as
part of the cap system design.
Cap System - A multi-layered, impermeable cap system, designed in
accordance with RCRA Subtitle C requirements and consistent with
the TSCA chemical waste landfill regulations will be installed to
prevent risks to human health from direct contact or incidental
ingestion of soil contaminants. The cap will also minimize
infiltration and resulting organics and metals leaching into
groundwater. The cap system will be installed over the area
where Raymark waste is located, and where necessary to maintain
the appropriate slopes/grades for the cap. This area is
currently bounded by East Main Street (Connecticut Highway 110)
on the northeast, Barnum Avenue and U.S. Route 1 on the south-
southeast, Longbrook Ave on the southwest, and the railroad
embankment/tracks on the northwest.
The conceptual cap system design, subject to modification during
the remedial design, will be based on the requirements of 40 CFR
265.310 and consistent with the Technical Guidance Document:
Final Covers on Hazardous Waste Landfills and Surface
Impoundments (EPA/530-SW-89-047, July 1989). A cross section of
the conceptual cap system is presented on Figure 3-4 within the
FS. Descriptions of the individual cap layers are summarized as
follows:
Cover Layer - The objective of this layer of the cap is to
provide protection from erosion and frost of the lower
layers of the cap. A minimum of 2 feet of soil may be
required to sustain growth of a vegetative cover, or the
surface layer (5 to 10 inches) may be comprised of hardened
or armored material (such as stones or cobbles) if
vegetative growth is not desired for future site-use. If a
building or parking lot were to be constructed on top of the
cap, the suitability of other materials for the cover layer
will need to be evaluated. The thickness of the top layer
will be determined- during the design in order to prevent
freezing and thawing that could damage the underlying
drainage layer or the impermeable layer. A surface slope of
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3 to 5 percent will be needed to promote runoff while
inhibiting erosion. The final surface slope,.to be
determined by EPA during remedial design, will be dependent
on the actual use of the property, the type of surface
materials used, and how runoff will be managed. Surface
runoff will be diverted to newly installed surface drains,
which will then be discharged to the storm drains present
near the Site.
Drainage Layer - This layer is used to reduce the potential
for infiltrated water to pond over the impermeable layer.
The drainage layer promotes the removal of water to areas
outside of the cap, such as a drain to the existing storm
water sewer. The drainage layer will be either a
geosynthetic material or coarse sand/gravel (less than 3/8")
with a minimum hydraulic conductivity of IxlO"2 cm/sec or
transmissivity of 3.5xlO~5 m2/sec. A geotextile filter
fabric will be placed over the drainage layer to prevent the
entry of fine-grained particles into the drainage layer.
Infiltrating water that reaches this layer will be channeled
to internal drains, and will ultimately be discharged to the
storm water drains present near the Site.
Impermeable Layer - This layer will be designed to minimize,
to the extent practicable, the potential for infiltration of
precipitation into the underlying soil-waste materials. A
double barrier will be reguired to be consistent with the
guidance for design of RCRA hazardous waste covers. Two
barriers will be used so that in the event one barrier is
damaged or fails, the second barrier will still be intact.
A maximum 3 percent slope is recommended by the RCRA/CERCLA
cover guidance document.
The top barrier may be a flexible membrane layer (FML) of at
least 60 mil thickness. The FML will be of sufficient
thickness to withstand any future use of the cap surface.
The bottom barrier will have a maximum permeability of 1 x
10"7 cm/sec and may consist of a geosynthetic clay layer
(GCL) (which typically has a permeability IxlO'9 cm/sec or
lower), or 2 feet of clay compacted to the target
permeability. GCLs can be installed more efficiently than
clay.
Vapor Control Layer - The purpose of this layer is to
capture and channel potential gas-phase VOCs to an off-gas
treatment system, e.g., activated carbon. Because VOCs are
present in the soil-waste materials below grade, the
placement of a multi-layered, impermeable barrier over the
these materials c.ould cause accumulation of undesirable soil
gases that could permeate upward through, or otherwise
disturb, the cap system. The gas collection layer will be
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made of either gravel, coarse sand, or geosynthetic
materials. A geotextile material will be used to separate
the gravel from the low permeability GCL. Treatability
testing will be required in order for EPA to evaluate and
optimize the effectiveness of VOCs treatment. The recovered
VOCs and condensates will be sent off-site for recycling,
treatment, or disposal.
Subgrade - The base layer of the cap system will be a well
compacted and smooth surface that has sufficient subgrade
material to prevent puncture of the barrier layer. The
subgrade will likely be sand or crushed building materials
(concrete, brick, etc.). A geotextile material will be
placed above the subgrade to prevent fines from entering the
vapor control layer.
The actual materials for the cap system will be determined during
the engineering design and will depend on the likely future land
use of the Raymark Facility property.
Since the capped area will encompass, at a minimum, all organic
and inorganic-contaminated Raymark soil-waste materials (the 33-
plus acres of the Facility), surface run-on and run-off controls
will be required given the large surface area the cap system is
anticipated to cover.
NAPL Removal - By performing NAPL removal at the Site, the
contaminant mass can be reduced that will significantly limit VOC
migration into groundwater. The presence of NAPL on-site has
currently been identified near the former acid neutralization
pits and the former toluene spill area. However, the full
lateral and vertical extent of the NAPLs at the Site is presently
unknown and will require further investigation.
To further evaluate the extent of NAPL contamination and to
quickly initiate removal, NAPLs will be measured and removed from
the two (2) existing on-site monitoring well clusters. These
remedial design activities will be used to evaluate how quickly
or not the NAPL recovers in the existing wells. If NAPL recovery
is minimal, then further evaluation of the feasibility of NAPL
removal will be required. If the NAPL removal yields substantial
quantities and NAPL recovery from the existing wells is rapid,
this approach will be continued until such time that the existing
monitoring wells will need to be decommissioned because of the
building demolition/capping activities. If NAPL removal is
successful, new wells, more specifically designed for NAPL
removal, will be installed, if and to the extent practicable,
prior to cap installation and incorporated into the cap design to
continue with the mass removal of NAPL. These new wells will be
installed in a manner that is not inconsistent'with the potential
Site re-use possibilities.
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All recovered NAPL will be sent off-site for recycling,
treatment, or disposal.
Interim Monitoring - Groundwater, storm water, and air monitoring
will be conducted during implementation of this alternative to
assess whether or not any contaminant migration is resulting from
the response activities envisioned according to the selected
source control remedy. Groundwater will be sampled from existing
and newly installed wells. Storm water will also be sampled to
evaluate the quality of runoff discharging to the existing storm
water system and eventually into Ferry Creek. Air samples will
be collected and analyzed as required by federal and state air
pollution control regulations.
Institutional Controls and Lona-Term Considerations - Groundwater
and storm water monitoring, cap maintenance, and deed
restrictions will be long-term components of the selected remedy.
After the cap has been constructed, deed restrictions will be
used to limit the future activities that could result in
accidental intrusion into the cap, accidental exposures to the
wastes, and damage of the cap system. Routine maintenance of the
cap will be required to ensure its long-term effectiveness.
The groundwater will be sampled and analyzed to monitor the cap
effectiveness, the quality of groundwater leaving the Facility,
and potential impacts to downgradient groundwater. Existing
monitoring wells will be used to the extent possible; however,
several wells will likely be decommissioned during implementation
of the remedial action. Some of these wells will need to be
replaced to facilitate monitoring. Surface water run-off that
drains from the cover of the cap and infiltration channeled by
the drainage layer within the cap will also be sampled to assess
the quality of the water discharging to the storm drain.
Five-Year Reviews - Since hazardous substances, poll-utants or
contaminants will remain on-site, a review of Site conditions and
risks will be conducted at least once every five years after the
initiation of the source control remedial action at the Site
(i.e., award of the contract for remedial action), as required by
CERCLA. This is required by law to assure that the remedial
action continues to protect human health and the environment.
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XI. STATUTORY DETERMINATIONS
The source control remedial action selected for implementation at the
Raymark Industries, Inc. Facility is consistent with CERCLA and the
NCP. The selected remedy is protective of human health and the
environment, attains ARARs and is cost-effective. The selected remedy
utilizes permanent solutions and alternate treatment or resource
recovery technologies to the maximum extent practicable for this Site.
However, the selected remedy does not fully satisfy the statutory
preference for treatment which permanently and significantly reduces
the mobility, toxicity or volume of hazardous substances as a
principal element. This is because EPA has determined that the risks
and costs attendant with treatment of a discrete portion or of the
substantial volumes of contaminated soil-waste materials on-site
outweigh the limited increase in protectiveness afforded and,
therefore, treatment of the principal threats was not found to be
practicable.
A. The Selected Remedy is Protective of Human Health and the
Environment
The source control remedial action selected for this Site will
significantly reduce the risks posed to human health and the
environment by eliminating, reducing or controlling exposures to
human and environmental receptors through engineering controls
(capping) and institutional controls (deed restrictions).
More specifically, the cap will provide short-term and long-term
protection from direct exposures (dermal contact, incidental
ingestion, and inhalation) to the contaminated soil-waste
materials. Leaching of organic and inorganic contaminants from
precipitation through the soil-waste materials to groundwater
'will also be.virtually eliminated by. the cap system. Removal of
NAPLs will further reduce contaminant leaching into groundwater,
while plugging of the on-site subsurface drainage system will
also prevent the continued discharge of contaminated storm water.
to Ferry Creek. Deed restrictions will restrict activities that
could damage or intrude into the cap system.
The selected remedy will achieve potential human health risk
levels that attain the 10"4 to 10"^ incremental cancer risk range
and a level protective of noncarcinogenic endpoints, and will
comply with ARARs.
B. .The Selected Remedy Attains ARARs
This source .control remedial action will attain all applicable or
relevant and appropriate federal and state requirements (ARARs)
that apply to the Site. Environmental laws from which ARARs for
the selected source control remedial action are derived, and the
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specific regulations are included in the Tables attached to this
ROD. These tables provide a brief synopsis of the ARARs and an
explanation of whether the requirements are applicable or
relevant and appropriate to the actions to be taken at the Site.
No federal or state chemical-specific ARARs were identified for
the selected source control remedial action. A discussion of the
selected remedy ARARs is presented below:
Action-Specific ARARs
Under the selected source control remedial action, capping
of the on-site lagoons (surface impoundments) and the on-
site buried materials (landfill) will comply with the RCRA
closure requirements specified in 40 CFR 265.228. and 265.310
[excluding 40 CFR 265.310(b)(2), which is not an ARAR],
respectively. All tanks that remain on-site will be closed
in compliance with 40 CFR 265.197. The general closure and
post-closure requirements under 40 CFR 265.110-120 will be
complied with during and following implementation of the
selected remedy. The selected remedy will also comply with
the federal RCRA requirements for post-closure long-term
monitoring of groundwater (40 CFR 265.90 - 265.93).
Compliance with the federal requirements stated above also
constitutes compliance with the closure regulations of the
State's Hazardous Waste Site Management Regulations which
incorporate by reference substantial portions of the federal
hazardous waste regulations.
The selected remedy will also comply with the asbestos
NESHAPs requirements (40 CFR 61, Subpart M; specifically,
Sections 61.145, 61.150-151, and 61.154), and the State
Asbestos Abatement and Licensing and Training regulations
(Sections 19a-332a-l through 19a-332a-l6, and Sections 19a-
332a-17 through 19a-332a-23, respectively) during the
building demolition, handling, management, and disposal of
the asbestos on the Site.
This remedy will be consistent with the Connecticut Water
Quality Standards (issued pursuant to Section 22a-426, CGS)
since actions are taken to reduce further degradation of the
groundwater through capping and NAPL removal.
The selected remedy will comply with the TSCA regulations
(40 CFR 761.60) applicable to the disposal of PCBs (at
concentrations greater than 50 ppm), with the exception of
several of the requirements under 40 CFR 761.75 which EPA
waives consistent with 40 CFR 761.75(c)(4). These
requirements, which EPA waives, include: construction in low
permeable clay conditions [40 CFR 761.75 (b)(l)]; use of a
synthetic membrane liner [40 CFR 761.75 (b)(2)]; no
hydraulic connection between the Site and flowing surface
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water arid that the bottom of the landfill be 50 feet above
the historic high water table [40 CFR 761.75 (b)(3)]; and a
leachate collection system be installed [40 CFR 761.75
Finally, the selected remedy will comply with the state
Discharge of Stormwater requirements for monitoring storm
water discharges from the drainage system, and will also
comply with the state air pollution control regulations for
fugitive dust and odors.
Location-Specific ARARs '
The only location-specific ARAR that is applicable to the
Site is the State's Coastal Management Act at Section 22a-
92, CGS. This Act applies to the "coastal area" defined in
Section 22a-94(a), CGS to encompass the entire Town of
Stratford. EPA will, therefore, determine whether the
remedial action will be consistent, to the maximum extent
practicable, with the policies set forth in the Coastal
Management Act.
Chemical-specific and action-specific policies, criteria, and
guidances (TBCs) that are not ARARs but that EPA deemed
appropriate to consider, as identified in Tables 4-2A and 4-2B of
the FS report and attached to this ROD, were also considered in
selecting the selected source control remedial action. In
particular, the selected remedy will be consistent with the
proposed Connecticut Cleanup Standard Regulations, the TSCA PCB
Spill Clean-up Policy, and OSWER Directive No. 9355.4-01 for PCB
contamination. Finally, the cap will be consistent with the
technical specifications contained in the EPA guidance for Final
Covers on Hazardous Waste Landfills and Surface Impoundments
(EPA/530-SW-89-047, July 1989).
Finally, EPA has determined that the RCRA land disposal
requirements ("LDRs") are not triggered for the selected source
control remedial action so long as the soil-waste remains within
the area of contamination.
C. The Selected Remedy is Cost-Effective
The selected remedy is cost-effective, i.e., the remedy affords
overall effectiveness proportional.to its costs. In selecting
this remedy, once EPA identified alternatives that are protective
of human health and the environment and that attain, or, as
appropriate, waive ARARs, EPA evaluated the overall effectiveness
of each alternative by assessing the three additional criteria
long-term effectiveness and permanence; reduction in toxicity,
mobility, and volume through treatment; and short-term
effectiveness, in combination. The relationship of the overall
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effectiveness of this remedial alternative was determined to be
proportional to its costs. The estimated costs of the selected
source control remedial action, based upon the assumptions
contained in the FS, are:
ESTIMATED CAPITAL COST: $35.926.000
ESTIMATED 0 & M (Present Worth): S5.780.430
ESTIMATED TOTAL COST (Present worth): $41.706.430
In comparing the overall effectiveness of SC-2 with that of SC-3,
EPA believes that SC-3, while only partially satisfying the
statutory preference for treatment, does not provide any
significant added protection of human health or the environment.
The excavation and treatment of 21,000 cubic yards under SC-3
involves significantly greater short-term impacts than SC-2 which
involves little or no excavation. Because SC-3 would address
only 5-10% of the total contaminated soil-waste materials on the
Site, it would provide only a marginal increase in the long-term
effectiveness over capping and NAPL removal at more than twice
the cost of SC-2. Therefore, EPA believes that the costs for SC-
3 (an additional $70 Million in comparison to SC-2) are not
proportional to its overall effectiveness.
EPA, therefore, believes that the cost of the selected
Alternative SC-2 is clearly proportional to its overall
effectiveness when considering this alternative against all other
alternatives evaluated for cost-effectiveness.
D. The Selected Remedy Utilizes Permanent Solutions and
Alternative Treatment or Resource Recovery Technologies to
the Maximum Extent Practicable
'Once EPA identified those source control remedial alternatives
that attain or, as appropriate, waive ARARs and that are
protective of human health and the environment, EPA then
considered which alternative(s) utilizes permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. This
determination was made by deciding which one of the identified
alternatives provides the best balance of trade-offs among all
the alternatives in terms of: 1) long-term effectiveness and
permanence; 2) reduction of toxicity, mobility or volume through
treatment; 3) short-term effectiveness; 4) implementability; and
5) cost. The balancing test emphasized long-term effectiveness
and permanence and the reduction of toxicity, mobility or volume
through treatment; and considered the preference for treatment as
a principal element, the bias against off-site land disposal of
untreated waste, and community and state acceptance.
The selected source control remedial action (Alternative SC-2)
was determined to provide the best balance of trade-offs among
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all the alternatives evaluated for the following reasons: (1)
while only Alternatives SC-4 and SC-5 were determined to best
satisfy the criteria of long-term effectiveness and permanence
and reduction of toxicity, mobility or volume through treatment,
these two alternatives were also determined to result in
significantly greater short-term impacts, additional difficulties
and unknowns associated with excavating, transporting and
treating large quantities of contaminated materials, and vastly
greater costs than SC-2, (2) the excavation, transportation and
treatment of 21,000 cubic yards under Alternative SC-3, while
nominally satisfying the preference for treatment, would involve
significantly more short-term impacts, additional
implementability considerations, and significantly more costs,
while only providing a marginal increase in the long-term
effectiveness and permanence, than SC-2, and (3) state acceptance
of and community input into the selected source control remedial
action was largely favorable.
E. The selected Remedy Does Not Fully Satisfy the Preference
for Treatment Which Permanently and significantly Reduces
the Toxicity, Mobility or Volume of the Hazardous Substances
as a Principal Element
CERCLA and the NCP set forth the process by which remedial
actions are evaluated and selected. The Raymark Industries, Inc.
Site contains a large volume of contaminated soil-waste
materials. The excavation, transportation and treatment of such
volumes (including the 21,000 cubic yards considered in SC-3)
would involve unacceptable short-term impacts and would not be
cost-effective. Therefore, the Alternative SC-2, which does not
fully satisfy the preference for treatment, was selected in this
ROD.
41
-------
XII. DOCUMENTATION OF SIGNIFICANT CHANGES
EPA presented a proposed plan (preferred Source Control Remedial
Alternative) to the public for remediation of the Raymark Industries,
Inc. Site and solicited public comments from April 8 through June 8,
1995.
The preferred Source Control Remedial Alternative involved: (1)
containment, which consisted of a multi-layered, impermeable barrier
(cap) together with institutional controls (e.g., deed restrictions);
(2) decontamination and demolition of all on-site buildings and
structures; (3) plugging of all existing on-site subsurface drains;
(4) consolidation of contaminated soil-waste materials from
residential properties and the Wooster Junior High School on the Site;
(5) NAPL removal, to the reasonable extent practicable, found
currently in wells near the former acid neutralization pits and former
toluene spill area; and (6) long-term groundwater monitoring (using
existing and new monitoring wells) and storm water monitoring and
five-year reviews.
Following the public comment period noted above, the following
significant change is to be included in the selected source control
remedial action:
(1) projected decontamination/demolition costs have increased.
In particular, Based upon information available at the time of
the Proposed Plan and contained in the Administrative Record, EPA
considered the capital cost estimate provided by Raymark
Industries, Inc. to be fair and reasonable relative to building
decontamination/demolition. However, a more recent, independent
evaluation of the capital costs associated with building
decontamination/demolition indicates that the projected costs
will increase from the original estimate of $10 Million to
approximately $30 Million. It should be noted, also, that this
projected increase in costs would effect the costs associated
with all the alternatives evaluated for the Site, except the No-
Action alternative.
42
-------
XIII. STATE ROLE
The State of Connecticut, Department of Environmental Protection has
reviewed the various source control remedial alternatives and has
indicated its support for the selected remedy. The State has also
reviewed the Remedial Investigation, Risk Assessment and Feasibility
Study to determine if the selected remedy is in compliance with
applicable or relevant and appropriate State Environmental laws and
regulations. The State of Connecticut concurs with the selected
source control remedy outlined in this ROD for the Raymark Industries,
Inc. Site. A copy of the declaration of concurrence is attached as
Appendix.B.
43
-------
FIGURES
44
-------
a, r:-;Hv ,-jj..* JL -,-
^ » I rt-v » ' I
"-V-^r-^inV ^.'/^
s -."1 : *"": .'-- .rXV:: fe} I'**
i ^&&SM\
-i- '. r
""' '""
ki * BJ Hnri BB *ud F«knwy 10M.
Cedar Bea
SCALE 124000
FACILITY LOCATION MAP
RAYMARK INDUSTRIES, INC.
REMEDIAL INVESTIGATION
STRATFORD, CONNEaiCUT
; Halliburton NIB
9 CORPORATION
FIGURE 1-1
-------
ACID NEUTRALIZATION
PIT AK£AS
LAGOON
HO. I
LAGOON NO S
LAUXN HO. 3
LEGEND:
APPROMMAIE PROPERTY UNC
BULDMG OUTUNE
FORMER COVERED
LAGOGNS
TDIPORAWLY STORED RESIDENTIAL WASTE
LMBOt NO
NOTE:
NOT TO SCALE - ALL LOCATIONS APPROXIMATE
FACILITY ORIENTATION
RAYMARK INDUSTRIES, INC.
REMEDIAL INVESTIGATION
STRATFORD, CONNECTICUT
Halliburton NUS
'CORPORATION
FIGURE 1-2
-------
BUM tee
WDE 3EVCR EASEMENl
80- SEWER LME (AffROX. LOCA
EXISTMG COVERED SOL
3TOCKPLES (APFROX. LOCATION)
CCNCRAi
I) B*<-t PlAN *Ai HhOVII.Hl U< MOCI.IJUKIUM NUS COHPOH«IIUN. 55 JUNSPlN ROAD. WLUINGIGN. MA
(SOB) bb6-'899. WHK H rvA', UAM 0 ON A CLAN PKlPA«to BT CNviRONuCNIAL LABOKAIORlCS. INC.
HARD OHO. Cl. UNOLH CRUjll.l NO il 54b-IO. PLAN NO USP- I. OAICO OCI08CR 1994 fOl'JKCi
DIHlCICO UN IrilS UHAviint Ahf APPKOiiMAIl AND SHOULD NO I Bt USCO FOR DESIGN PURPOSES
TtllS [jhAWINU IS NOI fOh UC'*I1>N
J) SANIIAhT 'jt'Wl H KriCHI Ul WAI IKI/M IOAN Ot
'ROW Al HAIbCMUS & RAIlhOAU". UAliD I JU
5) lUCAItUNS Ol f'OllNllAl Arjll MJUWN HUtAMS
DLPAftlM£.Nl Of
bl) I '.'0
IN fLL I
Souce: Fm«l inveslluuiion Rapcxt. Vol 0. Piepaied by HaJttxjIon NUS Co«po<«Uon|
FIGURE 1-3
SITE FACILITIES LAYOUT
RAYMARK WDUSTRCS. INC. FACILITY
STRATFORD. CT.
SCALE: AS SHOWN
-------
TABLES
45
-------
TABLE 1-1
Parameter
Total Asbestos, high
Total Asbestos, low
Aclinolile
Amosile
Anlhropholite
Cellulose
Cellulose, high
Cellulose, high
Cellulose, high
'Cellulose, low
Cellulose, low
Cellulose, low
Chrysolile
Chrysolile. high
Chrysolile. low
Crocidilile
Glass
Glass, high
Glass, low
Matrix (Soil), high
Matrix (Soil), high
Matrix (Soil), loxv
Matrix (Soil), low
Synthetic
Tremolile
Vermiculite, high
Venniculite. low
Raymark Industries locket No. 1-87-1057
Phase IID Soil Summary Statistics
Units No. No. Detection Del Limits of NDs Maximum Arithmetic Standard 95% UCL
Delects Samples Frequency Minimum Maximum Delected Mean Deviation (note a]
% 63
% 63
% 0
0
% 0
A 0
% 68
68
/. 68
v. 68
'. 68
% 68
i 0
63
63
. 0
% 0
v. S
i 5
69
V. 69
% 69
V. 69
% 0
% 0
: 17
% 17
69
69
'68
68
68
1
68
68
68
68
68
68
6
63
63
68
6-1
5
5
69
69
69
69
63
68
17
17
91
91
0
0
0
0
100
100
100
100
100
100
0
100
100
0
0
100
100
loo
100
too
100
0
0
100
100
25
20
40
40
40
35
35
35
25
20
10
5
98
98
95
95
60
55
9.6
5.7
9.7
9.7
9.7
5.9
5.9
5.')
10.6
6.3
5.4
2.4
85.8
85.8
76.8
76.8
13.2
8.8
5.9
4.8
8.7
8.7
8.7
8.0
8.0
HO
53
46
2.9
1.5
10.8
10.8
12.1
12.1
13.2
12.9
10.8
6.7
11.4
11.4
11.4
7.5
7.5
7.5
11.7
7.2
8.1
38
87.9
87.9
792
79.2
18.8
14.3
1 of 8
Location Depth (ft.)
of Max Upper Lower
SB 41
SB 41
SB 1
SB 8
SB 12
SB 1
SB 12
Sll 8
SB 41
SB 41
MWL4
MWL4
SB 49
SB 75
SB 75
SB 49
SB 7
SB 7
4
4
4
8
6
4
6
K
4
4
4
4
2
5
5
2
4
4
6
6
6
10
8
6
8
III
6
6
6
6
4
6
6
4
6
6
-------
TABLE 1-1 con't
/
Rayntnrk Industries . locket No. I-87-1057
Phase MR Soil oo.nmary Statistics
2 of 8
Parameter
Antimony
Arsenic
llarimu
Dei) Ilium
Cailniiiini
Chromium
Cobalt
( ltp|KT
1 C...I
Mouur>
Nickel
Sckiiiuin
Silver
Thallium
Tin
Vanadium
Zinc
pH
Cyanide. Total F kf
ing IF
IIIF'Vp
pit
mp'kg
nip/kg
niF'kF
niF'kF
mg/Vg
mg/ig
IIIF/IF
mg/lf
No. No. Detection Del Limits of NDs Maximum Arithmetic Standard 95% UCL
Delects Samples Frequency Minimum Maximum Detected Mean Deviation (note a|
18
126
143
87
31
142
113
137
143
9
118
16
12
11
It)
122
140
Ml
27
3
57
22
II
0
0
0
135
143
Ml
143
143
143
143
143
M3
143
14.1
M2
86
Ml
8-1
111
M.I
Ml
1.10
124
57
36
20
56
56
56
11
88
100
61
22
9')
79
96
100
6
97
25
II
9
III
85
98
100
21
2
100
61
55
0
0
0
055
23
002
O.I 8
555
57
322
025
04
0.06
037
006
56
6
03
007
049
87
86
86
86
86
27.1
51 2
41.4
414
55.5
414
139
15
222
275
34
275
511
414
45.9
3.5
290
220
110
4900
4900
4900
14.1
189
12600
088
8
684
130
56900
52700
15.1
957
88
259
8.2
219
114
8700
9.5
57.3
5400
44
55000
16000
2.8
10.3
1.089.7
1.2
1.4
50.2
17.5
2.K58.0
3.I)S6.5
04
104 5
17
OR
1.2
19.5
26.9
611.9
7.5
1.3
77.2
8.4
6.191.6
1.750.5
203.9
203.9
203.9
2.5
19.6
2.271.1
2.9
30
90.5
30.2
7,282.2
9.5468
14
1966
23
28
20
11 5
268
1,302.9
08
62
4825
12.0
14.8806
4.552.5
4482
448.2
448.2
3.2
13.0
1.404.2
1.6
1.9
62.7
21.7
3,866.4
5.308.3
0.6
131.8
2.1
1.3
1.4
25.2
30.6
792.3
7.6
2.2
149.0
III
10.382.3
3,5108
304.1
304 1
304.1
Location Depth (11)
of Max Upper Lower
SB 30
SB 43
SB 13
SB 44
SB 38
SB 38
MW 1.4
SB 20
MWI.4
Sli 4
SB 44
SB 43
MWI.4
SB 43
SH 68
SB 52-1
MW W4
SB 44
SB 52-1
SB 44
MWG4
SB 10
SB 7
5
6
2
10
3
1
2
6
2
8
10
6
2
6
4
2
2
1.5
2
10
10
4
8
7
K
6
12
7.5
7 S
H
8
8
US
12
8
8
8
H
1
8
4
6
1?
M
6
12
-------
TAHI.K ,1-1 ciui' t
\ ,'
Kaym.tik Inilnsltics .""" )ockfl No. 1-87-1057
I'tinsc lilt Soil r>..iiunary Slalislics
3 of 8
I'.iianirlri
Sfmivitlalile Organic*
\ .2.4.5- reliachlniiibviijcne
1.2.4- Ifirliloiithcn/cite
1 1 Nnplilliui|ciimiiic
1 Naplilliylamint
2.). 4.6- Iftrnclilnroplictinl
?. -1.5- liiclilnrnplieiiol
?. 4. 6- Iriclilnrophriuil
2 -1 Diclilninpliciiiil
? -1 Dullilln Iplli-llnl
2 1 Illllitliiplli-ilul
2.'l DinilinloliifiH"
2 6-HiciiliMiiplii'iiiil
.'.6 -Iliniiriiinliiriic
2- Accl) Ijitiinnlliinivnc
2 ( hlmon.iplilliali-nc
2-( 'Mninplicniil
2-Mi-lli)ln»pliiliali.-iic
2 Naplil!i)l. inline
2-Nilrnaniline
2-Nilfiiphtniil
2-l'iciiline
3.1'-l)iclilmoheimdine
l.l'-Dimelhylben/idine
3 Meihylcholnntluene
3-Mclliylclmlanllirene
) - Melhylcholanllircne
1 Nmnaniline
4,6-Dinilio-2-metltylplicnol
4-Aminobiphenyl
4-Hromnphenyl-plienylelher
4-Ctiloro-3-melhylplieiinl
'(('lilnrnaniline
'1-Clilnrnplieiiyl plicnykllier
1 Nilinaniline
1 Niliiipliciuil
.1 NiiHu|mni>liiii- 1 uoilc
S Minn n liiliildntc
Units
up kp
up.kf
iipkg
lip/kg
np'lg
up If
np/ip
up kp
upkf
,,pkf
up kp
"F 1-K
up kp
up kp
HI.' lp
up If
up It
up-kp
up kp
npkp
up kit
up kp
up kp
up kp
lip'kp
lip.kp
up/kg
lip.kp
np'kp
llgkg
np'kg
up/kg
lip'kg
iip'kp
,,,. \.f
»P >»'
up \ K
No. No Detection Del Limits ofNDs Maximum Arithmetic
Dried* Samples I'rcquenc) Minimum Maximum Delected Mean
0
0
II
0
0
5
5
0
36
1
0
II
O
1
1
II
15
0
0
1
0
1
0
1
1
1
(1
1
0
0
6
0
)
0
1
0
II
1)6
1)6
1)6
1)6
1)5
1)5
1)5
1)6
1)8
1)5
1)6
1)5
1)6
1)6
16
U
in
16
16
115
1)6
116
116
1)6
1)6
1)6
1)6
1)5
1)6
136
135
1)6
.16
16
14
?!
Hi
II
0
(I
0
II
4
4
0
26
1
0
II
II
1
1
II
11
II
II
1
0
1
0
1
1
1
0
1
0
0
4
0
2
0
1
(1
(I
680
680
680
680
1)00
1100
680
680
680
1100
680
680
6K(I
1 100
680
68(1
iiKII
680
3100
680
680
1 100
680
250
250
250
3100
3100
680
680
680
1)00
680
3100
)IOO
680
680
71000
7100(1
71000
71000
MOOOO
320000
7)000
71000
1 5000
1 80000
71000
71000
7111(10
140000
71000
71000
KKOO
71000
320000
39000
71000
MOOOO
71000
71000
71000
71000
320000
180000
71000
71000
71000
140000
71000
320BOO ,
1 80000
71000
71000
6400
6600
2500000
140000
270
100
7500(1
160000
71
750
750
750
83000
6700
no
830000
1,116.4
I.I 16 4
I.I 16 4
I.I 16.4
2.137.0
4.760.1
1.100.7
I.I 16 4
23.0098
4.778.5
1. 116.4
1.092.0
1.116.4
2.173.7
1.11)9
1.092.0
2.-I23.I
1. 116.4
5.033.8
2.0143
I.I 16.4
2.174.1
I.I 16.4
1.107.6
1.107.6
1,107.6
5,033.8
4.356.3
I.I 16.4
1. 116.4
1,097.9
2.178.7
1.109.8
5.033.8
9,9489
1.1499
I.I 16 4
Standard 95%IICL
Deviation (note a|
3,4894
3.489.4
3.4894
3.489.4
6.886.7
15.780.7
3,5124
3.4894
218.224.7
14,387 1
3.489.4
3.4908
3.4894
6.864.7
3,490.0
3.490.8
«)..1M.«)
3.489.4
15.812. 1
13.818 1
3.489.4
6.864.8
3.489.4
3.489.6
3.489.6
3.4896
15.812. 1
10.77 I.I
3.489.4
3,4894
3.514.3
6.8635
3,491.0
15.812. 1
71.863.1
3.637.3
3.4894
1.612.0
1.612.0
1.6120
1,6120
3.118.8
7,009.9
1.601.4
1.6120
54.676.2
6.829.6
1.612.0
1.5897
1.6120
3,148.7
1.609.6
1.5897
.1.741.5
1.612.0
7.279.7
3.984 2
1.612.0
3.149.1
1.6120
1.603.3
1.6033
1.6033
7.279.7
5.891.9
1.612.0
1.6120
1,5989
3.153 5
1.6057
7.2797
20.232 7
1.691 3
1 .6 1 2 0
Location
of Max
SI) 4
SI) 4
SI) 10
Sit III
MW K4
SO 91
SI) 41
sn 10
MWO4
Sit 77
MW 14
MW V4
SD 10
sn 4
MW 14
SI) 10
Ocplh
Upper 1
8
8
T
T
6
0
d
2
18
5.25
2
4
2
8
44
2
(0)
owe!
8 5
8.5
6
6
12
2
X
6
26
8
8
K
6
85
4K
(.
-------
TAIILK j-l ,-,,,,'t
Kaymaik Intliislriet >ockct No
-R7-I057
4 of 8
l';n;lim-lcr
7. 1 .' 1 )imelhy lhen/(ii)anthracenc
a a Dimelhylphenelhylaniine
Acrnaphthene
Acrnaphlhylrnc
Arrliiphvnone
Aniline
Aniline
Anilii.irrne
Ai.iiiiili'
1 1< ll/ll) .1 l.lllllll .11 CMC
ll.-M/,.(..l|.Mr.i.
ltcll/llfMlllll>f.llllluiV
Ilrn/n4p h.i)pci)lriir
llrn/iKk (niiof.inlliciu-
Hen/) 1 alcohol
hi\|2-rhlorii-l-niclli)lrlh)l)clhrr
tli\(2-«.hlo»oeilio\) Hnclliane
lliM2-ililoiiH.-|li> Drtlicr
llix(2 iilijIlKMylH'liili.i^li-
lliilyHicii/yliilillMl.ilc
( arha/ule
ChliHohcn/iMe
( "hr> sene
Creosote (calculated)
Di-n-hulylphlhiiliilc
Di-n-octylfiliihaliiie
Diallate
1 )ihen7o( a.h (anthracene
Dirtenroiuran
Dklhylphlhalale
Dimettiylnhihalale
Diphenylamine
1 ihyl melhanesul foliate
riunranihene
1 Inotene
llrxat liliiriilirit/rnr
1 Irn.H llllMolltlt.lllll'lir
llc«aililiifoc>rli>|>rnl.uliriir
I (nils
Fie
»P'lf
nrlf
'ut/Vf
licit
«lpt|!
llp'lp
HP/IF
..pip
up ip
..p IF
lip l|!
up le
up IP
up IF
"r I>F
..pip
,,p IF
np'ip
uplp
lip/If
UP/IF
ll('l|!
up'it
IIC/LE
f* t
"f*t
ttt'kc
uric
IIE/tf
HF'lp,
lip'lp
ur't.F
ll)> 1 1-
ll)> 1 )
,,p'Vp
Ptiase 1111 Soil .->uiiim.iry Statistics
No No Detection Del Limits of NDs
Delects Samples Frequency Minimum Maximum
0 1 16
0 136
27 13*
15 1 16
13 117
1 1 16
1 1 .16
30 137
0 1 .16
31
32
27
24
21
II
it
»
II
16
16
49 1 V)
3 3
3* 141
1 136
0 136
21 r>6
27 11*
2 116
2 1.16
IS 1 16
0 1 16
60 140
14 1 1*
1 116
0 1 16
l) 1 16
0
I)
20
It
«»
1
1
22
0
25
21
20
IR
17
0
It
II
II
42
1
11
0
35
I IK)
27
1
0
15
20
1
1
II
0
43
25
1
0
0
391)
1300
610
6*0
680
6*0
6*0
680
13(10
3RD
441)
450
ft'W
560
1)110
6*0
6*0
6*0
690
6*0
6*0
6*0
460
6*0
680
1300
690
680
680
680
680
680
690
680
680
680
680
71000
140000
71000
71000
71000
71000
71000
71000
MOOOO
71 INK)
7IOOO
71000
7IOOO
71000
140000
71000
71000
71000
71000
71000
71000
71000
71000
39000
71000
140000
71000
71000
71000
71000
71000
71000
71000
7IOJDO
71000
71000
71000
Maximum Arithmetic Standard 95% I ICL
Detected Mean Deviation (note a|
19000
2500
3400
340
340
13000
24OOO
IROOO
20000
6700
II IKK)
24000
260
7100
21000
4.7
300000
120
5000
18000
91
43
1800
48000
12000
88
1. 114.2
2.17*7
1.293.7
1.078.1
I.IIOO
1. 115.2
I.I 15.2
1.2*7.7
2.I7R.7
I.4RR.5
1.367.5
1.198.4
1.156.9
1.2*1.6
2.1.31 >
I.I 16 4
I.I 16.4
1,116.4
I.IK56
1.1142
1. 151.4
I.I 16.4
1.479.8
36
2.925.8
1,114.6
2.178.7
I.III.O
1.220.6
1,111.7
I.MI.7
I.I 10.2
I.I 16 4
2.0239
1.363 1
1. 114.4
I.I 16.4
I.I 16 4
3.4899
6.863.5
3.820.9
3.495.8
3.476.2
3.489.6
3.489.6
3.729.0
6.R635
4.197*
3,«57.»
3.9730
.3.535.1
.1.6.16 9
6.867 3
3.4*94
3.4»«).4
3.4894
3.795.2
3.489.9
3.550.3
3.489.4
4.103.2
1.5
25.262.9
3.489.8
6.S63.5
3.514.7
3.754.2
3.490.5
3.490.5
3.492.4
3.489.4
6,317.8
3.782.0
3.4899
3.4894
3.489.4
1.609 9
3.153.5
1.832.4
1.574.6
1.6019
1.610.8
1.6108
1.8 15.4
3,153.5
2.080.4
1.913.4
1.9627
1.657.2
1.79*. 2
3.1109
1.6120
1.6120
1.6120
1.720.7
1.609.9
1,655.6
1.6120
2.056.2
61
6.448.8
1,610.3
3.153.5
1.610.2
1.749.8
1.607.5
1.607.4
1.6062
1.6120
2.9082
1.896.3
1.610 1
1.6120
1.6120
l.ocnlion Depth
of Max Upper 1.
SB 44
SB 60
MWK4
SB 8
MWO4
MWI4
MWJ4
MWJ4
MW J4
MW J4
MW J4
SB 52-1
SB 10
MW J4
MWJ4
SB 68
SB 10
SB 55
MWJ4
SB 44
MWI4
SB 9-1
SB 20
MWJ4
SB 44
SB 91
10
1
6
4
2
2
2
2
2
2
2
2
16
2
2
4
2
2
2
10
44
0
8
2
10
4
(0)
ower
12
4
12
10
K
6
18
R
R
*
6
6
*
12
4R
2
Id
R
12
6
-------
Parameter
llexuchloroclhane
1 lex tichlf ironfoncnc
lmjcnu( l.2,3-cd)|>yrenc
Isndrin
Isophoroiic
Isosa Prole
Kepone
m & p-Crcsol
ni-Omilrobeii/eiie
Mrlhap>rilrnc
Mclli\l iiiciliaii«ilfim;ile
N-Niln««»-tli -ii-prop\ laininc
N-Nilmsndi-n-biil) famine
N NiliosiiJiclliy Inniinc
N Nilrosniliiiiclli) Iniiunc
N-Nitri>s>t*t
llgtg
iig/kg
ug'kg
ug'kg
llgkg
11(1 'I p
»t 1F
iiykf!
"f l(!
Hflf
»K1K
ll|! kg
llp'k(!
llg'kg
lll!'ku
r t1
tif.kp
tlfl\.f
u\i/l.f
lip/kg
llgkg
llg/kg
up/kg
I'g'kg
og/kg
llg'kg
llg'kg
'Ig'kg
ll^'k)!
llfl'lf
,1|:kK
"r 1K
i'h"kK
0
o
27
0
0
0
0
33
0
1
0
0
0
0
n
i
n
0
0
43
n
i)
23
II
0
0
0
0
0
7
0
71
39
0
(Ml
(1
0
.()
U6
136
136
136
136
136
130
136
136
M6
136
136
136
136
116
1)6
136
136
116
I1R
136
136
135
136
136
134
136
136
136
.135
1.16
141
136
136
HO
136
116
i?')
0
n
2(1
0
()
0
0
24
0
1
0
0
(1
(1
0
1
0
II
II
31
II
0
17
0
n
0
0
n
0
5
0
50
2
2 8
2 6
2 8
-------
1'aramelcr
Volatile Orgonk*
I.I.I -Tt kkfcirncihane
1 .1 .2.2-Tctracliloroethane
1.1.2-lrkhloroelhane
. 1 .2- 1 rkhlnrneihane
.l-DkbNMMClhane
.(-Dichloriwlhcnc
.2-1 >khloriihenrerie
.2-1 )icbhH«henrene
.2-l>khk>fnelluine
.?-l>kbl»rio»ane
2-BuUnnnc
2-llexanone
4-Mdhyl-2-pcnunonc
Acetone
ACCMMIC
Aceioniirilc
Benzene
Benzene
llromudiclilaronieiliane
Bromofonn
Bromontcthane
Carbon disullide
Carbon Iclrachloride
'hluroben/ene
'liliwuclhiine
lilniiiloiiii
'Illlllltllielll.mC
liliHiipirnc
Units
Ufll
Uf/if
««
2
2
15
II
0
1
6
6
2
22
22
1
0
0
28
1
22
II
)
(1
0
2
10
5
5
5
5
5
5
5
5
10
5
5
5
5
5
5
5
21
6
10
10
10
10
41
5
5
5
10
10
3
5
10
10
5
10
21
91000
190000
91000
91000
91000
91000
91000
91000
91000
91000
56000
91000
91000
9«oon
91000
91000
91000
91000
400000
56000
190000
190000
1 100000
1 100000
790000
91000
91000
91000
190000
190000
98000
98000
56000
190000 ,
98000
190000
400000
120000
27
27
1800
83
5
5
100
too
240000
n
14
14
14
14
14
2700
280000
51
4500
4500
400
410
410
6
300
6200
1500000
5400
28
1. -189.3
1.000.7
5186
5186
551 6
519.6
518.4
SI 8.4
5200
520.0
1 .089.9
518.3
5184
5 IX. 4
518.4
5184
5184
5184
2.3452
2.248.4
1.000.7
1.000.7
4.2763
4.276.3
4,136.1
527.0
527.0
5184
1.0007
1.0007
523.2
4637
10.357 1
1 .094 2
5187
1 .(H)0 7
.MIC; i
10.613.6
8.1003
4.182.4
4.182.4
4.182.4
4.182.3
4.182.4
4.182.4
4.1823
4.182.3
19.6709
4.1824
4.182.4
4.182.4
4.182.4
4.182.4
4.182.4
4.182.4
17.839.3
22.8255
8.100.3
8.100.3
44.640.7
44.640.7
33.621.8
4.1816
4.1816
4.182.4
8.100.3
8.1003
4.181.9
4.0508
121.6556
8.1072
4.1824
8.100 1
I7.06«>8
2.914.1
2.088.2
1.080.1
1. 080.1
1. 113.0
1.081. 1
1.079.9
1.079.9
I.OB 1.5
1.081. 5
4.6396
1.079.8
1.0799
1.079.9
1.0799
1.0799
1.0799
1.0799
4.851.1
5.3127
2.088.2
2,088.2
10.2694
10.269.4
8.6498
1.0884
1.0884
1.0799
2.0882
2.088.2
1.0846
1.0076
26.6895
2.1826
1.0802
2.088 2
4.3969
6 of 8
Location Dc|Hli (0)
of Max Upper Lower
MWJ4
SB 4
MWM4
MWJ4
SB 21
SB 49
SB SO
MWJ4
SB 4
SB 10
MWG4
SB 52-1
SB 4
SB 64
SB 77
MWG4
MWII4
SB 10
MWII4
SB 60
SB 43
MWI4
MWM4
MWJ4
SB 64
SB 68
MWO4
SB 10
SB 8
SB 64
26
2
6
2
1
10
6
2
8
2
66
2
2
4
II
66
26
2
8
28
6
38
6
82
1
6
12
2
1
1
28
4
8
4
2
12
8
4
85
4
68
4
4
6
10
68
211
4
10
30
K
411
8
84
T
N
14
4
HI
i
-------
TABLE, l-.l con't
Raymark Industries^--/Sockel No. 1-87-
1057
7 of 8
Parameter
cis- 1 ,2-Dichlorocthene
cis- 1 .3-l)ichtoropropene
Dihruiuochloromelhnne
Dichlorodiftuoromethane
Cthylhcnzene
Isohuiyl Alcohol
Mclhyl Melhacrylate
Melhylene Chloride
Propinuitrile
Tctrachliirucihene
Toluene
trans- 1 ,2-Dichloroelhene
trans- 1 .4-Dkhloro-2-bulene
Trichltirocihene
Vinyl chloride
Xylene (total)
Units
ug'kg
tig/kg
Ug/l>g
ug/kg
ug/kg
'ug/kg
ng/kg
ug/kg
ug/kg
ug/kg
ug/kg
ug'kg
ug'kg
ii|l
-------
Parameter
Units
No.
TABLE Ml con't
Raymark Industries "~" tocket No. 1-87-1057 toft
Phase KB Soil Summary Statistics
No. Detection Del Limits of NDs Maximum Arithmetic Standard 95% UCL Location Depth (ft)
Detects Samples frequency Minimum Maximum Delected
Mean Deviation jnote a| of Max Upper Lower
PeillcUn/llerbicMct/PCBt/DloxIn
2.4.5-T
2.4-O
sn.vr.x
Aroclor 1016
Aroclor 1221
Arockir 1232
Aroclor 1242
Aroclor 1241
Aroclor 125-1
Aroclor 1260
Aroclor 1262
Aroclor 1261
Dimeihoate
Disulfoltm
Famphur
Methyl parathion
Paralhum
IMtnrale
Sulfotepp
Iliionazin
Dioxin TF.F Lower |c|
Dmxin ll-l- 1 Inner |c|
Notes:
ugl* 6 1.18 4 49 85 4000 34.6 340.2 12.6 SB 10
iicAc 1 138 1 41 7MX) 1300 76.9 339.1 124.8 SB 77
ufkc 3 138 2 49 780 270 10.1 4I.S 16.0 MW W4
og'kg 0 IIS 0 18 3300000 18.692.6 155,4523 42.733.9
UfAf 0 115 0 18 3300000 18.692.6 155.452.3 42.733.9
ue'ka 0 115 0 18 3300000 18.692.6 155.452.3 42.733.9
.if/ig 0 IIS 0 18 3300000 18.692.6 155.452.3 42.733.9
iig/kp 0 IIS 0 18 3300000 18.6926 155.452.3 42.733.9
up'lp 0 115 0 18 3300000 18.6926 155,4523 42.733.9
uflf 0 115 0 18 3300000 18.692.6 155,452.3 42,733.9
i.p'lp 90 121 74 18 1 10000 4000000 53.840.6 386.990.4 1 12.163.6 SB 10
.ip'kp 107 12) 87 19 375000 6400000 140.834 0 799.750.2 260.364.4 SB 10
»V\.f 0 117 0 35 5400 442 229.0 76.6
,l|:lr 0 117 0 35 5400 442 2290 766
i,yl( 0 M8 0 35 5400 440 228.2 76.2
nply 0 118 0 35 5400 44.0 228.2 76.2
«f\t 0 138 0 35 5400 440 228.2 76.2
nek? 0 UK 0 35 5400 44.0 2282 76.2
U(!'lr 0 118 0 35 5400 44.0 228.2 76.2
uf\.f 0 118 0 35 5400 44.0 228.2 76.2
«i(r'ky . |
-------
UNfTED STATES ENVIRONMENTAL PROTECTION AGENCY
. FUTURE RESPONSE ACTIONS
In addition, EPA is currently undertakir. -' investigations within Ferry
Creek, the Housatonic River and several logical areas within the
Town of Stratford where Raymark contami. .on has come to be located.
These investigations will allow EPA, in consultation with the CT DEP,
to identify and evaluate potential cleanup options for these
ecologically-sensitive areas. Currently, a second operable unit ROD
is anticipated to be prepared which will address the selected remedy
for these areas of the Site.
Finally,' additional groundwater studies will be required to further
evaluate the extent of the groundwater contamination on and migrating
from the Raymark Facility. The purpose of these studies will be to
determine whether this groundwater contamination is impacting or may
in the future impact any human and/or environmental receptors. This
information, in conjunction with the results of the groundwater
monitoring required for the source control remedial action, will be
used to identify and evaluate potential groundwater remedial
alternatives for the.Site. EPA, in consultation with CT DEP,
anticipate that a third operable unit ROD for the Site will be
prepared which will address, and will represent the 'final response i
action for the Site.
The following represents the selection of a remedial action for source
control (operable unit #1) by the United States Environmental
Protection Agency, Region I, with concurrence of the Connecticut
Department of Environmental Protection, for the Raymark Industries,
Inc. Superfund Site.
By:
Date
Linda M. Murphy, Director
Waste Management Division
OMIOAVPILE COPY
-------
APPENDIX A
RESPONSIVENESS SUMMARY
46
-------
RESPONSIVENESS SUMMARY
REMEDIAL INVESTIGATION
FEASIBILITY STUDY
RAYMARK INDUSTRIES INC. FACILITY
STRATFORD, CONNECTICUT
Prepared By
EPA-New England
Halliburton NUS Corporation
EPA Work Assignment No. 47-1LH3
EPA Contract No. 68-W8-0117
HNUS Project No. 4847
June 1995
-------
TABLE OF CONTENTS
RESPONSIVENESS SUMMARY
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RAYMARK INDUSTRIES, INC. FACILITY
SECTION PAGE
PREFACE 1
I. OVERVIEW 2
A. Feasibility Study Alternatives 4
B. Proposed Cleanup Plan 7
C. General Reaction to the Proposed Cleanup Plan . . 8
D. Selected Cleanup Plan 8
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS ... 9
III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE .... 9
PUBLIC COMMENT PERIOD AND EPA RESPONSES
A. Administrative Issues 9
B. Legal Issues . . 10 t
C. Technical Issues 11
1. Construction Impacts 1-1
2. Cap 13
3. Long-term Considerations Including Utility . . 15
Access and Monitoring
4. Costs 16
5. Off-Site Investigations 17
6. Support for Other Alternatives 19
7. Other Considerations ....... 23
D. Commenters Posing Many Individual Comments ... 25
1. The State of Connecticut 25
2. The Town of Stratford 26
3. Raymark Industries, Inc 28
4. The Dock, Inc 34
5. Utility Companies 50 .
6. Brake Systems, Inc 52
ATTACHMENTS
A. COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE RAYMARK
INDUSTRIES, INC. SITE IN STRATFORD, CONNECTICUT
B. TRANSCRIPT OF THE MAY 4, 1995 PUBLIC HEARING
C. SUMMARY OF QUESTIONS AND ANSWERS FROM THE OPEN HOUSES, APRIL 8
AND 11, 1995
D. COMPLETE TEXT OF COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD
c:\wp\data\mhill\rayrnark.ind\rod\respnsm.fnl
-------
PREFACE
The U. S. Environmental Protection Agency (EPA) held a 60-day
public comment period (Originally the public comment period was
set at 30 days> but a request for an extension made during the
early part of the comment period was granted. Consequently, EPA
extended the public comment period by another 30 days) from April
8, 1995, to June 8, 1995. The public comment period provided an
opportunity for interested parties to comment on EPA's Proposed
Cleanup Plan for the contaminated soil-waste at the Raymark
Industries, Inc. Facility in Stratford, Connecticut. The
Proposed Cleanup Plan was selected after EPA developed a Remedial
Investigation (RI) Report based on field data collected by
Raymark's consultants, Environmental Laboratories, Inc. (ELI).
The information in the RI Report formed the basis for evaluating
five alternative cleanup approaches for the facility that are
discussed in the Feasibility Study (FS). EPA identified its
preliminary recommendation of a Proposed Cleanup Plan in a 10
page document at the start of the Raymark Facility public comment
period. The RI, the Risk Assessment, the FS, and the Proposed
Cleanup Plan were issued in April 1995 and became part of the
public record for the facility.
On Saturday, April 8, and again on Tuesday, April 11, EPA
conducted open houses to introduce Stratford citizens to the
findings of the RI, the risks associated with the site waste, the
cleanup alternatives evaluated in the FS, and the Proposed
Cleanup Plan that included the recommended cleanup option. These
open houses afforded the public an opportunity to better
understand the cleanup options and the processes involved in
formulating a cleanup plan. EPA project leaders described the
environmental investigations at the site and EPA's rationale for
the proposed cleanup plan. Approximately 84 people registered on
the sign-in sheets.
On the evening of May 4, 1995, EPA conducted a public hearing
attended by 35 people; thirteen people testified at the.hearing.
Thirty-seven written documents were received during the public
comment period. Of those submitting written comments, three also
testified at the public hearing.
The purpose of this Responsiveness Summary is to document EPA
responses to the comments and questions raised during the public
comment period, including those raised during the open houses.
EPA considered the comments summarized in this document before
selecting a source control cleanup plan to address soil-waste
contamination on and temporarily stored at the Raymark Facility
in Stratford, Connecticut.
The Responsiveness Summary is divided into the following
sections:
-1-
-------
Section I. Overview. This section discusses the site history,
outlines the objectives of the KI, identifies the treatment
alternatives evaluated in the FS, identifies and summarizes the
general reaction to EPA's Proposed Cleanup Plan, and specifies
the EPA's selected cleanup plan.
Section II. Background on Community Involvement and Concerns.
This section contains a summary of the history of community
interest and concerns regarding the Raymark Facility.
Section III. Summary of Major Comments Received During the
Public Comment Period and EPA's Response to those Comments. This
section characterizes the written and oral comments by the public
and interested parties on the Proposed Cleanup Plan into themes
and provides EPA's responses.
ATTACHMENT A - This attachment provides a list of the community
relations activities that EPA (sometimes in conjunction with
other government entities) has conducted for the RI/FS for the
Raymark Facility site.
ATTACHMENT B - This attachment is the transcript of the May 4,
1995, public hearing held in Stratford, Connecticut.
ATTACHMENT C - This attachment is the summary of the questions
and answers posed at the open houses on April 8 and 11, 1995.
ATTACHMENT D - This attachment includes the complete text of
comments received during the public comment period.
I. OVERVIEW
Raymark Industries, Inc. and its predecessor, Raybestos
Manhattan, Inc., operated a facility at 75 East Main Street in
Stratford, Connecticut, from August 1919 until September 1989,
when operations ceased. The facility produced brakes, clutch
parts, and other friction-based products. Raymark''s operations
generated flammable and corrosive wastes, as well as lead-
asbestos sludge containing many contaminants and scrap materials.
From August 1919 to July 1984, Raymark used a system of lagoons
to dewater lead and asbestos wastes produced by its manufacturing
process. As the lagoons filled with sludge, they were often
dredged and the material was used as fill in areas around
Stratford or the lagoons were covered with asphalt to increase
the manufacturing and storage area of the facility. Throughout
the summer and fall of 1992 and early 1993, the EPA covered and
stabilized Raymark's waste at Raybestos Memorial Ball Field.
During the fall of 1992 and the spring and summer of 1993,
Raymark, under EPA oversight, stabilized and covered three of
four remaining lagoons and removed thousands of bags of asbestos,
-------
as well as several containers, and tanks of hazardous materials.
Raymark also redirected the surface water drainage on the Raymark
property so that it no longer entered the fourth lagoon and Ferry
Creek. The fourth lagoon was stabilized and covered during the
summer of 1994. The Raymark Facility has also been secured
against trespassers with the installation of fencing and an
electronic gate, and the boarding up of the lower floors of
buildings.
In February 1993, the federal Agency for Toxic Substances and
Disease Registry (ATSDR), agreed to conduct a public health
assessment/health consultation and other health follow-up
activities concerning the Raymark Facility for the Town of
Stratford. These activities were carried out in coordination
with the Connecticut Department of Public Health and Addiction
Services (CTDPHAS) and the Stratford Health Department.
In early 1993, results from on-going environmental investigations
.at the Raymark Facility revealed the presence of dioxins/furans
beneath the surface of some areas on the Raymark property. ATSDR.
reviewed the data and concluded that the dioxins/furans found on
the property did not pose an immediate health threat because most*
of the ground surface was covered by asphalt and gravel and
public access was restricted.
At the time, it was not known whether any of the Raymark waste
disposed around Stratford contained contaminants similar to those
found on the Raymark property. The EPA and the Connecticut
Department of Environmental Protection (CT DEP), in consultation
with ATSDR and CTDPHAS, began an initial surface sampling effort,
focussing on residential properties, schools, recreation areas,
and accessible public properties. Results showed the presence of
lead, asbestos, and PCBs in the soil. ATSDR issued a Public
Health Advisory in May 1993, declaring that an imminent public
health threat existed from exposure to these contaminants. In
May 1993, a public meeting was held by the Town and attended by
more than 400 people. In response to the contamination problem,
the governor of Connecticut committed $5 million under State
Superfund jurisdiction. In June 1993, the EPA committed $3
million for the continued evaluation and eventual cleanup of the
Raymark contamination problem. To date, the EPA has.spent
approximately $25 million cleaning up contaminated properties in
Stratford.
In the spring of 1993, the EPA set up a command post
in Stratford to coordinate field work at those priority locations
needing to be investigated and remediated. ATSDR, CT DEP, and
CTDPHAS also provided personnel stationed in Stratford to
coordinate environmental and public health activities. From June
1993 through the present, the EPA, working closely with CT DEP,
ATSDR, and CTDPHAS expanded the breadth of the investigation.
Sampling included residences, recreation fields, day care.
-3-
-------
facilities, schools, public areas, and local water bodies
(Housatonic River, Ferry Creek, and streams, lakes, and ponds).
In addition, planning continued for cleanup at residential
locations identified as contaminated.
On January 18, 1994, the EPA proposed adding to the National
Priorities List (NPL) the Raymark property and other locations in
Stratford where Raymark's waste has come to be located and that
EPA determines pose a significant threat to public health. The
NPL is a listing of abandoned or uncontrolled hazardous waste
sites that the EPA deems potentially most harmful to public
health and the environment. Raymark was added to the NPL on
April 25, 1995.
As more sampling results were received, more residential areas
were added to the list of known Raymark waste locations; a number
of municipal areas with contamination were also found. The EPA
and CT DEP installed temporary protective measures on some
residential, commercial, and municipal properties. The measures
included sod, bark mulch, fences, and warning signs, to protect
the public from exposure to the Raymark contamination until a
permanent remedy was completed.
In September 1993, the EPA began the permanent cleanup of the '
first residential property. During the 1993, 1994, and 1995
construction seasons, the EPA continued to remove waste from
residential properties. EPA expects that the cleanup of 43
residential properties will be completed in the fall of 1995.
The excavated material from these residential properties (and
waste from the Wooster Junior High School) are being disposed of
on the Raymark Facility. These wastes, together with the waste
already existing on the Raymark Facility were the subject of the
EPA's Proposed Cleanup Plan.
A. Feasibility Study Alternatives
The objectives of the source control cleanup action are to: 1.
prevent the public from exposure to contaminated soil-waste
material through touching or accidentally ingesting or inhaling
it; 2. minimize contaminant leaching from the facility; and 3.
facilitate future re-use of the property.
Based on these objectives, EPA developed and evaluated five
alternatives to address the soil-waste material. The
alternatives that were evaluated in the FS are described briefly
below. The EPA's preferred alternative was described in a
Proposed Cleanup Plan issued in April 1995 and presented at the
open houses held on April 8 and 11. After the close of the
public comment period and consideration of comments from the
public, state, and local agencies, and the Potentially
Responsible Parties' representatives, the EPA selected the
alternative that would be implemented to address on-site source
-4-
-------
control. Summaries of the alternatives evaluated in the
Feasibility Study are presented in this section; a synopsis of
the Proposed Cleanup Plan is presented in Section I.E. A
description of the general reaction to the Proposed Cleanup Plan
is included in Section I.e. Section I.D. details the EPA's
selected cleanup plan.
The general response actions to clean up the Raymark facility
property that the EPA considered included: no action, which
serves as a comparative baseline; containment, which covers
contamination in such a way as to prevent exposure to the waste
and restrict its migration; off-site treatment of soil-waste
materials; and on-site treatment of the soil-waste. Based on
these general response actions, EPA identified five specific
alternatives evaluated in the FS:
1. No Action
2. Capping (the Proposed Cleanup Plan)
3. Capping with Limited Excavation
4. Off-site Treatment/Disposal
5. On-site Treatment with Thermal Desorption and
Solidification
The following section outlines the basic components of each
cleanup alternative analyzed in the Feasibility Study for the
Raymark Facility.
Alternative 1 No Action
Leave the facility as it is
Test groundwater and surface water
Visit and evaluate the facility every 5 years to review site
conditions
Alternative 2 Capping (EPA's Proposed Cleanup Plan)
Decontaminate and demolish all buildings
Use the residential and Wooster Middle School soil-waste and
some building debris to level the ground surface
Install a vapor control system beneath the cap to capture
potential gases
Construct a cap to prevent exposure to the contamination and
minimize water seepage into the soil-waste
Remove the highly concentrated pockets of liquid (solvent)
contamination from contact with groundwater
Implement groundwater and surface water monitoring, cap
maintenance, and restrictions on site use".
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Visit and evaluate the facility every 5 years to review site
conditions
Alternative 3 Capping with Limited Excavation
Decontaminate and demolish all buildings
Excavate soils with the highest levels of PCS contamination
and then treat and dispose of them off site (approximately
21,000 cubic yards)
Use the residential and Wooster Middle School soil-waste and
some building debris to level the ground surface
Install a vapor control system beneath the cap to capture
potential gases
Construct a cap to prevent exposure to the contamination and
minimize water seepage into the soil-waste
Remove highly concentrated pockets of liquid (solvent)
contamination from contact with groundwater
Implement groundwater and surface water monitoring, cap
maintenance, and restrictions on site use
Visit and evaluate the facility every 5 years to review site-
conditions
i
Alternative 4 Off-site Treatment/Disposal
Decontaminate and demolish all buildings
Excavate all contaminated soils above the water table
(approximately 330,000 cubic yards)
Transport the excavated soils and residential and Wooster
Middle School soil-waste off site to a disposal facility for
incineration, solidification, and/or landfilling
Remove the highly concentrated pockets of liquid (solvent)
contamination from contact with groundwater
Backfill excavation areas with new fill
Implement groundwater and surface water monitoring and
restrictions on site use
Visit and evaluate the facility every 5 years to review site
conditions
Alternative 5 On-site Treatment with Thermal
Desorption and Solidification
Decontaminate and demolish all buildings
Excavate all contaminated soils from above the water table
(approximately 330,000 cubic yards)
Heat the excavated contaminated soils and residential and
Wooster Middle School soil-waste, on site, to remove
solvents and PCBs
Solidify metals in the contaminated materials on site
Return treated materials to excavated areas
Remove the highly concentrated pockets of liquid (solvent)
contamination from contact with groundwater
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Implement groundwater and surface water monitoring and
restrictions on site use
« Visit and evaluate the facility every 5 years to review site
conditions
B. Proposed Cleanup Plan
EPA's Proposed Cleanup .Plan presented Alternative 2. Alternative
2 proposed to remediate the soil-waste historically buried on the
Raymark Facility and the soil-waste materials being excavated
from residential properties and the Wooster Junior High
School(approximately 70,000 cubic yards). The proposal was
divided into four principal components.
1. Decontaminate and Demolish Facility Buildings and Structures
All buildings and other structures on the facility would be
decontaminated and demolished. Contaminated building remains
would likely be removed from the property and appropriately "
disposed, while uncontaminated material could be used to level ^
the ground surface. Existing building foundations would be left
intact.
2. Remove the Highly Concentrated Pockets of Liquid (Solvent)
Contamination from Contact with Groundwater
Highly concentrated pockets of liquid contamination currently in
and around wells near the former acid neutralization pits and the
former toluene spill area appeared to serve as continuing sources
of contamination to the groundwater. These sources of
contamination would be removed to the reasonable extent possible.
3. Cover the Entire Facility with an Impermeable Cap
'A multi-layered barrier (cap) would be constructed over the
facility to prevent people from coming into contact with the
contaminated soil either by direct exposure (touching), by
incidental ingestion (accidentally eating), or by inhalation.
The cap would also minimize rain from infiltrating the
contaminated soil-waste material on the property and moving this
contamination into the groundwater.
The cap would collect water that could seep through the top layer
of the cap, but not into the waste, and discharge it into a storm
water drain. A piping system would be constructed to collect
solvent vapors that could potentially build up below the cap; the
vapors would be treated in an on-site emission control system.
Before the cap was constructed, the contaminated soil-waste
material from residential properties and the Wooster Middle
School would be used to level the ground surface.
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4. Ensure the Integrity of the Cap
Several restrictions would be necessary to protect the cap and
assess the cleanup's effectiveness. Cap maintenance would
include regular inspections to ensure the system is working as
designed. Formal restrictions on site use would prohibit
activities that could damage the cap. Quarterly groundwater and
surface water monitoring would determine the quality of the water
leaving the facility and the effectiveness of the chosen cleanup
plan. Every five years, EPA would review site conditions to
assess whether the cleanup action is working as planned.
As stated in the Feasibility Study, EPA will begin additional
studies to further evaluate the groundwater contamination, and at
the same time, the effectiveness of the chosen cleanup plan. The
additional information from existing and newly installed
groundwater monitoring wells would allow the EPA to identify
potential groundwater cleanup options in the future, if
necessary. If they are needed, these options would be presented
to the public for comment at a later date.
C. General Reaction to the Proposed Cleanup Plan *
As expressed by public comments, there is moderate support for
selection of the Proposed Cleanup Plan. Comments show increased
public support if the community (in particular, the Stratford
Health Department and the Stratford Citizens Advisory Counsel
(SCAC) has an active role in planning to reduce impacts from
building demolition and capping, construction scheduling and
public notification, and the future groundwater investigation.
Among those commenting on or testifying to a position of support
include the State of Connecticut, the Town of Stratford (the
First Councilman, the Director of the Health Department, and the
Town Manager), and the civic group, SCAC. Fifteen (15) people
expressed opposition to the proposed plan. A sizeable percentage
of the people who submitted written comments did not express any
obvious opinion on a cleanup alternative but did highlight
related and unrelated issues. A transcript of the public
hearing is included in Attachment B. A summary of the questions
and answers posed at the two open houses, where general support
was expressed, is included in Attachment C.
D. Selected Cleanup Plan
The EPA has selected Alternative 2 as its source control
approach. Implementation of Alternative 2 will address the
public health and facility re-use issues: by constructing a
permanent cap, the public will be protected from exposure
(through the skin, accidental ingestion, or inhalation) to the
contaminants on the facility and the amount of precipitation
leaching through the waste will be diminished. Facility re-use
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is addressed by coordinating the building demolition and capping
with the requirements of redevelopers.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The level of community concern about the Raymark soil-waste was
highest during the summer of 1993, after the Agency for Toxic
Substances and Disease Registry (ATSDR), a branch of the U. S.
Public Health Service, issued a health advisory. Federal and
state agencies stationed staff in Stratford to increase their
understanding of the scope and depth of residential, municipal,
and commercial properties that contained Raymark soil-waste.
Bankers and real estate agents clamored for answers that the
government did not have.
After months of waiting for the results of individual soil tests,
the scope of the contamination become evident. Eventually, EPA
determined that approximately 43 residential properties required
that the waste material be excavated. The excavation activities
began in the fall of 1993 and should be completed by the fall of
1995.
As a result of these activities, the themes that were prevalent
during the interviews for the Community Relations Plan (conducted
in the spring of 1994) included public health; economic concerns
(real estate values, local taxes, and impacts on economic
growth); nuisances (vermin, truck traffic); poor government
communications; and future use of the facility property.
Beginning in the spring of 1993 and throughout its activities in
Stratford, EPA has issued many public documents about the cleanup
and has hosted or co-sponsored numerous meetings with the public
to present information and listen to their concerns. A list of
the outreach efforts is presented in Attachment A.
III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA RESPONSES
The comment characterizations and EPA responses that follow are
divided into the following topic groupings: administrative;
legal; technical (construction impacts; cap; long-term
considerations including utility access and groundwater
monitoring; costs; off-site investigations including groundwater,
surface water and sediments; support for other alternatives; and
other considerations); and commenters posing many individual
comments.
A. ADMINISTRATIVE ISSUES
Comment: Several commenters requested that the EPA extend the
public comment period. An early, verbal request asked that the
original 30-day comment period be extended for 30 days, to June 8
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from May 8. Another did not specify an extension length; the
third requested a 90-day extension, to September 8. The basis
for the requests was the need to take additional time to review
the technical information available regarding the proposed
cleanup plan.
Response; The public comment period for the proposed cleanup plan
was extended to June 8, 1995 for a total of sixty (60) days. The
Agency has conducted an extensive community outreach program to
inform the public of the proposed cleanup plan that exceeds our
normal practice in complying with the public participation
requirements of CERCLA §113 (k) at the Raymark site. The typical
two to three hour public meeting to explain the results of the
Remedial Investigation/Feasibility Study/Proposed Plan was
expanded to two, four-hour "open houses." The open houses
included presentations with questions and answer sessions. EPA
personnel were also available to speak one-on-one with
individuals regarding the proposed cleanup plan. In addition,
the EPA held a Public Hearing as required by CERCLA §§ 113 and
117 on May 4, 1995.
EPA's position is that 60 days is sufficient time for an
interested party, attorney or environmental consultant to
identify the project's significant issues and articulate them in
writing for EPA's consideration.
B. LEGAL ISSUES
Comment; Raymark should pay for past and future cleanup costs
and be prosecuted. Future site users, rather than EPA, should
pay for the cleanup.
Response; The EPA is presently in negotiations with Raymark
regarding the recovery of costs associated with the cleanup of
Raymark's waste. The EPA is also negotiating with a potential
developer for the site to define the future owner's
responsibility. If the future owner has entered a prospective
purchaser agreement with EPA before it buys the property, the new
owner will not be responsible for cleanup costs unless the new
owner exacerbates or contributes to the contamination.
Comment: The commenter wants a hold harmless agreement between
the Town and EPA before transporting wastes from the Wooster
School to the Raymark Facility. The commenter does not want the
Town to become a third party and become liable. The commenter
wants EPA to indemnify the Town as well as residential property
owners against third party liability suits.
Response; This comment is not relevant to the Proposed Cleanup
Plan. This issue will be addressed by the Town, State, and EPA
independent of the remedy decision for the Raymark Facility.
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In January 1995, Regional Administrator John DeVillars stated
that EPA would take all necessary and appropriate action to
provide residents with protection from third party liability
suits, if Raymark were to bring any such actions.
Comment; Raytech Corporation denies any successor liabilities of
Raymark Industries. If Raytech is ever labeled by a court as
liable, the company will seek recourse against all entities that
were found to have Raymark fill.
Response: The EPA will not speculate as to the action Raytech
may take based on future unknown actions and events.
C. TECHNICAL ISSUES
1. Construction Impacts
Comment: Five years for the cleanup is too long.
Response; The Raymark Facility is a large parcel of land that
spans over 33 acres. To properly address the demolition of all
buildings, and to design and implement the clean-up of the
facility takes time. The 5 years referred to by the commenter
only applies to the alternatives that require extensive
excavation, treatment, or off-site disposal. The EPA plans to
complete building demolition and capping as set out in the
proposed cleanup plan by late spring, 1996.
Comment: The commenter wants EPA to establish cleanup
priorities, work standards, and schedules to complete discrete
tasks, carefully compare all contractor proposals, and institute
QA/QC procedures. The commenter also wants information to be
disseminated to the public through mechanisms like the
newsletter, the Stratford Environmental Update.
Response: The remediation of the Raymark Facility (demolition and
any subsequent construction activities) will have an established
set of goals and a schedule. Specifications will be developed
that direct the work activities. All procurement of contractors
and subcontractors will follow established government regulations
and procedures. The performance of all work activities will
comply with federal and state regulations that govern hazardous
waste site activities and environmental issues. Health and
safety plans will be developed to protect workers and nearby
communities and individuals.
Comment: The commenter is 'concerned about potential exposure to
fugitive dust during demolition. To ensure that no fugitive dust
is generated during demolition and cap installation, the site and
property perimeter should be monitored.
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Response; EPA is aware of the potential for fugitive dust
generation, as discussed in the Feasibility Study for each
remedial alternative. Measures will be taken to monitor and
abate fugitive emissions during the building demolition and
during cap construction.
The EPA will provide information to the public regarding the
proposed demolition and construction activities before and during
the construction period. Information will be provided through
newsletters, public meetings, and press releases. Residents and
individuals may also call the local EPA hotline number (203/380-
6034) and leave messages.
Comment: The Agency for Toxic Substances and Disease Registry
(ATSDR), the Connecticut Department of Health and Addiction
Services CTDPHAS), and Stratford Health Department should review
all health and safety plans prior to the commencement of any work
on the property with sufficient lead time to convene neighborhood
forums.
Response; EPA will consult with the health agencies as necessary j
to develop plans that are protective of public health and safety.
EPA will provide final health and safety plans to the health
agencies. EPA will work with Stratford's Health Department and
inform the community, especially those individuals nearest the
site about the site cleanup.
Before any construction work commences on-site, EPA will convene
neighborhood forums and continue to issue fact sheets, press
releases, and newsletters like the Stratford Environmental
Update. to keep all parties informed of the construction
activities.
Comment; The Stratford Citizens Advisory Council wants to review
design plans to ensure that all safety considerations to workers
as well as the public are included. These plans should also
include provision for communications with residents of the
affected areas and the town in general. Neighborhoods should be
notified of upcoming construction activities by leafleting so
they know when demolition will take place and during which hours.
Signs should be posted in and around the shopping center warning
parents to keep young children away from the area. EPA should
publish newspaper notices indicating specific dates and times
when work will be done, and indicate when conditions will be the
most critical. Notify Parent Teachers Associations of
surrounding schools about the schedule.
Response; EPA will provide final health and safety plans for
public review once they are completed. Appropriate signs will be
posted around the Raymark Facility informing people to keep off
of the property. EPA will work closely with the local Health
Department to disseminate information. The EPA will provide
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information to the public regarding the proposed demolition and
construction activities before and during the construction
period. Information will be provided through newsletters, fact
sheets, public meetings, and press releases. Residents and
individuals may also call the local EPA hotline number (203/380-
6034) and leave messages. EPA will respond to these messages
shortly thereafter.
Comment; EPA should commit to specific dates for demolition and
capping.
Response: EPA will commit to specific dates for the demolition
and capping when the work plans are finalized. EPA will notify
the Town and the public regarding the proposed construction
activities and dates in the same manner as EPA has been doing for
the last two years.
Comment: EPA should implement measures to contain all debris,
.including airborne debris.
Response: Appropriate measures will be taken to monitor air
quality and to prevent fugitive air emissions during all
demolition and construction activities. During building
demolition and subsequent construction, measures such as wetting
of materials and other appropriate engineering controls will be
employed to minimize dust problems that could affect the
surrounding community.
Comment: EPA should hire security guards to ensure that the
public is kept out of the facility.
Response; The Facility will be secured to minimize unauthorized
personnel from entering the facility. Security guards," fencing,
and other measures will be used to secure the site and prevent
trespassing.
Comment; EPA should have a lot of the work done during the night
to minimize public exposure.
Response: EPA recognizes that night time activities could be
disruptive to nearby residents. If night work is required,
nearby residents will be notified prior to the initiation of
activities. EPA will endeavor to minimize the impacts of the
construction on the surrounding community. EPA acknowledges that
there will be inconveniences as a result of the construction
activities.
2. Cap
Comment: The responsibility for long-term management of the site
after remediation needs to be determined.
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Response; The responsibilities for future upkeep of the cap will
be shared by the State and future site owners and will be defined
in the State Superfund Contract and any prospective purchaser
agreement.
Comment; If the soil is good enough to cap Raymark, why isn't it
good enough to leave at Wooster?
Response; The EPA will not use soil from the Wooster Junior High
School to cap the Raymark Facility. Rather, contaminated soil
and materials that originated from the Raymark Facility will be
consolidated back on the facility. A multi-layer cover system
will then be constructed over all the consolidated contaminated
materials to prevent possible human exposures. The cap would
also minimize infiltration that could leach contaminants into
groundwater.
Furthermore, one of the principle reasons for excavation of the
waste at Wooster School is to reduce the risks to children in a
recreational setting. The setting at Raymark is an
industrial/commercial area where recreation is limited.
Questions regarding the excavation of the Wooster School should
be directed to the Connecticut Department of Environmental
Protection at (203) 424-3705 .
Comment; By capping the 33 acres, more storm water runoff will
be entering Ferry Creek.
Response; Capping the 33 acres will not increase the existing
surface water runoff at the Facility. Much of the existing
property is already paved and the precipitation runoff currently
discharges to Ferry Creek. During construction, the existing
subsurface drains will be plugged to prevent any residual
contamination frdm discharging into Ferry Creek. Once the cap is
installed, only runoff from precipitation will be discharged.
This water will be directed to the storm water sewer through a
new clean network of drainage pipes unaffected by contamination.
In accordance with state reguirements, monitoring of the storm
water quality will be conducted by collecting runoff samples and
performing chemical analyses.
Comment; The clean fill brought to the site should be tested to
make sure it is clean. Who would do this testing and what
contaminants would you test for?
Response; The Facility already has a substantial amount of
material that will be used as fill to grade the site. The fill
brought to the Facility for cap construction will have to meet
the technical specifications as set out in the design for the cap
system and be tested to ensure that it is clean. All soil-waste
and fill materials will be covered by the cap system.
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EPA's contractor will test the fill to be used in the cap for a
variety of contaminants to ensure that it is clean.
3. Long-term Considerations Including Utility Access and
Monitoring
Comment: EPA should be sure that utilities are installed before
the cap is constructed to ease site re-development.
Response; The developer and their engineers are working on a plan
to install all necessary utilities in an enclosure that would not
be affected by either the proposed cap system or the existing
contaminated soil. The plan is to ensure that no contact with
contaminated soil occurs during installation of utilities or in
the future when utility modifications or repairs may be required.
Comment; Groundwater monitoring should be conducted more
frequently than every 5 years.
Response: After the remedy is constructed, initial monitoring
will be conducted on a quarterly basis each year (not every 5
years) to evaluate contaminant status in groundwater and to
determine whether contaminants are migrating off-site. Since
storm water runoff also discharges off-site to the storm sewer
system and ultimately to Ferry Creek, monitoring of this flow is
required by the State.
Comment: The EPA must address future utility services for the
main sewer line that cuts through the facility. There may be
exposure to contaminants when the pipe eventually requires
replacement in the future. The creation of a worker safety zone
is one suggestion that has and should be pursued.
Response: The EPA is currently discussing the sewer line issue
with the .Town of Stratford's Engineer and the developer.
Provisions will be made so that the sewer line can be serviced in
the future.
Comment; Who will be doing the groundwater testing on and off
the site? Who will be responsible for the cost? Can this
testing be done prior to the cap being put on or will it take
place after?
Response; EPA will be conducting the groundwater testing on and
off-site of the Raymark Facility to characterize the nature, rate
and extent of contamination. EPA will pay for the cost of the
groundwater investigation. The State will be responsible for
long-term monitoring of groundwater and will also be responsible
for periodic monitoring of the Facility property. This will be
defined by the Superfund State Contract that EPA enters into with
the State.
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The majority of the on-site and off-site groundwater monitoring
will be conducted after the installation of the cap system.
Comment; Who will be policing the new owners? Who will make
sure that they maintain the integrity of the cap? What penalties
would be implemented if they fail to maintain the cap? If the
deed is broken, who will be the responsible party? Who would
assume ownership of the property if the deed was broken? What
are the deed restrictions?
Response: The developer would share responsibility with the state
for monitoring and maintenance of the cap system. The
Prospective Purchaser Agreement will define the developer's
responsibilities for these activities. Any actions by the
developers or owners or lessees which violate the Prospective
Purchaser Agreement will be justification for EPA to invoke its
enforcement authority against these entities. Therefore, if the
deed is violated the owners and/or the lessees would be the
responsible parties. The owners of the property would still be
the owners of the property if they violated the deed
restrictions.
Institutional controls and/or deed restrictions will prevent
certain actions and activities from harming the cap system.
These issues will be resolved during the design phase of this
project.
4. Costs
Comment; Raymark should pay for the cleanup.
Response; EPA is negotiating with Raymark Industries, Inc. to
settle the cost Raymark will pay for EPA's clean up of the
Raymark Facility and other areas where Raymark's waste is posing
threats to public health and the environment.
Comment: The commenter does not understand how monitoring and
site visits can cost 15 percent of the total cost of Alternative
2.
Response; Because of the numerous contaminants identified in both
soil and groundwater underlying the Raymark Facility, it is
necessary to monitor changes in the contaminant status.
Therefore, a variety of analyses, which are costly, need to be
performed to properly assess.contaminant status. The facility
covers more than 33 acres, which means a large number of samples
are needed to monitor groundwater conditions. Initially,
monitoring will be conducted on a quarterly basis each year (not
every 5 years) to evaluate contaminant status in groundwater and
to determine whether contaminants are migrating off-site. Since
storm water runoff also discharges off-site to the storm sewer
system and ultimately to Ferry Creek, monitoring of this flow is
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required by the State. If it is determined that the contaminant
status varies only slightly between each quarterly monitoring
event, the monitoring frequency could be decreased which would
reduce the overall costs of monitoring. For the purpose of the
feasibility study (FS), quarterly monitoring was assumed to
determine what the costs would be to implement Alternative 2 over
30 years.
Comment; The commenter believes that the cost of the Proposed
Cleanup Plan is exorbitant, particularly based on governmental
inefficiencies.
Response: The estimated costs presented in the FS are derived
from available information sources including: costs for similar
types of.hazardous waste cleanups, vendor and treatment facility
quotations, and standard cost guides for construction activities.
These estimated costs also include engineering, health and
safety, and contingency factors. Because of the additional
health and safety needed during hazardous waste site cleanups,
costs are higher than other types of construction.
The costs in the FS were developed to allow the comparison of
different remedial alternatives. The actual cost of the
remediation will be dependent on the labor, materials, equipment,
fuel, utility costs, interest rates, and other factors when
construction is implemented.
Comment: Who will pay for the Proposed Cleanup Plan? The
developer should pick up the tab for some of the cleanup costs.
Response: The cost for the planned clean-up of the Raymark
.Facility will be paid for initially by the EPA's Superfund with
contributions from the state. The EPA will pursue cost recovery
from potentially responsible parties (PRPs) including Raymark.
The developer will not be responsible for the cleanup costs of
the site.
5. Off-Site Investigations
Comment; The commenter is concerned about contamination in Ferry
Creek and how it may affect the long-range development of
Stratford's waterfront. The commenter thinks that the property
below the high water mark belongs to the State of Connecticut.
Response; EPA is currently investigating the surface water and
sediments in Ferry Creek and other areas in Stratford. The
sampling is being performed to ascertain whether contaminants are
present in the water and sediments of Ferry Creek. At the
conclusion of the investigation, EPA will present to the public
the results of the studies and propose a cleanup plan to address
the contamination problem. EPA's goal is to have a proposed
cleanup plan by.late summer, 1996, for the Ferry Creek area.
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Comment; The commenter believes that it is imperative that some
assurances be given to the Town that the groundwater migrating
off-site of the Raymark property be thoroughly addressed. The
commenter is unaware of how far the plume of contamination has
advanced, a situation that poses public safety issues. Several
years ago a foundation caught fire during an excavation project.
Toluene found in the groundwater seeping into the construction
area was thought to be the cause of the fire. The commenter is
concerned about the safety of workers and neighboring residents.
Response; A groundwater study will be conducted to better define
the extent of contamination, whether contaminants are migrating,
and whether humans and the environment are at risk. EPA's goal
is to present the results of this investigation and propose a
cleanup plan to the public in December 1997. The implementation
of any alternative to address the Raymark Facility will not
interfere with any subsequent groundwater response actions. In
addition, results of an area wide study found that no .one is
drinking groundwater downgradient of the Raymark Facility and the
aquifer is classified as not suitable for drinking without
treatment. Therefore, since no one currently drinks the
groundwater in the vicinity of the Raymark Facility, the risks to,
public health are significantly reduced from any potential
groundwater contamination migrating off-site.
Comment; The Housatonic River and the Sound should be tested
before and after the remediation is done.
Response; The EPA has sampled the Housatonic River as well as
Ferry Creek. The EPA is presently investigating the
contamination in Ferry Creek and other ecological areas in
Stratford. Depending on the results of this study, EPA may
sample Long Island Sound. After the remedy is completed at the
Raymark Facility, monitoring of the groundwater and surface water
will be conducted.
Comment; Wells should be established along Ferry Blvd. and
between Raymark and the Housatonic River north of Ferry Creek.
Response; Off-site monitoring wells will be installed as part of
the planned groundwater investigation, and contaminant migration
from the Raymark Facility will be assessed for impacts to
downgradient areas. If a well situated on Ferry Boulevard
supports the groundwater investigation, then that location will
be considered for the study.
Comment: The commenter favors the removal of chemicals before
they pollute the Housatonic River, Ferry Creek, and Long Island
Sound, and ruin waterfront development and scare away potential
developers who might have to underwrite an expensive cleanup of
migrating Raymark contamination.
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Response: EPA is investigating the surface water and sediments in
the Stratford Area. Sampling is being conducted in Ferry Creek.
EPA's goal is to present the results of this investigation and
propose a cleanup plan of the Ferry Creek area to the public in
late summer, 1996. In addition, the groundwater migrating from
the Raymark Facility property will be studied and a proposed
cleanup plan is anticipated to be presented to the public in
December, 1997.
EPA has a policy which states that where hazardous substances
have come to be located on or in a property solely as a result of
subsurface migration in an aquifer from a source of contamination
outside the property, EPA will not require the property owner to
cleanup the property. Therefore, developers do not have to pay
for the cleanup of contaminated groundwater migrating onto their
property.
6. Support for Other Alternatives
Comment; Raymark should purchase land in the Nevada desert and
pay property taxes on it. Raymark waste should be packaged and
sent there, an area without a large population, water mass, or
food chain.
Response: It is virtually impossible to send contaminated
materials to any other parts of the country without affecting
other human populations or the environment. Furthermore, EPA has
no legal authority to require Raymark to purchase land in the
Nevada desert.
Addressing the contamination where it is currently located
protects human health and the environment. The threats posed by
the contaminated.materials are through exposures such as
inhalation, accidental ingestion, or skin contact. These
exposures can be eliminated by isolating the contamination from
'potential human contact, such as through capping, or through the
removal of contaminants. The net public health protection of
capping all soils in place "is comparable to excavating all
materials and sending them off-site.
EPA prefers Alternative No. 2, capping, since it offers the best
combination of protecting human health in the short and long- .
term, can be completed within a relatively short time period, is
economically feasible and implementable, and would result in less
disturbance to nearby individuals during implementation.
Comment: The commenter supports Alternative 3. Even though
Alternative 3 may take an .extra 6 months.or a year to complete,
it would make the site safer in 'the long term.
Response; Alternative No. 3 would provide only a marginal
increase in protectiveness because over sixty (60) different
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contaminants would remain in place. Combined with the increased
short-term risks inherent in excavating hazardous wastes, the net
reduction in overall risks to human health is negligible.
Furthermore, capping of the contaminated site soils or capping of
the site with several areas excavated would afford the same level
of protection since there would essentially be no contact with
any contaminated materials.
Comment; The commenter supports Alternative 5. No other area
should be burdened with Raymark's problem.
Response; As indicated in the previous responses, Alternative No.
2 offers the best combination of protecting human health in the
long and short-term. It can be completed within a relatively
short time period, is economically feasible and implementable,
and would result in less disturbance to nearby residents and
property owners during implementation. Alternative No. 5 has
many technical, timing, and community impacts associated with it
that make this alternative extremely difficult to implement as
well as potentially increasing risks from exposure to
contaminants. As soon as the site is capped, threats to the
public health will be mitigated.
Comment; The commenter supports Alternative 4 since it would b'e
more cost-effective in the future and would stop groundwater
contamination. The lagoons should be dredged and the topography
should be restored, and area ponds should be cleaned.
Responset Alternative 4 calls for the off-site disposal of all
contaminated materials above the water table. This Alternative
is probably the most difficult option to implement because of the
volume of wastes to be excavated, the time required to clean-up
and restore the site topography, the potential threats that may
be incurred during excavation and transport, and the cost of the
remediation. In addition, it may be difficult to locate
sufficient off-site treatment and disposal facilities to
accommodate the volume of contaminated material. This
alternative would also take the longest time to complete, which
entails more impacts to the local community. In addition,
Alternative 4 does not entail digging up contaminated materials
below the water table approximately 150,00 cubic yards of
waste. Therefore, Alternative 4 would not entirely eliminate
groundwater contamination.
Although there are many groundwater monitoring wells on Raymark's
property indicating that the groundwater is contaminated, there
are no groundwater monitoring wells off-site to characterize the
groundwater. Furthermore, there are nearby facilities other than
Raymark that are also contributing to groundwater contamination.
A separate groundwater study will be conducted to define the
extent of groundwater contamination and risks posed to human
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health and the environment. At the conclusion of the study, EPA
will propose to the public a cleanup plan.
The last series of visible lagoons have all been temporarily
closed. Raymark's entire property, including the lagoons, will
be permanently capped and graded as part of the cleanup plan.
EPA is sampling selected ponds as part of its surface water and
sediment sampling program in the Stratford area under a separate
investigation. The sampling is being performed to ascertain
whether contaminants are present at these locations. If
contamination 'is identified, it will be assessed to determine any
potential human health and ecological risks and whether
remediation is required. The public will be involved in this
process.
Comment; The commenter supports Alternative No. 5.
Contamination should be removed because: capping is not a long-
term solution; capping may not be effective; and paving for a
shopping center is not assured. The commenter supports
Alternative No. 4 as a second choice.
Response: As indicated in the previous responses, EPA prefers
Alternative No. 2, capping, since it offers the best combination
of protecting human health in the short and long-term, can be -
completed within a relatively short time period, is economically
feasible and implementable, and would result in less disturbance
of highly contaminated material and possible threats to nearby
individuals during implementation of the remedy. With proper
maintenance and restrictions on use of the property, the cap is a
permanent remedy. The responsibilities for future upkeep of the
cap will be shared by the State and future site owners and will
be defined in the State Superfund Contract.and any prospective
purchaser agreement.
The health risks posed by the contaminated soil and material
occur only if there is an exposure (such as through inhalation,
accidental ingestion, or through direct contact) to waste at
concentrations that could pose a threat. The cap effectively
prevents exposure to these contaminants. If the site is to be
reused by a developer, the cap will be under the building
foundations and pavement. This will decrease weathering and
exposure of the cap, thus further protecting and ultimately
prolonging the cap's life.
Under Alternative No. 2, the overall status of the site and the
effectiveness of the cap will be re-visited every five years. In
addition, the groundwater at the site will be monitored four
times per year. Actions would be taken to remedy problems, if
any are identified. These 5-year reviews would be conducted in
addition to the periodic monitoring and maintenance that will be
required.
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Comment; The commenter wants all contamination taken away, above
and below the waterline. If it is not, the commenter believes
that monitoring may fail since there is no guarantee of
government funding forever. Groundwater will continue to be
contaminated. The cap has no guarantee of lasting forever.
EPA should spend $2 to $3 billion and up to ten more years to
clean up the site if that's what it takes to thoroughly clean the
property.
Another commenter favors removal of PCBs and toxins from the site
and clean up of the site today, while there are still funds
available in the Superfund.
Response; EPA prefers Alternative No. 2, capping, since it
offers the best combination of protecting human health in the
short and long-term, can be completed within a relatively short
time period, is economically feasible and implementable, and
would result in less disturbance of highly contaminated material
and possible threats to nearby individuals during implementation
of the remedy. The excavation and off-site disposal may create
more problems than may be solved. Capping is a permanent
solution provided that there is periodic maintenance and it
affords a level of long-term protection appropriate to the future
re-use of the property.
The responsibility for performing the long-term monitoring and
maintenance of the cap lie with the State and the developer as
set out in previous responses. Also, any developer of the
property would have to sign a prospective purchaser agreement
that addresses their responsibilities. These measures will
ensure the integrity of the cap.
One component of the preferred alternative is that the overall
status of the site and the effectiveness of the cap will be re-
visited every five years. Actions would be taken to remedy
problems, if any are identified. As indicated in previous
Responses, these 5-year reviews will be conducted in addition to
the periodic monitoring and maintenance requirements.
The EPA must select remedies that are cost-effective pursuant to
the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP). The expenditure of funds in excess of what is
necessary to protect human health and the environment which
affords little or no added protection is an unwarranted
disbursement of government monies.
Comment; The commenter stated that Alternatives No. 3 through 5
would entail the moving of contamination which may pose a health
risk, and that off-site treatment is too expensive. The
commenter also felt that the developer's proposal protects the
cap.
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Response: The comments raised by the commenter are some of the
important tenets that supported EPA's selection of Alternative
No. 2 as the preferred cleanup option.
7. Other Considerations
Comment: The commenter asks whether EPA's Proposed Cleanup Plan
'includes remediation of Raybestos Memorial Field? If so, what
will happen to the memorial to honor the veterans of WWII, a
boulder at the entrance of the field.
Response: EPA's Proposed Cleanup Plan only addresses the Raymark
Facility, and will not affect the Raybestos Memorial Field or the
memorial. The EPA installed a soil cover over Raybestos Memorial
Field in 1992 and 1993 to abate imminent threats. Any future
actions on the site will endeavor to accommodate the memorial.
Comment: What contingency exists to deal with residential or
municipal sites that are discovered after the cap is constructed?
Response: If new sites are identified and/or discovered that pose
unacceptable risks to human health and the environment after the
cap is constructed, the EPA and/or CT DEP will address these
sites through other mechanisms.
Comment: The commenter feels that the community may want to use
the site for open space.
Response: One of the remediation objectives is that after
remediation is completed, the site will be permanently safe for
its intended use. Since this part of Stratford is zoned for
commercial and industrial use, this.would be the most realistic
goal for future land use. Questions regarding the future .use of
this site should be directed to the town manager, town council,
and the zoning board.
Comment: The commenter requests a response to his letter of
April 13, 1995, concerning Ferry Creek.
Response; All comments submitted during the public comment period
will be addressed in this Responsiveness Summary. Individual
letters of response will not be written to each commenter.
Comment; The 24 volumes that take up a whole wall of the
Stratford library contain no answers to the public's questions.
There is no information in those 24 volumes from the Stratford
Health Department survey or the health effects study funded by
the Agency for Toxic Substances and Disease Registry (ATSDR).
The library contains no information on the lead screening program
or the Stratford Public Works screening program.
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Response; The administrative record which contains 24 volumes of
information is only meant to address the investigation and
planned remediation of the Raymark Facility and was not meant to
address studies performed for other purposes. Questions
regarding the health studies (i.e. evaluation of cancer
incidence, and lead screening program) should to be directed to
the Connecticut Department of Public Health and Addictive
Services (CTDPHAS) and the Stratford Health Department.
The Stratford Health Department has placed all of the fact sheets
and newsletters on environmental health activities in the
reference 'section of the Stratford Library. The CTDPHAS is
currently drafting a public health assessment of the Raymark
Industries, Inc. Site. This Public Health Assessment will
include summaries of all of the health activities that have
occurred in Stratford. The CTDPHAS plans to release the draft
Health Assessment for public comment in late summer, 1995.
Comment; The Community Relations Plan (CRP) mis-characterized
the Town. How much did the CRP cost?
Response; Information regarding the Town came from the 1990
Census and from interviews. A CRP attempts to characterize the
concerns of a community affected by the presence of a hazardous
waste site. As activities progress that address the
contamination, as well as the community's concerns about those
actions, the document is reviewed to determine whether conditions
have changed sufficiently to warrant updating the plan.
Suggestions for changes or additions to plan are welcome.
The EPA has spent approximately $50,000 on community outreach
which includes a variety of tasks such as the issuance of
numerous newsletters, to the Stratford community, fact sheets,
public meetings, and the preparation of the CRP. The approximate
cost of the CRP was $3,000.
Comment t The commenter expressed a desire that the spirit of
cooperation among the interested parties experienced to date be
carried through to the remediation.
Response; EPA concurs completely in maintaining the spirit of
cooperation that has existed throughout this project.
Comment; The commenter wanted to know whether the lead content
of soil-waste discussed in the Proposed Cleanup Plan was a total
count or TCLBs [TCLP]?
Response; The lead concentrations in the soils and waste
materials were analyzed for total lead presence. A separate TCLP
analysis was performed on other samples to determine whether the
contaminated materials are a hazardous waste.
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Comment; How did EPA determine where Raymark had deposited its
waste? How would anyone know if their property had Raymark's
waste deposited on it?
Response; Locations of where Raymark's wastes were used as fill
materials in the Town of Stratford were determined through a
variety of sources including: Raymark, historical town records,
visual observations, chemical analyses, geophysical tools, aerial
photographs, and by interviews with a variety of people including
past employees of Raymark residents local officials and
the town historian.
Comment; The commenter is concerned about the re-opening of the
Wooster School playing fields.
Response; Issues relating to the Wooster School should be
addressed to the Connecticut Department of Environmental
Protection and the local Health Department. CT DEP is
responsible for the excavation of Raymark7s waste and restoration
of the school's playing fields. The local Health Department will
work with the CT DEP and other' agencies to ensure that the fields
at the Wooster School are safe when re-opened.
Comment: One commenter submitted three sets of documents
regarding construction management strategies for the upcoming
demolition at the Raymark Facility and how he could be of
assistance.
Response; EPA appreciates the recommendations this commenter made
and will consider them as the project proceeds.
D. COMMENTERS POSING MANY INDIVIDUAL COMMENTS
1. The State of Connecticut
The State is in favor of the cleanup approach as set out in
Alternative No. 2 and offers the following comments:
Comment: The State does not consider the proposed approach to
address the non-aqueous phase liquids (NAPLs) to be an
appropriate level of effort. NAPL recovery in the vicinity of
the toluene spill and the former acid pit areas (MW-J and MW-V
well clusters) should be conducted using wells specifically
designed for extraction of these contaminants. The areal extent
of the NAPLs should be delineated, and wells and other
engineering features to address the NAPL should be incorporated
into cap system design. Engineering devices to address the NAPLs
should be consistent with re-use of the Site.
Response: NAPL recovery will be attempted in at least two areas
of the Raymark Facility: in the former acid pit areas (MW-J
cluster) and in the toluene spill area (MW-V area).
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To further evaluate the extent and to quickly initiate removal,
NAPLs will be measured and removed from the two (2) existing on-
site monitoring well clusters. These remedial design activities
will be used to evaluate how quickly or not the NAPL recovers in
the existing wells. If NAPL recovery is minimal, then further
evaluation of the feasibility of NAPL removal will be required.
If the NAPL removal yields substantial quantities and NAPL
recovery from the existing wells is rapid, this approach will be
continued until which time the existing monitoring wells will
need to be decommissioned because of the building
demolition/capping activities. New wells, more specifically
designed for NAPL removal, will be installed, if and to the
extent practicable, prior to cap installation and incorporated
into the cap design in order to continue with the mass removal of
NAPL. Engineering devices designed for NAPL recovery will be
integrated into the cleanup design so as to not impede future
site re-development.
Comment; Several regulations should also have been identified as
ARARs in the FS report.
1. Connecticut Coastal Management regulations (22a-90
through 22a-112, CGS inclusive). EPA needs to make a
formal consistency review.
2. Asbestos Abatement regulations (19a-332a-l through 19a-
332a-16 RCSA).
3. Asbestos Licensing and Training regulations (19a-332a-
17 through 19a-332a-23 RCSA).
Response: 1. The EPA concurs that these regulations are ARARs.
2. These regulations will be complied with in the demolition of
the buildings, and during the disposal and handling of asbestos-
containing materials.
3. These regulations are mandatory for any contractors and
subcontractors that will be engaged in remediation efforts
involving asbestos abatement. ARARs are meant to identify
regulations that are directly invoked as the result of specific
actions to be taken at a site.
2. The Town of Stratford
The Town of Stratford supports the Proposed Cleanup Plan.
Several specific concerns were noted:
Comment; The public is concerned about contaminant migration
from the Raymark Facility via groundwater. EPA should install
off-site monitoring wells and collect off-site groundwater
samples to determine if the groundwater poses any problems.
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Response; The EPA will be conducting a groundwater investigation
to determine the nature, rate, and extent of contamination that
includes the installation of off-site groundwater monitoring
wells and sampling. The study will evaluate risks posed by the
contamination. EPA plans to propose a cleanup plan for the
groundwater to public in late 1997.
Comment; The Town supports NAPL removal since this is the first
step to addressing a larger groundwater contamination issue.
Response; The NAPL removal will commence as quickly as possible.
All practical efforts will be made to remove NAPL.
Comment; Slip-lining, abandonment,- and re-routing are not
feasible options to address the sanitary sewer that traverses the
Raymark Facility. Since the sewer line will have to be replaced
some day, the cap's integrity and the health of utility workers
is in question. A worker safety zone should be created around
the line to provide workers with unencumbered access.
Response; EPA is discussing this issue with the Town. Slip-
lining is a viable method for extending the useful life of the
pipe. The liner can be made of PVC, which has good corrosion
resistance properties and would be resistant to the corrosive
liquids typically found in sewer lines. Abandonment and re-
routing may be possible, but additional evaluations are
necessary. The creation of a worker safety zone may also be
feasible.
Comment; The Town urges EPA to provide state and local officials
time to review demolition, cap engineering and health and safety
plans. The Town also urges the EPA to meet with these officials
periodically to discuss the status of the site. The Town is
pleased by the level of cooperation to date.
Response; EPA will consult with the health agencies as necessary
to develop plans that are protective of public health and safety.
EPA will provide final health and safety plans to the health
agencies. EPA will work with Stratford's Health Department and
inform the community, especially those individuals nearest the
site about the site cleanup.
Comment; The Town supports establishment of on-site and
perimeter air sampling units. The Town also wants on-site
security to prevent unauthorized personnel from entering
Raymark's property.
Response; Air monitoring will be conducted on-site and at the
perimeter to ensure that fugitive emissions are properly
controlled and that the public and workers are protected. Site
security will be maintained twenty-four hours per day to prevent
trespassing and unauthorized entry into work areas.
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Comment; The Town is in support of the continued communications
with the public through the Environmental Update, and
participation in neighborhood forums and periodic official
briefings that include citizens groups such as SCAC.
Response; The EPA will continue to keep the public, the Town, and
the State informed on all aspects of the site remediation. The
EPA endeavors to accurately communicate information on all
aspects of the cleanup activities on-going in Stratford.
3. Ravmark Industries. Inc.
Raymark Industries, Inc. does not support the Proposed Cleanup
Plan and offers the following comments:
Comment; The scientific data for the Facility and the Town of
Stratford does not support the Proposed Cleanup Plan.
Response: EPA has compiled sufficient data with which to select a
remedy, pursuant to the requirements of the NCP and CERCLA.
Using field and analytical data contained in a site wide
environmental investigation report (known as a RCRA Facility
Investigation or RFI) developed by Raymark and its contractor,
Environmental Laboratories, Inc., EPA prepared a detailed
Remedial Investigation (RI) report. The RFI was overseen by EPA
where samples were split and the data were validated and checked
for accuracy. The RI assessed the types and extent of
contamination present at the facility, how contaminants may
migrate into groundwater and off-site, and developed a risk
assessment that quantified the potential risks associated with
exposures to contaminated materials.
Comment; "... [T]he Agency formulated... several proactive
alternatives ranging in cost from $110 million to $1 billion...
this range is so wide [that it] tends to indicate the inability
of EPA to tie the potential remedies to any concrete scientific
data."
Response; The formulation of a range of alternatives reflects
consistency with the NCP, which indicates the FS should evaluate
various options that protect human health and the environment.
The FS evaluated options for containment (Alternatives 2 and 3
for capping, $40 million and $110 million, respectively),
treatment (Alternative 5 for thermal desbrption and
solidification, $330 million), and off-site treatment and
disposal (Alternative 4, $1 billion), and No Action (Alternative
1,. $6 million). The costs of the various cleanup options do vary
over a wide range. This is the result of evaluating different
cleanup options. When the costs of these different cleanup
options are combined with the tremendous volume of contaminated
soil and waste caused by Raymark during its operating period, the
cleanup options become very expensive.
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Comment; EPA refuses to address the lack of data to support the
addition of Raymark to the National Priorities List (NPL) and the
Proposed Cleanup Plan.
Response; Regarding the lack of data to include Raymark on the
NPL, the EPA did address this concern when EPA added Raymark to
NPL. The NPL is intended to be a "rough list11 of prioritized
hazardous waste sites; a "first step in a process nothing
more, nothing less" Eaale Picher Indus, v. EPA. 759 F.2d 922, 932
(DC Cir. 1985) (Eagle Picher II). As described above, the
information from the Remedial Investigation (RI) and the
Feasibility Study (FS) do support the need to cleanup Raymark's
property.
For further information regarding the addition of Raymark to the
NPL, please refer to EPA's response to comments raised during the
public comment period for the proposing of Raymark to the NPL.
Comment; The lead in the waste does not leach unless exposed to
acidic conditions with a pH of less than four.
Response; All metals leach from soils in the presence of water aa
the result of ionic processes; leaching at a low pH values is
more pronounced. Raymark used acids in its manufacturing process
and disposed of the acids on the ground. The low pH conditions
at Raymark facilitate leaching and transport of metals. Metals
will not leach if there is no infiltration by precipitation. The
capping system described in the Proposed Plan would address the
leaching of metals to groundwater.
Comment; Dioxins are considered isolated and are not
statistically significant.
Response; Dioxins were not detected as frequently as other
contaminants, but nonetheless dioxins are very toxic and do pose
risks to human health and the environment.
Comment: PCBs are not mobile, unless in the presence of
solvents.
Response; PCBs were detected in soils throughout the Facility's
subsurface. Several areas have been identified as containing
solvents where PCBs are present in the groundwater. It is likely
that the PCBs were mobilized by these solvents. The solvents may
not remain in discrete locations indefinitely and can migrate,
thus potentially mobilizing PCBs in other locations.
PCBs do adhere to soil particles. Once exposed to ambient air,
PCB-laden soils, without a cap in place, may be airborne through
fugitive dust emissions thereby posing potential health risks to
on-site workers and the public. Therefore, even in the absence
of solvents, PCBs can migrate through another pathway.
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Comment; Asbestos is not free to the atmosphere, based on air
data collected on and off the Facility.
Response; Air sampling was conducted by Raymark during the
closure of the lagoons and during drilling to monitor potential
worker exposures. The results do indicate that airborne asbestos
was generated as the result of intrusive activities. However,
the concentration of asbestos that was detected was below levels
of concern. Any future use of the Facility without remediation
could cause asbestos migration.
During remediation, all measures will be taken to monitor and
abate-fugitive emissions.
Comment; There are no users of private wells within 4 miles of
the Facility. Therefore, groundwater is an incomplete exposure
pathway because no population would be exposed to the
groundwater.
Response; Current searches by the CT DEP have not identified any
public wells within 1 mile of the Facility. One private well was
discovered uparadient of the Raymark Facility within one mile of t
the Facility. However, the ultimate discharge of groundwater has
not been identified and there may be human populations or
environmental receptors at risk.
Comment; Shellfish has been tested by the State and found not to
be contaminated.
Response; EPA is continuing to study Ferry Creek, the Housatonic
River and other ecological areas. The results of these studies
have not been finalized. EPA plans to propose a cleanup plan of
these areas in the late summer of 1996.
Because Raymark discharged process waters into lagoons that
ultimately discharged into Ferry Creek, it is of.concern that
much of Ferry Creek has been contaminated. Contaminated
sediments in the stream bed are likely to be transported
downstream into the Housatonic River and may possibly affect the
shell fish beds. While no effects of contamination have been
observed, it is possible that past disposal and discharges by
Raymark have affected Ferry Creek, and may eventually affect the
Housatonic River.
Comment: "... [E]pidemiological analysis of CT Health Department
data shows that town-wide cancer rates are within normal
incidents of cancer experienced on a state-wide basis and ...
that the Stratford community has not suffered rates of cancer
greater than that of any town in Connecticut of equal size." The
comment indicates that no further action is needed since no
health problems have been identified to date.
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Response; Actual evidence of health problems are not a pre-
requisite for placing a site on the NPL or for EPA to abate
health threats. EPA can determine that there is a significant
threat to human health without cancer studies. To wait for
health effects to be clearly evident (which could take many
years) would be a grievous transgression of the EPA's mission to
protect public health.
Comment: The Agency has never determined that the Facility and
Satellite Sites pose a significant threat to public health. The
EPA has no basis for concluding that the Raymark Facility poses a
significant threat to public health.
Response; EPA completed a risk assessment in early April 1995
(provided to the public on April 8, 1995) for the Raymark
Facility that concluded the soil-waste materials underlying the
facility did pose risks under current and future land use
scenarios. The risk assessment was developed by EPA following
documented procedures, using realistic exposure scenarios, and
analytical results provided by Raymark.(and Raymark7s
contractors). The ATSDR Health Advisory was prepared to identify
threats to residences that had fill materials from the Raymark
Facility, and concluded the fill materials do pose threats.
These assessments formed the basis for concluding that the waste
materials and contamination generated by Raymark do pose threats
to the public.
Comment; A risk assessment for the Facility and Satellites has
never been completed. Raymark completed a partial risk
assessment that addressed workers in a utility trench scenario.
It is the only scenario in which any risk to human health has
been shown.
Response; The EPA prepared a risk assessment based on the future
land use of the property including scenarios for the worker in
different parts of the facility and in the sewer trench. In
addition, trespasser exposure scenarios were evaluated.
Collectively, the results do indicate potential risks to human
health.
Comment; Trespassing at the Facility, is highly unlikely because
of the barriers surrounding and inside the Facility, and should
not be used in assessing risk.
Response: The EPA's risk assessment for future land use assumes
that there are no barriers to prevent trespassers from entering
the site. Before EPA became actively involved in the site,
trespassing was very common on Raymark's property.
Comment; The potential pathways identified in the ATSDR health
advisory are all hypothetical. In fact, the advisory indicated
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that "no health hazard is currently posed" by the presence of
dioxins on the Facility.
Response; EPA considers the dioxins and up to sixty other
contaminants at the Raymark Facility to pose future risks to
human health. As indicated in the Response above, the results of
the risk assessment do indicate potential risks to human health.
Comment; EPA has refused to identify the specific sites around
Stratford where Raymark waste was or is located.
Response; This issue was discussed in EPA's addition of Raymark
to the NPL. This comment is not germane to EPA's Proposed
Cleanup Plan.
Comment; Government contractor estimates for demolition are
nearly three times the estimate prepared by Raymark for the same
work. Such demolition costs were not taken into account in the
Proposed Cleanup Plan.
Response; At the time the FS was prepared, EPA requested of
Raymark the basis for their demolition cost estimate. This
information was not forthcoming. EPA was only told that all
demolition could be performed for approximately $10 million.
Raymark did provide a rough breakdown of the costs of the
building demolition, but the information provided to the EPA did
not contain a sufficient amount of documentation to verify
Raymark's estimate.
In addition, EPA and its contractors did not have access to all
the buildings in order to survey the structures and to verify
Raymark's estimate. However, Raymark's demolition cost was used
in the FS uniformly in all alternatives. According to the NCP,
the purpose of the FS estimates is to compare the relative costs
for different alternatives, within an accuracy of +50 to -30
percent. Demolition estimates have not been finalized by EPA's
contractor at this time.
Comment; The Agency has refused to consider the redevelopment of
the property after remediation. EPA never considered the
probable uses of the site.
Response; EPA has considered the re-development of the property
after remediation throughout the RI/FS process. The probable
uses of the Facility were considered in the EPA's risk assessment
future land use scenarios. EPA has facilitated numerous
discussions between the developer and the remediation contractor
to ensure that scheduling, design, and construction issues are
properly integrated and implemented.
Comment; The Proposed Cleanup Plan encompasses the excavation of
various, unspecified Satellite Sites.
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Response; The Proposed Plan does not encompass the excavation of
various, unspecified Satellite Sites. The Plan is meant to
address the contaminated materials present at the Facility and
off-site contaminated materials, which originated from Raymark
and will be consolidated back to the Facility. The Proposed
Cleanup Plan does state that soils removed from some of the
satellite sites would be consolidated back at the Facility and
addressed under the proposed capping option.
Comment: The excavation at the Satellite Sites includes removal
of all waste, even that below the water table, despite the health
advisory's recommendation that only the upper three to four
inches needed to be removed.
Response; The excavation of Raymark's waste from residential
properties generally does not include excavating waste from below
the water table. In order to permanently cleanup the residential
properties, the waste is excavated so that future residential
uses will not pose risks to human health.
Comment; The Proposed Cleanup Plan acknowledges that wastes at
the Facility and satellite sites do not require removal or on-
site treatment, except in certain, unspecified, areas.
Therefore, the removal of wastes from the Satellite Sites may not
have been warranted.
Response; The ATSDR Health Advisory recommended the dissociation
of residents from the contaminated fill materials. Excavation
and removal has been proceeding through the on-going removal
process to protect the health of residents. Based on the results
of the Risk Assessment and the RI for materials at the Raymark
Facility, under a future commercial/industrial land use scenario,
where less exposure than a residential setting is likely, the FS
determined that remedial options are available to protect human
health and the environment without soil treatment or removal at
the Facility.
Comment; The proposed double layer cap is underlain by a
drainage system. However, the existing pavement reduces
infiltration, and a less costly cap is appropriate.
Response; The integrity of the existing pavement as a component
of the cap is questionable. The current pavement is in disrepair
with many potholes. Therefore, the existing pavement provides
limited infiltration reduction capabilities. The multi-layer cap
is to be constructed above all waste fill materials.
Comment; Installation of vapor extraction system may be
appropriate for solvent-contaminated areas. Installing such an
expensive system may be costly if done early in the process. To
avoid unnecessary costs, the vapor extraction system should be
completed in conjunction with the end user of the property.
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Response; The EPA has already initiated the coordination of
possible remedial construction requirements with the developer's
engineer to ensure that all remediation and future development
needs are properly integrated. The design and installation of
the vapor extraction system will accommodate the future use of
the site.
Comment; The EPA plans to install additional wells and complete
additional studies. These costs are not included in the Proposed
Cleanup Plan.
Response; The cost for replacing some of the existing monitoring
wells is included in the remedial alternatives cost estimate. As
clearly indicated in the FS and the Proposed Cleanup Plan, a
separate study for grpundwater will be conducted. Those
investigation costs are not included in the Proposed Cleanup
Plan.
For more information on the .off-site groundwater study, the
commenter is referred to EPA's Responses in Section E, Off-site "
Investigations, of this document.
Comment; The EPA has not addressed Raymark's arguments. The EPA
has postponed addressing these arguments "... until an
unspecified later point in time. That time is now." EPA never
completed a "... full risk assessment or NPL study. Numerous
aspects of the Proposed Plan ... remain questionable and could be
addressed in a much more cost-efficient manner."
Response; The EPA has addressed all of Raymark's comments. EPA
included Raymark on the NPL pursuant to the regulations in the
NCP. Furthermore, EPA did perform a complete risk assessment of
the Raymark Facility that identified risks to human health.
Based on the information contained in the RI and FS, the Proposed
Cleanup Plan is a cost-efficient mechanism to cleanup the Raymark
'Facility and facilitate re-use of the property.
4. The Dock. Inc.
The Dock, Inc. .does not support the Proposed Cleanup Plan and
offers the following comments:
Comment; The Proposed Cleanup Plan is not consistent with the
National Oil and Hazardous Substances Contingency Plan (NCP). If
the Facility is not cleaned up now, it will have to be addressed
again in 30 years. The Proposed Cleanup Plan threatens Ferry
Creek and the Housatonic River. Alternative No. 3 more
thoroughly complies with existing federal regulations.
Response: The Proposed Cleanup Plan, and its development and
selection, is consistent with the requirements of the NCP which
sets out the rules for -Superfund cleanups. A remedial
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investigation of the Raymark Facility was completed, the risks to
human health were evaluated, and a range of remedial options were
developed to address potential human exposure to contaminated
soil and minimize leaching of contaminants into-the groundwater.
The RI, risk assessment, and FS serve as the basis for EPA's
selection of Alternative No. 2 as the Proposed Cleanup Plan.
Alternative No. 2 is a permanent remedy as indicated in previous
Responses.
The Proposed Cleanup Plan does not threaten Ferry Creek.
Subsurface drains at the facility that currently discharge to the
Creek-will be plugged. In the future, only storm water run-off
(that does not come in contact with waste materials) will be
discharged into the Creek, and will be monitored (analyzed)
periodically.
Alternative No. 3 would provide only a marginal'increase in
protectiveness because over sixty (60) different contaminants
would remain in place. Combined with the increased short-term
risks inherent in excavating hazardous wastes, the net reduction
in overall risks to human health is negligible. Furthermore,
capping of the contaminated site soils or capping of the site
with several areas excavated would afford the same level of
protection since there would essentially be no contact with any
contaminated materials.
Comment; The government (EPA, DOJ, and ATSDR) has not been
timely in responding to Freedom of Information Act (FOIA)
requests.
Response; The FOIA requests are for issues unrelated to the
Proposed Cleanup Plan for the Raymark Facility and will not be
addressed as part of this Responsiveness Summary.
Comment; The Administrative Record in Boston and Stratford was
missing 113 key pages of information until late May 1995. This
lack of information deprived the public of information necessary
for preparing comments.
Response: As indicated in several letters to this commenter, the
113 pages were missing from the Administrative Record in Boston
only. As stated in the Dock's comments, the missing pages were
promptly provided to them and the missing pages were added to the
Administrative Record in Boston. The analytical data provided in
Raymark's RFI was summarized and sorted in a variety ways. In
addition, a summary of the analytical results along with a
discussion of the meaning of the data are included in Volume I of
the RFI. Furthermore, the analytical data along with a complete
discussion of the data was included in the RI. Therefore,
considering the data was summarized in a number of different
formats and discussed at length in both the RI and RFI and the
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subject data was present in Stratford, the public was not
deprived of information necessary to prepare comments.
Comment: The Proposed Cleanup Plan is technically unsound and
unworkable, and contrary to laws and EPA guidances. A decision
cannot be made to address only soils and NAPL without determining
remedial actions for groundwater and surface water.
Response; The Proposed Cleanup Plan, which addresses contaminated
soil and NAPL underlying the Raymark Facility, is appropriate to
protect human health and the environment. The development of the
Proposed Cleanup Plan is consistent with the NCP, regulations,
and EPA guidances. Additional investigations will be conducted
to address contaminated groundwater, and on-going investigations
are assessing whether surface water and sediments may have been
affected.
The EPA commonly divides the cleanup of contaminated areas into
phases. The Proposed Cleanup Plan for Raymark is no different
than the cleanup approach for other large.contaminated sites
across the country. There are many sites in the nation that havej
caps installed before the remedy for the groundwater is chosen.
Capping the site now protects public health while the
investigation of other areas of contamination proceeds. Waiting
for all of the investigations to be completed while the remedy
for the soil and sources of contamination at the Raymark Facility
is known would be inconsistent with the EPA's mission to protect
public health. As indicated in previous Responses, the EPA is
addressing this site in phases. Residential properties are
currently being cleaned up, Ferry Creek and other ecological
areas are currently under investigation and the groundwater
investigation will commence in the near future.
Comment; EPA must comply with 40 CFR § 300.430(a)(1)(iii)(F)
which states that groundwater will be returned "to their
beneficial uses where practicable" and otherwise "prevent further
migration of the plume, prevent exposure to contaminated
groundwater, and evaluate further risk reduction." The Dock
believes that the Proposed Cleanup Plan would impede and be
inconsistent with the expected final groundwater remedy.
Response; The beneficial use of the groundwater will be assessed
as part of the groundwater investigation that will be initiated
in late 1995. Because groundwater contamination may not be
restricted to just the Raymark Facility in that part of the Town
of Stratford, the groundwater investigation will assess the
extent of contamination for the area, identify potential users of
groundwater, determine whether there are threats to human health
and the environment, and identify risk reduction measures, as
warranted. The Proposed Plan would be consistent with a
potential groundwater remedy since capping would minimize
contaminant leaching into groundwater, and NAPL removal would
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result in decreased dissolution and migration of organic
contaminants.
Comment: EPA should not sign the ROD until all on-site and off-
site investigations are completed. The Dock does not believe
that there is sufficient time to complete all studies before the
placement of the cap in early 1996.
Response; Additional on-site and off-site evaluations of
groundwater contamination will be conducted. In addition, as
stated above, EPA will continue to investigate other areas where
Raymark's waste has come to be located. The EPA's goal is to
propose a groundwater cleanup plan to the public in December
1997. The implementation of the Proposed Cleanup Plan would
protect public health and minimize the continued leaching of
contaminants to groundwater.
Postponement of the ROD signing would leave the Raymark Facility
unaddressed, and pose potential threats to the public. In
addition to the risks posed to human health from the
contamination ori-site, many of the buildings are unsafe which
further increases the risk to public health. Waiting for all of
the investigations to be completed while the remedy for the soil
and sources of contamination at the Raymark Facility can be
implemented would be a transgression of the EPA's mission to
protect public health.
Comment; Construction of a building and a cap before the
selection of remedies for other operable units (groundwater and
surface water) would preclude any future remediation of
underlying soil or groundwater.
Response; The Proposed Cleanup Plan is a permanent remedy for
the contaminated soil at the Raymark Facility. Groundwater
remediation or containment can be implemented without disturbing
the cap.
Comment; EPA has not made clear who will be responsible for
inspecting and maintaining the cap. The public must be informed
about who will be accountable.
Response; Th« responsibilities for future upkeep of the cap will
be shared by the State and future site owners and will be defined
in the State Superfund Contract and any prospective purchaser
agreement.
Comment; The RI report did not present off-site (sediment and
surface water) data that were collected as part of an EPA Site
Inspection.
Response; The existing off-site data will be assessed with the
results of additional surface water and sediment samples
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collected under a separate investigative phase of this project,
as discussed above. The threat posed by the Raymark Facility to
surface water and sediments consists of the discharges from the
lagoons and the subsurface drainage system. The lagoons have
already been closed and water no longer discharges from the
lagoons to Ferry Creek. The existing subsurface drains will be
plugged as part of the Proposed Cleanup Plan and a new clean
drainage system will be installed as a component of the cap.
Therefore, inclusion of the data in the RI would not have
affected the development of the cleanup alternatives or selection
of a preferred alternative.
Comment; Groundwater quality off-site is likely to be above.
MCLs.
Response; This may be the case. However, exceedance of MCLs is of
concern if the aquifer is being used as a drinking water supply.
The groundwater in Stratford is classified by the state as not
suitable for drinking water. The proposed groundwater
investigation will assess the risks of the groundwater to human
health and the environment.
Comment; Raymark drainage is discharging contaminants to Ferry
Creek. Contaminated groundwater may be discharging from Raymark
to Ferry Creek and the Housatonic River.
Response; The discharge from the lagoons to Ferry Creek has
already been terminated. Discharges from the subsurface drainage
system will be completely eliminated once the drains are plugged
as part of the site remediation. EPA will be addressing the
groundwater contamination as discussed above.
Comment; Contaminated groundwater may be discharging to surface
water, wetlands and residents' basements.
Response; The contaminated groundwater including any potential
affects on residents7 basements will be addressed as discussed
above. In addition, EPA's on-going surface water and sediment
sampling program will provide information to evaluate whether
surface water and wetland areas may have been affected by any
contaminated groundwater migrating from the Raymark Facility.
Comment; Residents may be eating homegrown foods contaminated by
site groundwater. Contaminated groundwater may be reaching
private wells and swimming pools.
Response; As part of the planned groundwater investigation,
private uses of groundwater will be identified. If potential
threats are identified, measures will be taken to abate any
hazards.
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Comment; Light non aqueous phase liquid (LNAPL) vapors may be
entering homes creating health and explosion hazards.
Response; The cap system as proposed in EPA's cleanup plan will
have a vapor collection system to capture VOCs that may
accumulate under the cap. In addition, the groundwater migrating
off-site will be addressed as discussed above.
Comment: People may consume fish and shellfish that may be
affected by contaminated groundwater that discharges to sediments
and surface water.
Response; Biota sampling will be conducted as part of the EPA's
assessment of contamination in surface water and sediments.
Groundwater contamination will be assessed for potential impacts
to surface water and sediments.
Comment: Industrial/commercial pumping wells may cause exposure
to the public.
Response; As part of the groundwater evaluation, users of
groundwater in the area will be identified to the extent
practicable. If threats are identified, measures will be enacted
to protect public health.
Comment: EPA failed to consider the effect that soils have on
groundwater.
Response; The effect of contaminated soils on groundwater was
considered in RI and the FS. The RI assessed the relationship of
soil and groundwater contamination, and evaluated potential
contaminant transport pathways and mechanisms. The FS took the
RI findings and developed remedial action objectives that would
be protective of groundwater.
Comment: EPA must present its position on the most beneficial
use of groundwater. Based on results collected to date, EPA
objective should be to restore groundwater to potable use;
otherwise, eliminate adverse impacts to surface water and
sediments. Plume containment should be implemented if objectives
cannot be achieved, and state how this can be achieved with a cap
in place.
Response; As part of the groundwater evaluation, the groundwater
use in the area would be assessed. Without conducting the
groundwater investigation, it is impossible to determine whether
remedial actions such as plume containment or remediation is
warranted. Once the investigation is completed, EPA will, propose
a cleanup plan for the groundwater as described above.
The EPA commonly divides the cleanup of contaminated areas into
phases. The Proposed Cleanup Plan for Raymark is no different
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than the cleanup approach for other large contaminated sites
across the country. There are many sites in the nation that have
caps installed before the remedy for the groundwater is chosen.
Capping the site now protects public health while the
investigation of other areas of contamination proceeds. Waiting
for all of the investigations to be completed while the remedy
for the soil and sources of contamination at the Raymark Facility
is known would be a transgression of the EPA's mission to protect
public health.
Comment; EPA is not consistent with the PCB Spill Cleanup Policy
set forth in 40 CFR Part 761. EPA intends to dispose of off-site
PCB-contaminated soils at the Raymark Superfund Site. The policy
clearly requires that soils containing greater than 50 ppm of
PCBs be disposed on in an incinerator or a chemical waste
landfill.
Response; The.EPA will comply with the TSCA chemical waste
landfill requirements set forth at 40 CFR § 761.75 with the
exception of certain requirements which are waived pursuant to 40
CFR § 761.75(c)(4).
In this case, placement of soils on the top of the ground
surface, construction of an impermeable cap, and groundwater
monitoring will address the risks posed by PCBs contained in
soils transported to Raymark from residential and the Wooster
School properties. In implementing this response, EPA will
comply with the TSCA chemical waste landfill requirements
regarding flood protection (40 C.F.R. § 761.75(b)(4)); topography
(§ 761.75(b)(5)); and monitoring systems (§ 761.75(b)(6)).
Pursuant to the waiver authority contained within the TSCA
regulations at 40 C.F.R. § 761.75(c)(4), EPA is waiving certain
requirements of chemical waste landfills. The provisions to be
waived include: the construction of chemical waste landfills in
certain low permeable clay conditions (40 C.F.R. § 76l.75(b)(1));
the use of a synthetic membrane liner (§ 761.75(b) (2)) ; no
hydraulic connection between the site and flowing surface water
and that the bottom of the landfill be 50 feet above the historic
high water table (§ 761.75(b)(3)); and that a leachate collection
monitoring system shall be installed (40. C.F.R. § 761.75(7)).
For the following reasons, the requirements of 40 C.F.R. §§
761.75(b)(1), (2), (3) arid (7) are not necessary in this case to
protect against an unreasonable risk of injury to health or the
environment from PCBs.
Low permeability clay conditions for the underlying substrate are
not necessary at this site to prevent migration of PCBs. Soils
over 50 ppm will be placed on top of the existing ground surface.
An impermeable cap will effectively prevent future migration.
The requirement of a synthetic membrane liner is waived because
there will be no hydraulic connection between the soils and the
groundwater or surface water. Infiltration of PCBs to the
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groundwater will be prevented by placing the PCBs under an
impermeable cap. Surface erosion of PCBs in soils and transport
of the soils will be prevented by the impermeable cap.
The hydrologic requirement that the landfill must be fifty feet
above the historic high water table is waived because it is
highly unlikely that the soils will ever come into contact with
groundwater. The soils will be placed on the ground surface
above the historic high water table, and will not be located in a
floodplain, shoreland or groundwater recharge area. Finally, the
leachate collection system is not necessary as the materials will
be located under an impermeable cap and a groundwater monitoring
program will be implemented at the site. Additionally,
groundwater at the site will be addressed in a subsequent
operable unit.
Comment; The PCB Spill Cleanup Policy also requires that sites
with PCBs greater than 50 ppm be remediated. The commenter cites
two cases: In the Matter of Standard Scrap Metal Company. TSCA
Appeal No. 87-4, 1990 LEXIS 10 (Aug 2, 1990) and accord In the
Matter of City of Detroit Public Lighting Department. TSCA Appeal
No. 89-5, 1991 LEXIS 1 (Feb 6, 1991). "
Response: The PCB Spill Cleanup Policy, 40 CFR § 761.120,
establishes the criteria the EPA will use to determine the
adequacy of the cleanup of spills resulting from the release of
materials containing PCBs at concentrations of 50 ppm or greater.
The EPA considered these criteria as guidelines for soil cleanup
at the Raymark Facility. Furthermore, as discussed above, the
EPA will remediate the Site in compliance with the TSCA
regulations applicable to the disposal of PCBs at concentrations
greater than 50 ppm with the exception of certain requirements
which are waived pursuant to 40 CFR § 761.75(c)(4).
Comment: The EPA is excavating Raymark7s wastes at off-site
locations and bringing the waste back to the Facility in
violation of the Off-Site Rule and RCRA land disposal regulations
(LDRs).
Response; CERCLA § 104(d)(4) provides that where two or more
noncontiguous facilities are reasonably related on the basis of
geography, or on the basis of the threat, or potential threat, to
the public health, welfare, or the environment, the EPA may treat
these related facilities as one for the purpose of the response.
Pursuant to 104(d)(4), EPA is treating the Raymark Industries,
Inc. property and locations where Raymark's waste has come to be
located and pose a threat to human health as one facility.
Therefore, the Off-Site Rule does not apply.
EPA. determined that compliance with RCRA Land Disposal
Restrictions during the time critical removal action involving
excavation of Raymark's waste from residential properties was
impracticable. See the National Contingency Plan at 40 C.F.R. §
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300.415. The time required to treat the waste would delay the
Removal Action at residential properties, thereby compromising
the protection of public health. Additionally, the treatment of
wastes is beyond the scope of the removal action in that it
exceeds what is necessary to abate the threats at the residential
properties.
Compliance with such requirements was therefore impracticable.
The EPA is nonetheless managing the waste in a protective manner
and in compliance, to the extent practicable, with RCRA
requirements set forth at 40 C.F.R. § 265.250, et seq. (e.g.,
265.251 (protection from the wind) and 265.253 (containment)).
Additionally, EPA will ultimately dispose of such wastes in a
protective manner as set forth in the ROD.
Comment; The Raymark Facility does not meet the requirements for
a RCRA Subtitle C treatment, storage, or disposal facility. The
EPA is in effect creating a landfill at the Raymark Facility.
Therefore, the disposal of contaminated soils at the facility
which are excavated from satellite locations violates the Off-
site Rule which is to avoid having CERCLA wastes contributing to
future environmental problems.
Response; Since the EPA is addressing the cleanup of Raymark's -
waste as one Facility pursuant to CERCLA section 104(d)(4), the
Off-Site Rule does not apply. Nonetheless, EPA is managing the
waste in a protective manner as discussed above.
Comment; The EPA has "conceded" that LDRs do apply based on a
memorandum prepared by K. Woodward and M. Hill. During the Time-
Critical Removal Action, the materials excavated from residential
properties were placed, without treatment and without complying
with LDRs, on the Raymark Facility because of a lack of time and
further delays would pose an immediate threat to the public.
Since the immediate threats to the public are over, EPA must
comply with LDRs.
Response: Once placement of the waste has occurred as part of the
time critical removal action, a subsequent remedial action within
the same area of contamination does not trigger LDR again with
respect to the waste.
Comment; The area of contamination (AOC) concept applies only to
movement of wastes within one area and does not apply to
consolidating wastes from multiple AOCs, as the EPA has done
through the removal action. Disposal of excavated materials at
Raymark therefore has to comply with the RCRA requirements, such
as landfill closure.
Response: Pursuant to CERCLA section 104(d)(4), the EPA is
treating the Raymark Facility and the satellite sites as one
Facility, as discussed above. Once at the Raymark Site, the
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waste is being managed within one AOC. As explained previously,
the Raymark Site will be closed in accordance with the RCRA
landfill requirements.
Comment; The Raymark Facility does not meet the requirements for
a RCRA Subtitle C treatment, storage, or disposal facility. EPA
is in effect creating a landfill at the Raymark Facility.
Therefore, the disposal of contaminated soils at the facility
violates the Off-site Rule which is to avoid having CERCLA wastes
contributing to future environmental problems.
Response; Since EPA is addressing the cleanup of Raymark's waste
as one Facility pursuant to CERCLA section 104(d)(4), the Off-
Site Rule does not apply.
Comment; EPA has "conceded" that LDRs do apply based on a
memorandum prepared by K. Woodward and M. Hill. During the Time-
Critical Removal Action, the materials excavated from residential
properties were placed, without treatment and without complying
with LDRs, on the Raymark Facility because of a lack of time and
further delays would pose an immediate threat to-the public.
Since the immediate threats to the public are over, the EPA must
comply with LDRs.
Response; Once placement of the waste has occurred as part of the
time critical removal action, a subsequent remedial action within
the same area of contamination does not trigger LDR again with
respect to the waste.
Comment; The area of contamination (AOC) concept applies only to
movement of wastes within one area and does not apply to
consolidating wastes from multiple AOCs, as EPA has done through
the removal action. Disposal of excavated materials at Raymark
therefore has to comply with the RCRA requirements, such as
landfill closure.
Response; Pursuant to CERCLA section 104(d)(4), EPA is treating
the Raymark Facility and the satellite sites as one Facility, as
discussed above. Once at the Facility, the waste is being
managed within one AOC. As explained previously, the Raymark
Facility will be closed in accordance with RCRA landfill
requirements.
Comment; Post-closure care as specified in 40 CFR §§ 264.. 117 and
264.228(b) should be included in EPA's Proposed Cleanup
Alternative.
Response; EPA's Proposed Cleanup Plan includes post-closure care
of the cap as set out in EPA's Responses above.
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Comment; The RI/FS did not adequately consider the impacts of
contaminated soils and NAPLs to on-site and off-site groundwater,
surface water, and human receptors.
Response; The effect of contaminated soils and NAPLs on on-site
groundwater and human receptors was considered in the RI and the
FS. Off-site impacts to groundwater, surface water, and
potential receptors will be assessed by EPA in additional
investigations. The capping of the Raymark Facility will reduce
contaminant migration to groundwater, prevent potential exposures
of contaminants to the public, and eliminate discharges from the
facility's drainage system into Ferry Creek.
Comment; Trichloroethylene (TCE) was detected in monitoring well
M2 at 1,100 jug/kg (ppb) which is 220 times the MCL. Because
soils collected from the north or northwest (upgradient) of this
location did not contain such high levels, this suggest
groundwater flow was inadequately characterized. These results
suggest that another area with high TCE concentrations or NAPL,
possibly under the building. Further sampling should be
conducted.
Response; The lack of TCE in upgradient soils does not mean that
aroundwater was inadequately characterized. The elevated TCE -
presence at groundwater monitoring well M2 may indicate that a
spill or discharge occurred near or at this location, not that
there absolutely had to be a TCE source under the building.
Whether or not there is a potential TCE source under the
building, the placement of the cap system will sharply reduce the
leaching of contaminants to groundwater. The cap's vapor control
layer will capture VOCs that volatilize from the soil pore spaces
and prevent potential exposures to the public.
Comment; There is a lack of.reliable hydraulic conductivity
data, which may affect groundwater or surface water remediation.
For example, the reported hydraulic conductivity results for the
stratified silty sand unit range from 0.075 to 96.4 ft/day, which
is not indicative of a singly homogeneous geologic unit.
Response; Additional investigations will determine whether off-
site groundwater or surface water remediation will be necessary
to protect human health or the environment. As reported in the
RFI report and the RI report, the geologic units underlying the
Raymark Facility are highly stratified and are heterogeneous.
Should remediation be necessary at a later date, investigations
will be conducted to define aquifer characteristics that support
the design of a groundwater remediation system.
Comment; The color graphics presented at the public meetings are
misleading. The graphics do not reflect the extent of the
groundwater contamination. The graphics were developed using the
Site Planner data mapping and presentation software. Site Planner
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uses linear interpolation, which is inappropriate. A
geostatistical variogram-based approach would be more appropriate
and would probably give a different depiction, and would have the
ability to predict off-site concentrations.
Response; The use of the color graphics was to present the public
with visual depictions of the approximate contaminant presence
underlying the Raymark Facility. The use of different methods to
interpolate data will always result in somewhat different
interpretations. As stated at the public meetings, more detailed
information on the nature, rate, and extent of contamination is
contained in the RFI and RI.
Comment; The soils and .groundwater data were not properly
"contoured." Soil data should be contoured from the same depth
and groundwater samples should only be contoured from the same
geologic unit.
Response: The use of the color graphics presented at the public
meetings was to present the public with general visual depictions
of the approximate contaminant presence underlying the Raymark
Facility. As stated at the public meetings, more detailed
information on the nature, rate, and extent of contamination is
contained in the RFI and RI.
Comment: Contaminated soils and NAPL impacts to groundwater and
surface water were not considered in the FS. Slurry walls and
groundwater containment/treatment options were not fully
investigated. These alternatives, theoretically, could be
installed after the cap, but in practice would be impeded by and
inconsistent with the early installation of a cap.
Response; The effects of contaminated soils and NAPLs on
groundwater were considered in the RI/FS. Since EPA's goal is to
address the contaminated materials residing above the water table
and that fractured bedrock is present and guite deep in some
areas of the Facility, the effectiveness of slurry walls in
containing contaminant migration in groundwater is guestionable.
Once the groundwater investigation has been completed, the need
for containment will be assessed.
As stated above, the EPA commonly divides the cleanup of
contaminated areas into phases. The Proposed Cleanup Plan for
Raymark is no different than the cleanup approach for other large
contaminated sites across the country. There are many sites in
the nation that have caps installed before the remedy for the
groundwater is chosen. Capping the site now protects public
health while the investigation of other areas of contamination
proceeds. Waiting for all of the investigations to be completed
while the remedy for the soil and sources of. contamination at the
Raymark Facility is. known would be inconsistent with the EPA's
mission to protect public health.
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Comment; The commenter acknowledges that slurry walls are less
effective when the bedrock is fractured, but recommends that
slurry walls be reconsidered to reduce groundwater flow through
the waste materials.
Response; Once the groundwater investigation has been completed,
the need for containment will be assessed.
Comment; For alternatives that specify excavation and treatment,
the areas to be excavated are not equivalent to areas requiring
treatment and disposal.
Response; The EPA assumes a conservative approach when estimating
the total volume of contaminated material to be treated. The
total volume of contaminated material to be treated and excavated
was therefore assumed to be the same. This was calculated by
examining each sampling location and multiplying the maximum
contaminant depth above the preliminary remediation goals (PRGs)
by its area of influence. The maximum contaminant depth is
independent of the type of contaminants detected. If one or more"
contaminants were detected'at a specific location, only the
contaminant at the greatest depth was utilized in the
calculation. The maximum depth considered in any case was
limited to the depth to the low water table at that soil boring
location.
EPA field experience has shown that estimating the volume of
waste in this manner at hazardous waste sites more accurately
reflects the actual volume of waste to be treated in the field.
Furthermore, based on Raymark's past disposal practices and the
known extent of Raymark's waste contamination, the EPA believes
that this approach is sound and provides a more realistic cost
estimate.
Comment: All cost estimates for the cleanup options in the FS
are significantly overestimated.
Response; These estimates were prepared using available vendor
data, the types of facilities available, the hauling distances to
treatment and disposal facilities, and the anticipated excavation
rates. The actual costs may be lower if there was competitive
bidding involved. However, the purpose of the FS costs is to
provide relative cost comparisons. The actual costs can be
estimated better during the preparation of the remedial design
since specific requirements will be identified.
Comment; There are inaccuracies in the FS cost estimates such as
not including the cost for groundwater containment and treatment.
Response; This remedial action is only meant to address source
control. The costs for any groundwater response will be
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developed, if appropriate, at a later date after the completion
of the groundwater investigation.
Comment; The flat estimate of Health and Safety Monitoring in
Alternative SC-4 is unrealistic. Over $3 million per year is
estimated for having 1 to 2 people watch trucks.
Response: The health and safety estimate presented in the FS is
meant to address a variety of functions related to demolition and
construction activities that go beyond just watching trucks enter
or leave the facility. These functions include training of site
personnel, sampling and monitoring, preparation of health and
safety plans, auditing, monitoring, preparation of reports and
records, and other measures needed to ensure worker safety and
protect the public.
Comment: The $10 million cost for decontamination and demolition
of on-site buildings is not justified other than as a quote from
Raymark Industries, Inc. An independent evaluation by EPA is
necessary.
Response; A separate estimate of the decontamination and
demolition of the on-site buildings is currently being developed
for EPA. Raymark's demolition cost was used in the FS uniforml-y
in all alternatives since all of the alternatives, except the no-
action alternative, require building decontamination and
demolition to be performed. As documented in the Record of
Decision (ROD), Section XII Documentation of Significant
Changes, the capital cost estimate for decontamination and
demolition of the buildings, based on EPA's independent
evaluation is estimated to be $30 million.
Comment: No reason is given for taking 200 groundwater samples
per year. These numbers should be reduced, after 5 years
especially for alternatives involving removal of significant
amounts of soils.
Response; The 200 samples represent quarterly sampli'ng of
approximately 45 wells located in the Raymark Facility and 5
quality control samples. The existing wells located
predominantly along the perimeter of the Facility would be used
to assess potential contamination migration trends, and to assess
whether contaminants may be migrating off-site. The cost
estimate assumptions, presented in Appendix C of the FS, provide
more detailed information. The EPA concurs that at each.5-year
review,.the number and frequency of sampling can be reviewed and
modified, if appropriate. For cost estimating purposes and to
evaluate each option uniformly, the EPA assumes that groundwater
monitoring is required. Since all alternative cleanup options
evaluated in the FS leave waste below the water table,
groundwater monitoring is needed regardless of the volume of
waste excavated.
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If it is determined that the contaminant status varies only
slightly between each quarterly monitoring event, the monitoring
frequency could be decreased which would reduce the overall costs
of monitoring. For the purpose of the FS, quarterly monitoring
was assumed to determine what the costs would be to implement the
cleanup alternatives over 30 years.
Comment; A soil density of 1.5 tons/cubic yard was used in the
estimates; this is rather high and actual soil densities should
be used.
Response: A review of measurements made on samples for a
treatability study conducted on Raymark's waste indicated that
the densities of the soil-waste materials ranged between 95 to
135 pounds per cubic foot. The conversion of 1.5 tons per cubic
yard into pounds per cubic foot yields approximately 110 pounds
per cubic foot. This density falls within the sample data range.
Comment; The costs for thermal desorption/solidification
represent reasonable estimates for small quantities, but
significant economies of scale would likely exist for treating
600,000 tons of soils. EPA should cite costs for comparable
sized thermal desorption/solidification stabilization operations.
Response; The costs for thermal desorption/solidification were
developed from the results of treatability testing, and the
preparation of unit pricing is based on the amount of site-
specific contaminants needing to be addressed. If the only
contaminants in the soils were VOCs, then lower thermal
desorption costs would be anticipated. However, the Raymark
wastes contain Aroclor 1262 and 1268, which require significantly
higher operating temperatures at much longer durations to desorb
properly. Complicating the treatment process is the presence of
asbestos, lead a volatile metal under high temperatures, and
polymerized phenolic resins. Therefore, additional off-gas
treatment would be required. Consequently, the unit costs used
in the FS are reasonable.
Comment: All alternatives include laundry costs, but standard
procedure is to use disposable clothing.
Response; Disposable outer garments would be used to protect site
workers from exposure to chemicals. However, disposable garments
may be damaged, potentially causing dusts and liquids to be
accidentally deposited on work clothes. To better protect the
workers, and to ensure that all environmental contaminants remain
on-site, work clothes should be collected on-site and cleaned.
Comment; Because a comprehensive assessment of the buildings and
structures was not completed, EPA should not have selected an
alternative until, an assessment was completed. The safety
precautions and monitoring procedures that will be enacted during
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decontamination and demolition should be specified and provided
for public review.
Response; The building decontamination and demolition is required
for all of the cleanup options except for Alternative No. 1 which
calls for no-action and is not protective of human health and the
environment. Consequently, the lack of a complete, comprehensive
assessment of the buildings did not impact the comparative
analysis of the alternatives. The public will have the
opportunity to review the final health and safety plans.
Comment; 113 pages of information were missing from the Boston
information repository. But the pages were subsequently provided
to the Dock's consultant.
Response; As indicated in the Dock's comments, the missing pages
were promptly provided to the Dock. The Administrative Record in
Bostpn was rectified once the problem was identified.. The public
was not deprived of any information.
Comment; In Volume III of the Administrative Record, the table
"Preliminary Statistics for Groundwater Data" is missing the
final page: Page 6 of 6.
Response; EPA was not provided this summary page by Raymark's
consultant Environmental Laboratories, Inc. (ELI). However, EPA
was provided with all of the groundwater data and EPA used this
data to characterize the groundwater data in the RI.
Comment; The Dock is concerned that the State of Connecticut
will become liable because of the planned excavation of hazardous
substances from the Wooster Middle School and state-owned
property, and the disposal at the Raymark Facility.
Response; The State will conduct the Wooster Junior High School
excavation pursuant to a Superfund Cooperative Agreement.
Accordingly, the State will be the lead agency for the Wooster
School response. The EPA does not consider the State a
potentially liable party (PRP) with respect to the Wooster School
response.
Comment; The commenter is concerned that individual residential
owners could be held liable for future cost recovery actions.
Response; The EPA has a policy of not seeking cost recovery
actions against residential homeowners.
Comment; The Dock recommends that EPA not sign a ROD for.any
operable unit. An interim or removal action should be
implemented to collect NAPL and to limit access to the soils.
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Response: The Proposed Cleanup Plan, which addresses contaminated
soil and NAPL underlying the Raymark Facility, is appropriate to
protect human health and the environment. The development of the
Proposed Cleanup Plan is consistent with the NCP, regulations,
and EPA guidances. Additional investigations will be conducted
to address contaminated groundwater, and on-going investigations
are assessing whether surface water and sediments may have been
affected by Raymark's disposal practices.
The EPA commonly divides the cleanup of contaminated areas into
phases. The Proposed Cleanup Plan for Raymark is no different
than the cleanup approach for other large contaminated sites
across the country. There are many sites in the nation that have
caps installed before the remedy for the groundwater is chosen.
Capping the site now protects public health while the
investigation of other areas of contamination proceeds. Waiting
for all of the investigations to be completed while the remedy
for the soil and sources of contamination at the Raymark Facility
is known would be inconsistent with the EPA's mission to protect
public health. As indicated in previous Responses, the EPA is
addressing this site in phases. Residential properties are
currently being cleaned up, Ferry Creek and other ecological
areas are currently under investigation and the groundwater
investigation will commence in the near future.
5. Utility Companies
Four utility companies offered comments on the Proposed Plan.
Comment; The risk assessment concluded that potential human
health effects exist for utility workers at the Facility and in
the vicinity of the Facility.
Response; EPA acknowledges that the Risk Assessment demonstrates
an unacceptable risk for non-carcinogens from exposure to waste
in the utility easement area. The Risk Assessment assumes a
construction worker, without the use of personal protective
equipment, is exposed for 5 days per week for a period of 6
months. This exposure scenario would not be appropriate to
assess the risks to utility workers performing routine or
emergency maintenance at residential properties in Stratford
where residual Raymark waste (at concentrations less than what is
found at Raymark in general) was left at depth due to engineering
limitations.
Comment; The risk assessment was inadequate because it did not
evaluate risks to utility workers/agents and residents at
residential properties where Raymark wastes were left in place.
Response; The Risk Assessment properly addresses exposure
scenarios only at the. Raymark property since that is the area of
contamination addressed in this Source Control Operable Unit
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remedial response action. The appropriate extent of the response
action, conducted under the time-critical removal authority, at
the residential properties was determined in accordance with 40
CFR § 300.415 of the National Contingency Plan.
Comment; The EPA has not shared its sampling and analytical data
from these residential properties with the utilities so they can
protect their workers.
Response; The exchange of information between EPA and the
Utilities related to the Time-critical Removal Actions at
residential properties in Stratford is not relevant to the
selection of a remedial action at the Raymark facility. This is
an ongoing issue that will need to be resolved independently of
the selection of the remedy decision for the Raymark property.
Comment: The EPA should have involved the utilities in the
development of the removal action protocol to ensure that it
would be protective of utility workers' health.
Response: The cleanup protocol followed in the Time-critical
Removal Actions at residential properties is not relevant to the j
selection of a remedial action for the Raymark facility. This is
an ongoing issue that will need to be resolved independently of
the selection of the remedy decision for the Raymark property.
Comment: Unlike groundwater, which will be studied in a separate
operable unit, the issue of public worker safety will not be
addressed by EPA in a future action. Therefore, this issue must
be resolved before the Record of Decision is signed.
Response: The issue of public worker safety at residential
properties in Stratford is not relevant to the selection of a
remedial action for the Raymark property. This is an ongoing
issue that will need to be resolved independently of the
selection of the remedy decision for the Raymark property.
Comment; The utilities believe that in the event more Raymark
wastes are encountered by utility workers during work performed
at the residential properties, the EPA should develop
contingencies for excavation and removal of the contaminated
materials, and that space should be reserved at the Raymark
Facility to accommodate the disposal of Raymark wastes that may
be found by the utilities.
Response: It is not practical to reserve space indefinitely at
the Raymark facility to accommodate possible future discoveries
of Raymark waste. Should Raymark waste be discovered in the
future, EPA and/or the CT DEP would perform a removal site
evaluation pursuant to 40 CFR § 300.410 of the National
Contingency Plan to assess the circumstances of the release and
to determine whether or not a removal action is warranted. In
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the event that EPA and/or CT DEP were to determine that a removal
action was warranted, the "availability" of the Raymark site
relative to the status of the remedial action construction,
access from the property owner, and other limitations/constraints
would need to be assessed to determine whether excavation and
transhipment of waste to Raymark or some other response action
was appropriate.
Comment; The EPA underestimated the volume of waste material
excavated from the residential properties. A revised estimate
should be developed.
Response; The estimates, performed by the EPA, of the volume of
Raymark waste that has been or will be excavated from residential
properties under the Time-critical Removal Action are based on
extensive sampling of those residential properties targeted for
excavation. The properties were selected only after a very
extensive investigation and sampling effort of all Stratford
properties suspected of having received Raymark waste for fill.
The EPA has been revising the estimate of waste to be excavated
when new information warrants a modification.
6. Brake Systems. Inc.
Brake Systems, Inc. (BSI) offers the following comments:
Comment; BSI, not Echlin Inc., leased Raymark property in the
mid-1980s. All future correspondence should be directed to BSI.
Response; All future correspondence will be addressed to Brake
Systems, Inc.
Comment; From 1985 to 1988, the property was leased to BSI to
produce automotive brakes. BSI did have a spill in 1987. The RI
and FS incorrectly stated that 6000 gallons of 1,1,1-
trichloroethane (1,1,1-TCA) spilled from a tank transfer line in
1984. BSI records indicate that approximately 600 gallons of
1,1,1-TCA were released in the spill. The correct date of the
spill is December 1987, not 1984. Since the ground was frozen,
the spill flowed on the ground surface to storm basins and
drainage lines. A spill response contractor recovered more than
1000 gallons of a TCA water mixture that was disposed of by a
licensed disposal company. Therefore, it is unlikely that the
TCA found in downgradient groundwater is TCA from the 1987 spill.
Historical operating practices by Raymark are the more likely
cause of contamination.
Raymark engaged in decreasing operations, some near Building 44
where solvents have been found in the soil and groundwater. A
more careful study of Raymark operating practices should reveal
additional sources of contamination.
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Response: The spill information was obtained from the Raymark RFI
report, as noted in the RI and FS reports. The revised
information suggests that at least 100 gallons of 1,1,1-TCA was
not recovered. Historical management of solvents in this area
also may have impacted the subsurface soils and groundwater.
After a review of spill reports, EPA acknowledges that 600
gallons and not 6000 gallons of 1,1,1-trichloroethane was
released to the environment.
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ATTACHMENT A
COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE RAYMARK
INDUSTRIES, INC. SITE IN STRATFORD, CONNECTICUT
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COMMUNITY RELATIONS ACTIVITIES CONDUCTED AT THE RAYMARK
INDUSTRIES, INC. SITE IN STRATFORD, CONNECTICUT
Community relations activities conducted at the Raymark
Industries, Inc. site include:
APRIL 1993
MAY 1993
JUNE 1993
JULY 1993
Fact sheet on public health activities in
Stratford, CT issued (prepared by ATSDR for
first public meeting).
Meeting held with the Wooster School teachers
about their concerns regarding the discovery
of dioxin at Raymark and the waste used to
build the Wooster playing fields. Health
Director, ATSDR, CTDPHAS, CT DEP and Michael
Grey, M.D., UConn.
The EPA briefed officials and press on
Raymark's past waste disposal practices and
presented a course of action for addressing
the problem.
Wooster School Public meeting held, sponsored
by DEP and the Stratford Health Department."
Fact sheets and packets on the environmental
data issued (the EPA and DEP provided after
first round of sampling). Fact sheet issued
in a question/answer format on environmental
and health questions for May 27, 1993 public
meeting (CTDPHAS).
Fact sheet on the public health advisory
(ATSDR) issued.
Meeting with citizens living in the southern
end of Stratford, near a public housing area,
held at the South End Community Center.
Meeting with physical education teachers at
the Wooster School held. Health Director and
ATSDR.
A booth was sponsored by the Health
Department and the Stratford Citizens
Advisory Council at the Stratford Day Family
Fair.
Meeting with senior citizens at the Baldwin
Center held 'with the Town Manager, Town
Councilman, Conservation Director and Health
.Director.
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AUGUST 1993
SEPTEMBER 1993
OCTOBER 1993
NOVEMBER 1993
JANUARY 1994
FEBRUARY 1994
MARCH - MAY 1994
JUNE 1994
AUGUST 1994
Meeting with parents and residents from a
specific councilman's district held. Town
Councilman, ATSDR, and the EPA.
Meeting with people living near Wooster
School held on the remediation activities to
take place in July and August. Town Manager,
Conservation Director, DEP, CTDPHAS and
ATSDR.
The first Stratford Environmental Update
issued.
3rd and 4th Avenue Neighborhood Forum held.
Neighborhood forum fact sheet for 4th and 5th
Avenues issued.
The second edition of the Stratford
Environmental Update issued.
Neighborhood forums held and fact sheet
written for Lot K/Elm Street and Morgan
Francis property.
Neighborhood forum held for residents living
near Raybestos Memorial Field.
3rd and 4th Avenue Neighborhood Forum held.
The third edition of the Stratford
Environmental Update issued.
EPA mailing list notified of Raymark's
proposed addition to the National Priorities
List.
The fourth edition of the Stratford
Environmental Update issued.
The EPA conducted interviews for the
Community Relations Plan.
DEP held a public meeting to inform Wooster
School parents and neighbors that the school
cleanup was postponed until the summer of
1995.
The fifth edition of the Stratford
Environmental Update issued.
Sidney Street Neighborhood Forum held.
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SEPTEMBER 1994
JANUARY 1995
FEBRUARY 1995
APRIL 1995
MAY 1995
Willow Avenue Neighborhood Forum held.
The EPA sent affected residential property
owners a letter indicating that they would
not be held responsible for cleanup costs on
their properties and that the EPA would
protect them against third party liability
for waste brought to the Raymark facility.
Second Elm Street Neighborhood Forum held.
Stratford Avenue Neighborhood Forum held.
Sixth Edition of the Stratford Environmental
Update issued.
Public notices announcing the open houses,
public hearing, and public comment period
were published in the Stratford Star, the
Bard, and the Connecticut Post.
The Remedial Investigation Report, the
Feasibility Study, and the Proposed Cleanup
Plan were issued. .
Open houses were conducted, on Saturday,
April 8 during the day, and Tuesday April 11
in the evening, at the Stratford Public
Library to introduce the public to the
proposed cleanup plan through use of poster
stations and a short presentation by EPA
project leaders, followed by a question and
answer period.
A 60-day public comment period began on April
8 and ended on June 8.
A public hearing was held in Council Chambers
at Town Hall.
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ATTACHMENT B
TRANSCRIPT OF THE MAY 4, 1995 PUBLIC HEARING
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ORIGINAL
PUBLIC HEARING
EPA PROPOSED CLEANUP PLAN
RAYMARK INDUSTRIES, INC.
Stratford Town Hall
2725 Main Street
Stratford, Connecticut
May 4, 1995
7:10 p.m.
SCRIBES, INC.
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1 MR. CAVAGNERO: Good evening. My name is
2 Richard Cavagnero. I'm an environmental engineer with
3 the EPA in Boston, and I'm going to be the hearing
4 officer for tonight's meeting, which is a hearing on
5 the proposed cleanup plan for the Raymark Industries
6 facility.
7 Let me introduce the other EPA people that
8 are here with me tonight and explain the agenda for
9 tonight's hearing and the format for the hearing.
10 Art Wing is the On Scene Coordinator who's in
11 charge of the residential cleanup program that's
12 currently going on in town. Mike Hill is the Raymark
13 project manager in charge of the remedial and
14 enforcement activities at the Raymark site. Mike
15 Jasinski is managing the EPA contractor who prepared
16 the remedial investigation feasibility study for the
17 Raymark Industries site, and is also conducting the
18 . remedial investigation for Ferry Creek and other
19 ecological areas in Stratford where Raymark waste was
20 disposed. Finally, Liza Judge is the community
21 relations coordinator for all Raymark activities in
22 Stratford. : '
23 . There are also a number of representatives
24 from the Connecticut Department of Environmental
25 Protection here. They are Ron Curran and Chris Lacas.
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1 For those of you who are unfamiliar with the
2 Raymark project and EPA's approach to the cleanup, you
3 should know that we have divided the remediation into
4 three phases, which we call operable units.
5 The first phase addresses the contaminated
6 soils on the former Raymark plant property which EPA is
.7 proposing to cap. in place. Construction of this phase
8 will begin shortly after we sign a Record of Decision
9 in June of this year, and will be conducted by the
10 U. S. Army Corps of Engineers. This phase would also
11 include demolition of the buildings and extraction of
12 highly contaminated liquids in the groundwater. This
13 phase is the subject of tonight's hearing.
14 The second phase of our project will address
15 contamination in Ferry Creek and a number of wetland
16 areas throughout Stratford. And the third phase of the
17 . project will address contaminated groundwater migrating
18 from the Raymark property. .
19 In addition to these activities, a number of
20 ' interim cleanup measures have also been performed at ~
21 both municipal and commercial properties throughout
22 Stratford, primarily .by the Connecticut DEP and some of
23 the property owners. There will also be final actions
24 performed on 'these properties after additional study
25 and negotiations with the property owners.
SCRIBES, INC.
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1 Lastly, EPA has been working to clean up 41
2 residential properties since last year by excavating
3 the Raymark waste used as fill there and transporting
4 it back to the Raymark facility for storage. We have
5 currently completed work at 29 of those 41 properties,
6 and expect to finish work there this summer.
7 Back on April 8th and llth, EPA held public
8 meetings and open houses here in Stratford to present
9 the results of the remedial investigation and
10 feasibility study which examined the extent of
11 contamination at the property and the various
12 alternative ways to clean it up. We then presented
13 EPA's preferred approach or proposed plan and had a
14 question and answer period. After I conclude my
15 introductory remarks, Mike Hill will very briefly recap
16 the results of the remedial investigation, and then
17 . Mike Jasinski will again briefly recap EPA's proposal
18 for cleanup, along with why we decided to do that. We
19 will then begin the formal hearing.
20 The purpose of tonight's hearing is to
21 provide an opportunity for the public to provide oral
22 comments on EPA'S proposed cleanup strategy for the
23 site. I must emphasize that this proposal addresses
24 only the contaminated soils at the Raymark facility,
25 including those which were transported to the site from
SCRIBES, INC.
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1 the residential properties and those which the State
2 plans to transport from the Wooster School.
3 It also will address certain pockets of
4 highly contaminated liquids on the site i:: the
5 groundwater, and also the buildings on site. The
6 proposal does not address contaminated groundwater. It
7 does not address Ferry Creek or the wetlands or
8 Housatonic River. It does not address municipal and
9 commercial properties in town. I ask you, therefore,
10 to try to focus your comments tonight on the proposed
11 remedy for the Raymark property itself.
12 We will be transcribing the meeting and will
13 later produce a printed transcript which will become
14 part of the administrative record which EPA will use
15 before we make a final remedy decision. The
16 administrative record is available at both EPA's
17 . offices in Boston and at Stratford at the public
18 library. If you wish to buy your own copy of the
19 transcript, you need to make your own arrangements with
20 the transcription service. In order to ensure accuracy
21 in the record, we would ask that anyone who wishes to
22 make a statement please fill out o.ne of the index cards
23 at the back, I guess, of the hall and to provide your
24 name, address, and if you choose, your affiliation.
25 Hopefully, we'll have enough time for
SCRIBES, INC.
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1 everyone who wants to make a comment. I'll try to
2 limit people's time to 10 minutes at least initially to
3 make sure we have enough time for everyone. And the
4 meeting will be closed when everyone has had a chance
5 to make their comments. We need to vacate the premises
6 by 10 o'clock and need about 15 minutes to pack up, so
7 we'd like to hopefully close the hearing by about 9:30.
8 Whenever we are through, EPA will be staying around for
9 as long as you'd like after the hearing closes, if you
10 have any other general questions about our activities
11 in Stratford that you'd like to ask.
12 Again, I want to emphasize that although this
13 is your only opportunity to make oral comments for
14 inclusion into the record, it is not your only
15 opportunity to make comment. Whether or not you choose
16 to make oral comments tonight, you may also submit
17 written comments to EPA which we will consider before
18 we make a final decision. These comments should be
19 mailed to Mike Hill at the address given in the
20 proposed plan. They must be postmarked no later than
21 June 8, 1995. You may also submit those written
22 comments tonight if you have them with you and would
23 like to do that. We have received a number of requests
24 for an extension of a comment period, and we have
25 decided to extend it 30 days. Originally, it was to
SCRIBES, INC.
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1 close on May 8th, and now it will be extended to
2 June 8th.
3 During the formal hearing, we will not be
4 responding to questions. However, you may ask
5 questions as part of your statement into the record and
6 a response will be included in EPA's Record of Decision
7 in a portion of that called a Responsiveness Summary
8 where EPA responds to all comments. This will be
.9 prepared after the public comment period closes and
10 will be included in the ROD decision, which we hope to
11 issue in late June of this year.
12 Before I turn it over to Mike Hill, I'd ask
13 if there are any questions on either the hearing format
14 or the public participation process that anyone would
15 want clarified. I guess there's none. I will now ask
16 Mike Hill to briefly recap the results of EPA's
17 investigations into the contamination at the Raymark
18 .. facility.
19 MR. HILL: My name is Mike Hill, and I've
20 been the project manager at Raymark for the last six-
21 years. I'm going to show you some slides of Raymark,
22 and briefly go over what-we went over at the public
23 meeting a few weeks ago.
24 Raymark is located on 75 East Main Street
25 across from The Dock Shopping Mall, and about half a
SCRIBES, INC.
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8
1 mile from the Housatonic River. Raymark manufactured
2 brakes and friction products mainly for the automobile
3 industry. The waste generated at the site included
4 solvents and lead asbestos sludges and a number of
5 solvents. Raymark landfilled their waste on-site and
6 in a number of off-site locations; approximately 60,
7 including 41 residential properties, Wooster School,
8 other municipal properties, commercial properties, and
9 in Ferry Creek.
10 . In the last few years, Raymark conducted an
11 environmental investigation of its property where they
12 installed approximately 66 soil borings, and they
13 installed^-£6 groundwater monitoring wells to look at
14 the soil and groundwater and find out what
15 contamination was there. And they collected hundreds
16 .of samples from those monitoring wells and those
1-7 borings.
18 This slide is a map of Stratford. The green
19 area shows in general where Raymark disposed of its
20 waste, and the red stars indicate residential
21 properties where EPA's currently digging up the waste.
22 Approximately three-quarters of those have been
23 excavated to date. These symbols indicate, these red
24 ones here and these green ones indicate the soil
25 borings, and these symbols indicate the monitoring
SCRIBES, INC.
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1 wells on-site.
2 From 1919 through the 1970's, Raymark
3 landfilled their waste in lagoons and they built on top
4 of them, and they also landfilled or they disposed of
5 acids and solvents in these acid pits here, which is .
6 also one right here, you can see in this aerial
7 photograph. And they had a number of spills of tanks
8 on-site. They had a toluene tank here that spilled.
9 Toluene is a volatile organic chemical used in
10 degreasing and things like that. And they also had "a-
11 spill of 1,1,1-trichloroethylene, which is another
12 solvent used in'cleaning metal parts. And they also
13 disposed in pits solvents. And in this area they
14 disposed of trichloroethylene.
15 So I just want to show you a number of slides
16 that depict the contamination in the soil and in the
17 groundwater briefly. This slide shows in yellow lead
18 above 10,000 parts per million. And basically you can
19 see wherever there's yellow lagoons and underneath the
20 buildings, you can basically see that the entire site""
21 is contaminated with lead in very high concentrations.
22 The waste at Raymark ranged in thickness
23 anywhere between zero and 24 feet thick, and there's
24 approximately a half a million cubic yards on-site.
25 The amount of waste that we're bringing back on-site
SCRIBES, INC.
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10
1 represents about 10 percent of that volume. This slide
2 shows PCB's above 250 parts per million. And you can
3 see, again, the pattern where you find the lagoon
4 sludges you also find PCB's in very high
5 concentrations. This slide shows the organic
6 contamination, volatile organics, the solvents. And
7 you can see here that in this area, this is where the
8 acid pits were located, that's where the
9 trichloroethylene is. And that area is fairly
10 contaminated. -
11 This area up here is where the toluene spill
12 was located. Arid at this monitoring well location
1.3 right here, monitoring well V, we found a highly
14 contaminated pocket of liquid that's down about 40
15 feet, and that's about six inches in thickness. And
16 then at this area we found another one, and it's
.17 approximately five feet thick. Mike is going to talk
18 about how we're going to address that. And then the
19 spill location over here in the soils, that's where the
20 1,1,1-trichloroethylene spill was located.
21 Concentrations there are not that great, as you can
22 see, compared to these areas.
23 . This overhead shows the asbestos on-site.
24 The yellow indicates asbestos greater than 25 percent.
25 And again, you can see that the whole area is
SCRIBES, INC.
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11-
1 contaminated with asbestos in fairly high levels,
2 again, where the lagoons are located. Just to
3 . illustrate the point of where the contamination exists
4 on-site, this is asbestos above one percent, and the
5 asbestos is located virtually everywhere inside the
6 property boundary. And there is some asbestos and
7 contamination you're seeing out here, out here, and
8 that will be addressed by the remedy as well.
? The groundwater at Raymark flows basically
10 from southwest -- excuse me, northwest to the southeaa-t
11 across the site in general. And as I'm going to show
12 you shortly, this is the acid spill location, the
13 toluene spill, and the TCA spill. And you're going to
14 see how those areas are responsible mainly for the
15 contamination in the groundwater. This is the toluene
16 concentration in the groundwater of a hundred parts per
17 million, and this area in red is the highly
18 concentrated pocket of liquid, and that pocket is
19 causing-a lot of the contamination.
20 And you can see that the contamination is
21 basically flowing towards Barnum Avenue and in this
22 general direction. There are no off^-site groundwater
23 monitoring wells, only on-site groundwater monitoring
24 . wells. EPA is going to be addressing the off-site
25 groundwater arid the contamination associated with that
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1 at a later date and proposing a remedy like we're
2 proposing now in the future.
3 Again, here's a highly contaminated pocket of
4 trichloroethylene, one of the solvents. And the
5 groundwater is basically flowing in this direction
6 southeast. And when you look at all of the solvents
7 combined in the groundwater, this just shows the you
8 can basically see that the groundwater is flowing in
9 this general direction because there's actually a
10 valley at Raymark, and that concentrates all of the
11 contamination in this direction. And the contamination
12 in the southern, southwestern corner essentially flows
13 also to the southeast.
14 That's essentially the extent of the
15 contamination. I'll let Mike Jasinski talk about the
16 proposed remedy that we're proposing. Thanks.
17 MR. JASINSKI: Some of you know me. I'm Mike
18 Jasinski, and I'm the project manager that had our
19 contractor prepare the remedial investigation, which is
20 the study of the contamination, and feasibility study,
21 which looks at alternatives to clean up any Superfund
22 site. : ''
23 As Mike indicated, during the remedial
24 . investigation work that's been done at Raymark for
25 several years, the soil and groundwater contamination
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1 is highly contaminated. And in fact, it's contaminated
2 by some 60 different contaminants, trichloroethylene,
3 asbestos, and so on.
4 As part of the remedial investigation, we
5 performed what is called a risk assessment. It looks
6 at the baseline conditions for exposures to people who
7 may trespass on 'the property, people who may be working
8 on the property currently or in the future. In that
9 assessment, we determined that trespassers and on-site .
10 potential workers who may be contacting the soils
11 underneath the asphalt in the area of Raymark are
12 potentially at risk from direct contact; that is,
13 contacting it by skin or ingesting it.
14 Based on those two pieces of information, EPA
15 has determined that there are two critical objectives
16 we must establish and meet to respond to the
17 contamination at Raymark. And they are to prevent
18 human exposures to those soils that exist on that
19 property, and also to remove those highly concentrated
20 pockets of chemicals that are sitting in the
21 groundwater. .
22 . As Mike pointed out on his overheads, also as
23 Rich Cavagnero pointed out and as Mike indicated, we
24 don't have enough information to right now p-ropose to
25 the public for comment a remedy to clean up the
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1 groundwater, primarily because we don't have enough
2 information from wells off the property to determine
3 where it is going and whom it may be impacting.
4 What we did do is look at several cleanup
5 options for the Raymark property/ the soil
6 contamination, and the highly concentrated pockets of
7 solvents. And what we did was we looked at five
8 different alternatives is what we call them. They
9 range from a no action alternative; that is, basically
10 leaving everything as it is today and walking away.
11 We looked at Alternative 2, which is simply
12 capping the facility, which involves demolishing the
13 buildings, capping the facility, removing those pockets
14 of contamination, and returning it to some hopefully
15 beneficial use in the future.
16 - Two other alternatives we looked at were
17 capping the facility, but before we would do that we
18 would do a limited' excavation of some 21,000 cubic
19 yards of highly concentrated pockets of PCS
20 contamination primarily in those areas to the far west
21 of the facility over near Long Brook Avenue and in that
22 general area. We would take that material and dispose
23 of it off-site appropriately under federal regulations,
24 and then we. would go in and cap the facility, tear down
25 the buildings and the like.
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1 The other two alternatives we looked at
2 primarily dealt with excavating all contamination above
3 the water table. As Mike indicated, we have over a
4 half a million cubic yards of contamination on Raymark
5 proper. Approximately 300,000 cubic yards of that is
6 above the water table. What we looked at in two
7 alternatives was excavating all 300,000 cubic yards and
8 either treating it on-site or treating it off-site, and
9 then returning the facility to reuse again with no
10 contamination in that upper 10 to 12 feet.
11 What we're proposing this evening is
12 Alternative 2, and that is simply capping the facility.
13 In comparing the five alternatives we looked at, we
14 have several criteria that we have to balance and meet
15 in order to select and propose a remedy for public
16 comment. And they involve protecting human health and
17 the environment, meeting the state and federal
18 requirements, laws, providing long-term protection-,
19 reducing mobility, toxicity, and volume through
20 treatment, short-term, looking at the short-term
21 impacts from any one of those alternatives or its
22 effectiveness, is it implementable, can you do it, what
23 does it cost,- what does the state think, and why we're
24 here during this comment period, what does the
25 community think. .
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1 In looking at the five alternatives, we have
2 provided, and as shown on page 7 of the proposed plan,
3 a matrix that sort of looks like a Consumer Reports
4 presentation. It basically shows in dark black circles
5 what we felt the alternative does relative to not
6 meeting the requirements in dark black, partially
.7 meeting the requirements as in half circles, or meeting
8 or exceeding the requirements that are being shown here
9 as clean circles.
10 In looking at the five alternatives,
11 obviously we came to one conclusion that no action,
12 which we have to look at under law, doesn't meet
13 several of the criteria given in comparison to the
14 other ones. It's not going to do any treatment, we're
15 not going to reduce any toxicity, we're not going to
16 provide any protection over the short-term, the
17 long-term, or otherwise. It can be implemented very
18 easily 'cause we're not going to do anything.
19 So we're left with four other basic
20 ' alternatives involving capping, capping with some
21 excavation, and excavation and either on-site or
22 off-site treatment. And what you see is simply a
23 comparison of what we feel these five criteria, which
24 . are called balancing criteria, how they factor and how
25 they appear to us today to satisfy or exceed the .
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1 requirements we have to look at. And the basic
2 differences, as you can see here, are that we can
3 provide long-term protection and a lot of treatment and
4 reduction of mobility, toxicity, and volume by digging
5 up 300,000 cubic yards, but we're also going to have a
6 lot of short-term impacts by digging that up, either by
7 a lot of truck traffic along that area or by simply a
8 lot of excavation activity on that property. And it
9 may be not that simple to implement. And finally, it's
10 going to cost either $330 million or a billion dollars..
11 So essentially we were left with these two
12 alternatives to choose from and propose to you this
13 evening. And what it came down to in proposing the
14 capping alternative alone with limited excavation is
15 that we have these two criteria that made it a bit more
16 difficult for us to propose a capping with an
17 excavation than simply capping. That is, 21,000 cubic
18 yards of excavation is not a simple task, treating that
19 . material off-site is not a simple task, and trying to
20 maintain some sort of control over an excavation of
21 . that magnitude is not an easy task. So there are
22 impacts, there are some" short-term problems,-there are
23 some implementability problems, and it's going to cost
24 $70 million more than what we propose this evening.
25 ' The last two criteria that we don't look at
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1 In most Superfund sites, but for this one in particular
2 we added are looking at potential reuse and the time to
3 reach the cleanup goals. And obviously, in order to
4 provide some potential reuse for this property in the
5 next several years, maybe one to two years, we would
6 have to very seriously look at proposed capping alone
7 in order to get there because excavating 21,000 cubic
8 yards may extend that time period out too far in order
9 to provide reuse in some reasonable time frame. Thank
10 you very much.
11 MR. CAVAGNERO: Thank you, Mike. A couple of
12 administrative notes before we start the hearing. For
13 those of you who didn't come in that way, came in this
14 way, there are copies of the EPA's proposed plan in the
15 back of the room, and also a brochure from the
16 Stratford Citizens Advisory Council indicating who they
17 are, what they've been doing for the past few years,
18 and their involvement in the project.
19 And one other detail is that we need .to
20 collect the index cards so we can call on people to
21 make their comments. And if you'd like to decide that
22 . you want to wait awhile before you decide if you want
23 to make a comment, that's fine. If you decide at a
24 later point, just see Liza, give her your card, and
25 then we can call on you.
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1 The first person here is named Jason Santi,
2 29 Long Brook Avenue. Did you want to make a comment?
3 Next is Al Santi. Elaine O'Keefe.
4 MS. O'KEEFE: I'm Elaine O'Keefe, Director of
5 Health for the Town of Stratford. I have reviewed the
6 EPA's proposed cleanup plan for the Raymark facility on
7 several occasions.and I want to offer some comments on
8 the plan this evening. Some of the concerns that I
9 will voice have been raised in prior discussions with
10 EPA; however, I am simply reiterating them this, evening
11 for the record.
12 One of my primary concerns with the proposed
13 plan is the tenuous nature of the groundwater
14 contamination beneath the Raymark facility and the
15 extent of this contamination beyond the perimeter of
16 the industrial site. Though I understand that the
17 cleanup plan is designed to focus solely on source
18 .. control and that groundwater remediation will be
19 addressed separately due to the lack of sufficient
20 information to adequately assess the need for
21 groundwater response action or what such action would
22 entail; however, I feel that in order to fully endorse
23 EPA's proposed cleanup strategy of capping with no
24 excavation, i.ei, Alternative number 2, it is
25 imperative that some assurances be given to the Town
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1 that the groundwater issue will be thoroughly addressed
2 and in due haste, as we face the very real possibility
3 of diminishing Superfund monies and regressions in
4 environmental regulations needed to clean up the
5 process.
6 By removing the pockets of liquid
7 contamination or solvents, which is part of Alternative
8 number 2, clearly EPA will reduce the amount of
9 contaminants that could be available and mobile..
10 However,, the strategy is only a partial remedy. Again,
11 we need to know more about the character of the
12 groundwater contamination problem. Testing undertaken
13 by Raymark's consultant does not provide information
14 beyond the property boundaries; thus we are unaware of
15 how far the plume of contamination has advanced.
16 Because the end receptor is the Housatonic River, we
17 cannot know what the long-term impact will be once the
18 contamination plume meets the river. While the tests
19 performed last year on shellfish from the river show no
20 evidence of Raymark contamination, we also cannot rely
21 solely on these data to provide us with a window into
22 what will occur in the next 15 to 20 years. j
i
23 The uncertainties surrounding the groundwater j
24 contamination problem poses public s.afety issues as
25 well. Several years ago, and some of you in this room
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1 may remember this incident, a foundation caught fire
2 during an excavation project because of the toluene
3 content found in the groundwater seeping into the
4 construction area. The back hoe sparked a pipe and an
5 explosion ensued.
6 Another major concern about the proposed
7 cleanup plan is the safety of workers and neighboring
8 residents. This would apply to any of the options that
9 we're looking at this evening. Clearlyj EPA must
10 address future utility services issues .as part of its
11 remediation plans. A particular concern is the fact
12 that a main sewer line threads right through the center
13 of the site. The health and safety of the utility
14 workers who will have the responsibility of maintaining
15 this line in the future must be carefully considered.
16 While I understand that EPA is entertaining the notion
17 of relining the pipe to prevent further erosion and to
18 defer maintenance concerns, this measure alone also
19 does not guarantee that workers will.be protected from
20 exposure when the pipe eventually requires replacement
21 in the future. The creation of a wroker safety zone is
22- one suggestion that has and should be pursued.
23 . Yet another major issue is the demolition of
24 the Raymark buildings. This aspect of the .remediation
25 project obviously raises many concerns about the
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1 potential for exposure to fugitive dust that may be
2 generated during this process. Clearly, monitoring
3 will be necessary at the actual site and at the Raymark
4 property perimeter. Further, I would request that the
5 Agency for Toxic Substances and Disease Registry and
6 that the Connecticut Department of Public Health and
7 Addiction Services, as well as my office, have the
8 opportunity to review all health and safety plans prior
9 to the commencement of any work on the property. In
10 addition, we would ask for sufficient lead time to
\.
11 allow us to convene neighborhood forums so that
12 residents can be properly informed of the schedule and
13 have an opportunity to hear air their concerns about
14 the demolition and ensuing remediation schedule.
15 The needs for long-term monitoring of the
16 site subsequent to the completion of the remediation
17 work is another concern. To my knowledge, EPA and
18 Connecticut Department of Environmental Protection are
19 working this out, but have yet to formalize an
20 agreement. I would hope that this agreement can be
i
21 formalized before the remediation commences. j
22 In closing, I'd like to say that I commend \
i
23 . EPA for all the work they've done to develop these
24 options, and the tremendous amount of effort they've
25 put into cleaning up the Raymark sites in Stratford.
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1 And I also concur that Alternative number 2 has many
2 positive features, including the fact that this will
3 provide short-term effectiveness and favors
4 implementability. It is feasible from a cost
5 standpoint. For a variety of reasons, and most
6 importantly, the immediate need to protect public
7 health and to reduce the risks that are currently
8 present at that site, I think it behooves us to move
9 quickly with the remediation process, and Alternative
10 number 2 offers us that possibility. Notwithstanding
11 by EPA's own analysis, Alternative 2 only partially
12 . fulfills the criteria of providing long-term protection
13 and reducing mobility, toxicity, or volume through
14 treatment. Both of these criteria figure into the
15 long-term.protection of. the environment and human
16 health. Although we all want expediency and wish to
17 see the property restored to useful purposes, it is
18 imperative that we not only concern ourselves with our
19 generation, but also act in mind of the health and
20 well-being of generations to come. Thank you.
21 MR. CAVAGNERO: Tom Carroll. Ahgie DeMello,
22 Janet Carlucci. =
23 MS. CARLUCCI: I'm Janet Carlucci and this is
24 , Angie DeMello. We are the co-chairs of the Stratford
25 .Citizens Advisory Council. In June, 1993, pur group
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1 was formed. The SCAC is a diverse group of many local
2 concerned residents, business people, and entrepreneurs
3 who became involved to serve as a link to the community
4 between the community and the various government
5 agencies to hold the agencies accountable to the public
6 and to help obtain and disseminate factual information
7 on the issues.
8 Our ongoing dialogue with the state and
9 federal legislators have helped to indemnify the
10 residential property owners from any financial
11 liability for the waste found on their property. In
12 the future/ we hope that the same consideration will be
13 extended to the town as well.
14 The SCAC would like to respond for the record
15 on the proposed cleanup plan for-Raymark Industries as
16 outlined by EPA. The group is in favor of Alternative
17 2, capping the site. We see this as the most viable
18 and effective option presented. While we realize
19 comparisons were done between each alternative, we are
20 also aware that the engineering details of how to
21 implement the chosen plan and its four principal
22 components have not yet begun. When:the engineering
23 and safety plans are finalized by EPA, we would like
24 them to be made available for public review and a
25 public comment period before the remediation process
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1 proceeds. The SCAC would like to point out the
2 following points and have them kept in mind when
3 developing the engineering and safety plans as they
4 relate to four principal components. Angie is going to
5 start.
6 MS. DE MELLO: I'm Angie DeMello, as Janet
7 said, and I'm co7chair of SCAC. We're going to address
8 this in terms of the four components that EPA has
9 presented as part of their cleanup plan. Component 1
10 is decontaminate and demolish facility buildings arid
11 structures. There are some points that we would like
12 EPA to keep in mind.
13 The first is that we would like SCAC as a
14 group would like to review the plan when you do
15 finalize the plan with some of these points kept in
16 mind. The first is to ensure that all safety
17 considerations to workers as well as the public are
18 included. We would like to see included in the plans
19 communications between or to both residents of the
20 ' affected areas and the town in general. 3, we would-
21 like EPA to commit to specific dates. And I'm not sure
22 that -this is too much of a demand, if possible, to
23 commit to specific dates and times for demolition .and
24 : capping. I'm sure those dates will change as we go
25 along, but at least to be somewhat time bound so we
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1 have an idea of what we're working under.
2 Second, as an effect of demolition and
3 remediation, there are young children at shopping
4 centers and the Wooster School, which is also part of
5 the remediation plan, who are going to be exposed to
6 fallout during demolition and removal of waste and
7 capping process.. We'd like to ensure that as much
8 safety as is possible is maintained. Older children
9 curious about the site may try to get into places and
10 explore. It always is an exciting place, especially
11 when you're not allowed to go in. Measures to contain
12 all debris, including airborne debris, during all
13 phases of the demolition and capping. And we see a
14 definite need for security guards to ensure that the
15 public is kept out of the facility.
16 . The next is notifying the public when
17 demolition and capping will take place; We recommend
18 that the neighborhood be bulletined and residents be
19 told of when this demolition will take place. We
20 ' recommend that signs be posted in and around the
21 shopping center warning parents to keep young children
22 away from the area, post numerous items in the
23 newspapers indicating specific dates and times when
24 . work will be 'done, and indicate when conditions will be
25 the most critical.
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1 This is a suggestion, but perhaps it will be
2 expedient, to notify PTA's of surrounding schools of
3 the warnings and the dangers of these particular
4 remediation sites to children. That's definitely a
5 place where children are expected to listen, in school,
6 so you know, the message gets out to them. One of our
7 recommendations, and this I think is a great
8 consideration, is to possibly have a lot of the work
9 done during the night. This will minimize public
10 exposure from traffic, cars, trains, planes, and
11 certainly there are fewer people out. on the street at
12 that point, so it's a good option to consider.
13 Component number 2, which deals really with
14 the removal of high concentrations of pockets of
15 solvents or VOC's from groundwater in the area. We do
16 understand that, you know, there is no specific plan at
17 this point as far as testing the groundwater on and off
18 the site. But we do have some considerations that we
19 would like to express. We'd like to know who will be
20 doing this testing and monitoring, and who will be
21 responsible for .the cost; can this groundwater problem,
22 can this testing be done prior to the cap being put on
23 or will it take place after? And 1 imagine this
24 pertains to the testing off-site as.well. We would
25 like to see that the Housatonic and the Sound be tested
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1 for contamination before and after the remediation is
2 done. And with that, I'm going to have Janet, you
3 know, talk on the rest of it.
4 MS. CARLUCCI: On component number 3, cover
5 the entire facility with an impermeable cap. We would
6 like to see that the clean fill that's brought to the
7 Raymark site be tested to make sure it is clean. After
8 all, this is New England; it's very hard to find any
9 fill that is not contaminated with something. We would
10 hate to see the cap end up being more contaminated than
11 what's already at the site.
12 How frequently it's tested, maybe every truck
13 load, every hundred cubic yards. We're not quite sure
14 what you would consider. Who would do this testing as
15 well, and also what contaminants would you test for?
16 We certainly don't need fill coming from other sites as
17 well and having it trucked from one site and being
18 dumped on this site as clean fill.
19 There also are concerns that, as Elaine had
20 spoken of, the sewer line that is on the property. And
21 we certainly would like to see that worked out as well
22 utility workers' safety. Those are all issues with
23 the, once the cap is in place, what you are going to do
24 with those..
25 The next issue is component number 4,
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1 ensuring the integrity of the cap. Who will be
2 policing the new owners. The details of that would
3 actually need to be worked out as part of this
4 engineering plan. And some of the things we'd like you
5 to keep in mind when you're working on that plan is who
6 would make sure that they maintain the integrity of the
7 cap? What penalties would be implemented if they fail
8 to maintain the cap? What are the deed restrictions
9 that would be placed on the Raymark property? If the
10 deed is broken, who will be the responsible party? Wh~o
11 would assume ownership of the property if the deed was
12 broken?
13 And lastly, the SCAC supports the proposed
14 plan as outlined. We feel if this is engineered and
15 executed properly, that it is the most intelligent and
16 effective solutipn for the site and also for Stratford.
1.7 Thank you.
18 MR. CAVAGNERO: Before you leave, I need to
19 ask one clarifying guestion. On the building
20 demolition, you made reference to EPA putting bounds on
21 the time. Did you mean the time frame hours of
22 operation during the day, were you speaking of, or just
23 a schedule --. .
24 . MS. DE MELLO: The schedule, as well as
25 possibly the number of hours so people are aware that
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1 this is actually happening and to avoid being in the
2 areas at that point.
3 MS. CARLUCCI: Especially the small children.
4 MS. DE MELLO: I have a comment that I'd like
5 to address as Angie DeMello and not as co-chair of
6 SCAC. I understand until the cap is finally in place
7 that the facility is the recipient of the residential
8 waste, as well as possibly some of the waste from
9 municipal sites. However, I would like to know what
10 alternative is being made once the cap is put on for
11 any possible residential or municipal sites that are
12 discovered after that cap goes on. I really think
13 that's an important issue at this point because I don't
14 know of any known facility in Stratford that will take
15 that kind of waste. Thank you.
16 MR. CAVAGNERO: Thank you. Next is the
17 Waterfront Harbor Commission, Robert Saxnmis.
18 MR. SAMMIS: The preliminary remarks that I
19 have are for the purpose of explanation. Prior to this
20 evening and following the meeting that was held at the
21 Stratford Library, a letter was sent to Mr. Hill with
22 regard to Ferry Creek, which is a considerable concern
23 to the Waterfront Harbor Management Commission. A
24 subsequent review of the data that .was available at the
25 library became apparent, and I believe that was
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1 frame 1-1 that shows that the surface water transport
2 goes to the southwest corner. Mike, if you would put
3 the town map on the thing, people can tell a little bit
4 better what I'm talking about.
5 The surface water goes into storm drains, as
6 one would normally expect, and then go in their merry
7 old fashion to Ferry Greek. And this is not a new
8 phenomenon,, but is one which has been going on for
9 decades. The concern that was expressed in the letter
10 of April 13th was that the sediments have been
11 . accumulating as, if you will, the downstream
12 accumulation from Raymark since Raymark started
13 discharging and having surface water discharges in that
14 form.
15 If you look at the map, which is called
16 Raymark Industries with the town as a whole, the green
17 finger, if you will, that comes down from the Raymark
18 site is for all practical purposes the Ferry Creek
19 discharge zone, and eventually the terminus of that
20 discharges into Housatonic River between what is called
21 Brown's Marina or Brown's Boat Yard and Stratford
22 Marina, too. It is also the junction at which a very
23 ' large concentration of the seed oyster industry is
2.4 .domiciled. Although those - rascals do move around a
25 bit, the oyster beds are predominantly from that area
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1 further down the river, which is the normal transport
2 of the Housatonic.
3 So the letter of the 13th addressed the fact
4 that everything below the high water mark happens to be
5 state-controlled, state property. And obviously the
6 DEP, the state agency, should be highly concerned about
7 the remediation work which is being done upstream as
8 well as their own property, much in the same fashion
9 that a property owner of private property would want
10 their land cleaned up and returned to hopefully a
11 nontoxic state. This is not to say that the Waterfront
12 Harbor Management Commission knows that the Ferry Creek
13 bed, if you will, is contaminated, but reasonable
14 people, we think, would be left with that conclusion.
15 Subsequent, as I say, to that, we went over
16 to the library and reviewed the documentation. And if
17 anyone has had the opportunity to review your
18 government's documentation, you'll find that it is
19 voluminous. We've heard of the five-foot book shelf of
20 Western Civilization. This is the 10-foot book shelf
21 of the EPA analysis of the Raymark problem. It is
22 extensive; it is highly detailed; it is highly
23 - technical. From that, though, you can derive a certain
24 amount of information, which is in what I would call
25 the public sector, the non-technical sector.
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1 Two things are apparent: The storm water
2 transport, rain water, whatever, that is going to come
3 onto that 33-acre site is going to continue to fall and
4 . aim itself through the storm system into Ferry Creek.
5 And by further examination of the data, the
6 groundwater; that is, the subsurface water, continues
7 to migrate in a southerly or southeasterly direction.
8 And strange as it may seem, it is a two-way transport
9 system because the findings of the EPA show- that in.the
10 deep as well as the lower subsurface testing is that-
11 the.water by and large is brackish up to the railroad
12 tracks. Brackish simply means it's a mixing of salt
13 and fresh water, so it's coming and going.
14 And in that regard,, we have prepared this
15 letter. Actually, it's dated tomorrow because of the
16 incidence of tonight's meeting, and addressed again to
17 Mr. Hill.
18 - "On behalf of the Commission, the Waterfront
19 Harbor Management Commission, I would like to convey to
20 you and your organization our profound concern with ~
21 regard to the disposition and remediation with regard
22 to Ferry Creek in Stratford. As I mentioned in our
23 letter of April 13, 1995, we expressed a desire to have
24 an indication as to what activitieis would be undertaken
25 to eliminate the contaminants found in the Ferry Creek
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1 below the high water mark. To this date, we have not
2 yet received a reply."
3 "In the interim, we have had the opportunity
4 to review some of the documentation placed at the
5 Stratford Library by your organization. A review of
6 this material reinforces our belief that Ferry Creek
7 is, has been and will continue to be the focal point of
8 storm water discharge from the noted site. In fact,
9 the "capping" of the 33 acres, it would appear that the
10 storm water runoff will be increased as the property
11 will no longer have retention properties. As to the
12 groundwater, this too is of some long-term concern. As
13 the proposed cleanup, Alternative 2, does not remove
14 the most contaminated soils, with PCB's, 21,000 cubic
c
15 yards we mentioned, these and other organics will
16 continue to leach as they have been doing currently
17 toward the river, and in particular, toward Ferry
18 Creek. It is interesting to note that much of the
19 groundwater, at shallow and deep levels, is brackish.
20 This would lead one to surmise that salt water has
21 infiltrated this area and concludes that there is a
22 subsurface transport system at work."
23 . "The remediation plan calls for on-site
24 testing, through wells, of the ground and surface
25 water. We would suggest that it might be prudent to
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1 establish a number of strategic wells or test sites off
2 the property in the area of Ferry Boulevard and perhaps
3 one or more between the site arid the H'ousatonic River
4 more northerly of the creek."
5 "We look forward to having a response to our
6 concerns in a fashion that we can respond to it prior
7 to the end of the comment period on June 8 of 1995.
8 Sincerely, yours truly, Robert Sammis, Chairman of the
9 Harbor Management Commission."
10 And since I have the floor for a minute
11 longer, I would like to, without beating a dead horse,
12 extend my personal concerns about third-party
13 liability. The Town of Stratford has recently gone
14 through a rather traumatic effect of delivering at the
15 time, I believe, a load of tires to an appropriate dump
16 site outside the community. And if my intelligence
17 services, including the local newspaper, inform me
18 correctly, that the Town of Stratford, in spite of the
19 fact .that they did the right thing at the right time
20 and they were told it was okay, has subsequently been
21 held liable for helping to contaminate the property
22 because they like so many of us in this community,
23 ha-ha, have deep pockets. If you transport all the
24 contaminated material from the school site to the other
25 places .throughout this town,, the question stands do we
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1 have third-party liability; and if that's the case, the
2 pockets unfortunately in Stratford aren't deep enough
3 to handle that kind of suit. Thank you very much.
4 MR. CAVAGNERO: Bob Osborne.
5 MR. OSBORNE: I'm Bob Osborne, and I
6 represent The Dock, Incorporated. We have reservations
7 about the overall effects of the Environmental
8 Protection Agency's Preferred Plan for the Remediation
9 of the Raymark Facility. We have studied the five
10 alternatives for remediation. We are concerned about
11 the lack of permanence in the Preferred Plan. We are
12 concerned about the very limited removal called for in
13 the Preferred Plan. We are very concerned about the
14 long-term health effects, the lack of protection of the
15 citizens) of Stratford, and the absence of any
16 information or studies concerning the groundwater and
17 Ferry Creek in Alternative Plan 2, the'Preferred Plan.
18 The current Preferred Plan, Alternative 2, is not
19 consistent with the National Contingency Plan, and
20 therefore is not acceptable. We fear that in less than
21 30 years, the cap will be compromised and the Raymark
22 property will be in approximately the shape it is right
23 now, with contaminants, still unmoved and the EPA still
24 telling us they will study it later. Who then will be
25 responsible for the problem? It will be the same
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1 problem that the community of Stratford faces tonight.
2 The Dock would like nothing better than to
3 see the Raymark site cleaned up and put back on the tax
4 roles. Commercial activity of any kind would be a
5 welcome alternative to the aging industrial site we see
6 every day. We want to see the source of major
7 contamination of the groundwater and Ferry Creek
8 cleaned up before it is capped and paved over. It
9 simply defies logic and factual evidence for the EPA t.o
10 acknowledge that the Raymark site is a significant
11 source of pollution (the NPL listing, April, 1995) arid
12 then restrict access for future site cleanup by
13 prematurely capping the site. Environmental effects on
14 the entire community, including Ferry Creek, Housatonic
15 River, and area groundwater resources, need to be
16 addressed as part of any site cleanup plan.
17 . Unfortunately, the EPA did not use the time it had to
18 make those studies prior to this juncture. If the
19 groundwater migration and Ferry Creek had been
20 investigated in a timely manner, then there could have
21 . been a more comprehensive plan for remediation
22 developed which would have addressed the impact of the
23 plan on the Town -of Stratford's resources. The plan
r
24 before us inadequately addresses contaminants at the
25 Raymark site, ignores precedents established by past
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1 practices of the EPA at other similar sites, and
2 threatens our Town's groundwater and surface water
3 resources.
4 The future of Stratford's economic and human
5 health depends directly on the Housatonic River and its
6 capacity to sustain life. The Shakespeare Theater is
7 another key to sustaining the economic health of the
8 town and future. We believe it is irresponsible,
9 shortsighted, and not in the community's best interest
10 to execute a remediation plan that threatens the
<
11 vitality of the Housatonic and that of Ferry Creek.
12 There is nothing specific in the preferred plan before
13 us that offers any criteria for off-site impact
14 assessment or the evaluation of the risk to any
15 ecological system beyond the borders of the Raymark
16 property. As we all know all too well, the impact of
17 Raymark's past has extended beyond the site's
18 boundaries. I find it ironic that in addressing the
19 Raymark remediation, the EPA simply wants to pull the
20 covers over the site and ignore the monsters that lurk
21 under the bed.
22 We have been neighbors of Raymark's for more
23 than 50 years, and we look forward to the day when the
24 site is reclaimed and active again. . We also want a new
25 neighbor that will not continue to degrade Housatonic
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1 River and Ferry Creek. According to the EPA itself,
2 Alternative 3 provides three key elements missing in
3 the Preferred Plan, Alternative 2. Alternative 3 more
4 thoroughly complies with existing federal regulations.
5 The proposed excavation and off-site disposal in
6 Alternative 3 eliminates a significant health threat.
7 The third alternative with, its excavation and off-site
8 disposal also eliminates a source of groundwater
9 contamination. Alternative 2 does not offer anything
10 .but a premature installation of' a cap. It is a
11 non-solution to a problem that has gone on for too many
12 years. It is now time to deal with Raymark
13 comprehensively and completely unless we want our
14 children and grandchildren to be dealing with it. The
15 Dock is currently preparing a response to help the EPA
o
16 protect our environment. We anticipate this.response
17 to include the results of our investigation, ,the
18 identification of specific areas that have not been
19' addressed and yet are vital to the protection of our
20 community, and a site cleanup plan that incorporates
21 more cost-effective and protective, long-term remedial
22 solution.
23 MR. CAVAGNERO: Chris Kopley, Clem Naples,
24 Rebecca Soukup, Jim Killer, Steve Garvey, Anne Kelleher
25 Smith. .
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1 MS. SMITH: I became involved back in '93
2 when Mr. Parker came to town and we had a meeting at
3 Stratford High with about 400 townspeople, and he
4 frightened the mothers and babies almost to death.
5 There was crying and hysterics, and something didn't
6 ring right with me. A professional person does not
7 come in and scare a community the way Mr. Parker did.
8 So I took it upon myself to try to read up on
9 everything that came into town. And in the beginning
10 at the Stratford Library, where all information was
11 supposed to be put, there was generic information like
12 "Lead in your Child."
13 About a month ago, 25 volumes, as Mr. Sammis
14 mentioned and I saw your little yellow marker; I
15 knew someone else was there arrived. And I thought,
16 "Oh, good, maybe there's some answers to all of my
17 questions." I joined SCAC in the beginning because we
18 had questions. They've done a fabulous job of asking
19 them. To this date, we do not have answers. I read
20 all the notes, even though I was not able to go weekly,
21 monthly to all the meetings. You guys have tried
22 desperately to get answers to questions.. We still
23 don't have them. All those volumes, 24, that take up a
24 whole wall of the library, there's, no answers to any of
25 our questions.
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1 There's even more questions, as Mr. Sammis
2 brought up, in terms of the water. Your last meeting,
3 you said you were not going to deal with the
4 groundwater problem because no studies were done on it.
5 There's plenty of information in those volumes on
6 groundwater and you're not dealing with them at all.
7 $40 million has been spent so far. For what? We have
8 capped residential, Wooster, the ball fields down near
j»
9 the park, and now we're talking about digging it all up
10 and bringing it over to Raymark and capping it there
11 because the one line would cost too much to take all of
12 the contaminated soil out of Raymark.
13 Of the 24 volumes of information, there's
14 nothing that answers any of our problems. Now, let me
15 go back and ask a couple of questions. This 15-page
16 was the most interesting out of the 24 volumes. It's
17 called "The Community Relations Plan, Raymark Industry
18 Site and Surrounding Areas for U. S. Environmental
19 Protection Agency" by Halliburton NUS Corporation, I
20 would like to know how much they were paid for this
21 study.
22 ' Let me just read the description of our town.
23 ' "Community background: Stratford is located
24 ..immediately east 'of Bridgeport on Long Island- Sound in
25 . Fairfield County. Its residents are among those with a
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1 moderate to average income. Much of Stratford's
2 population in the first half of the century was
3 employed by one of several aviation-related industries.
4 Among its distinguishing characteristics, Stratford has
5 a significant older population" I wonder how they
6 survived all of those contaminations "and the
7 largest number of real estate agents of any community
8 in the state."
9 Now, as a real estate agent> I find that
10 interesting. It's not factual, but why would whoever
11 was paid big money on a one-paragraph describing our
12 community have to put in a whole sentence that we have
13 the largest number of real estate agents of any
14 community in the state? Also, that we have a
15 population of Spanish-speaking residents, and a
16 significant number of residents living in public
17 housing. Now, is that anyone in this room's
18 description of Stratford? That's it.
19 I went and read through all 24, I didn't read
20 it word for word, I don't understand a lot of the
21 tests, borings, and lab results, but I don't have to.
22 I was looking for answers to the questions that we
23 . raised two years ago. The health results. You lined
24 up mothers hysterical with babies in the heat for lead
25 levels. We still don't have any results on that. The
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1 cancer study, it's still the old facts that there is no
2 significant difference in Stratford than any other
3 community. Now we want to wait and decide whether
4 we're going to take the soil from Wooster and put it on
5 Raymark's and then maybe be liable. Well, if it's good
6 enough to cap on Raymark, why isn't it good enough to
7 leave it alone at Wooster? Why can't you let the kids
8 play on .those fields?
9 Also, I didn't see any connection with
10 Attorney Barry Knot's Leach Family holding who's
11 interested in developing this. At the last meeting
12 there was all kinds of information, the site plans.
13 There is no technical information in the library
14 analyzing what is involved in this and connecting it
15 with what you're going to do there. Also, I know and
16 it says on the front of your proposal that in
17 accordance with the Comprehensive Environmental
18 Response Compensation and Liability Act, Section 117,
19 the law that establishes the Superfuhd program, certain
20 things have to be done. And yes, technically, you did
2.1 them. You did establish a Citizens Advisory Committee.
22 I don't know if .they even know that that's what they
23 are; They are technically established to meet the
24 . requirements of this law. , . .
25 You established a medical I don't know
{
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1 what you call it, but there is no information in those
2 24 volumes from the Stratford Health Department survey.
3" There is no information from the health effects study
4 funded by the ATSDR at the library. There is no
5 information on the lead screening program. There is no
6 information on the Public Works screening program.
7 So technically, on the surface you've
8 accomplished the law, but in terms of real facts and
9 information, you have come in and hurt Stratford. And
10 as a real estate agent and as a person who has lived
11 here and loved Stratford, to see what you've
12 accomplished -- this was my time to say it and I took
13 it. Thank you.
14 MR. CAVAGNERO: Ann McCrory. Is it Lori
15 Henderson?
16 MS. HENDERSON: My name is Lori Henderson.
17 I'm a member of SCAC. A couple of days ago I called
18 . Liza Judge in regards to the fill that was put in
19 between Long Beach and Pleasure Beach. She told me
20 that the fill was taken out of Housatonic River.
21 Housatonic River is in bad shape. So is our Sound. We
22 need to find out whether or not this: contamination came
23 from Raymark or if it happened naturally, which I don't
24 think it did. Let's think of our river, our Sound,
25 community, and wildlife. If we don't do this right the
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1 first time, we'll be doing this again in 10, 20 or 30
2 years. Let's hold these owners responsible in court
* .
3 now, even if it means that they go bankrupt. They
4 didn't care about us. Why should we about them? And
5 with this going on, let's get our legal system changed
6 by letting our town, state, and government officials
7 know that this can't and will not be tolerated again.
8 Let's not let companies all over our country make money
9 by contaminating our earth. We only have one. Let's
10 keep it clean. DEP and EPA officials, you are here to
11 help. Let's do this right now. Thank you.
12 MR. CAVAGNERO: Rudy Weiss.
13 MR. WEISS: Rudy Weiss, Councilman-at-Large,
14 Town of Stratford. I just want to take a couple
15 minutes to echo my support for the concerns of Elaine
16 O'Keefe and the Stratford Citizens Advisory Council
17 regarding the site cleanup. And I would also just like
18 to ask that during this process as problems and
19 conflicts arise that the EPA continue the spirit of
20 cooperation in working with the Town and the neighbors
21 to remedy problems that are bound to come up during
22 this.process.
23 I also want to take a few minutes tonight
24 because I thought it.would be proper to thank a few
25 people that have spent an awful lot of time and been a
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1 huge help to the Town regarding this whole issue. And
2 I'd like to start with Elaine O'Keefe, Andrea
3 Boissevain, Bill McCann and Mike Barnart from the Town.
4 And I'm sure there's probably some other people that
5 I'm not as aware of that put so much time and effort
6 into the handling of this situation as something that's
7 been very time-consuming and complex over the past few
8 years.
9 I'd also like to thank the Stratford Citizens
10 Advisory Council, who have been the eyes, ears, and
11 voice of the Town through this process and have been a
12 huge help not only for the Town administration, but for
13 the Town Council. And I know there's more than this,
14 but the people I've worked with over the past year,
15 Janet Carlucci, Angie DeMello, Cindy Kaplan, and Don
16 Patterson. I know there are a number of other people
17 that also deserve a lot of thanks on behalf of the
18 Town,
19- And in closing, I'd like to also thank the
20 EPA and DEP, who have worked together with the Town
21 throughout this process to speed the cleanup up and to
22 also minimize the inconvenience of the Town as much as
23 they could and also the Town's future liability. The
24 speed and I know there are some concerns tonight
25 that need to be addressed a .little bit further, but the
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1 speed at which this is moving forward is lightning
2 fast, considering the situation, and my personal
3 feeling is that the faster this is done and done right,
4 the better off the town is going to be, both
5 economically, just a perception, and I think
6 everybody's overall well-being. And I just wanted to
7 make sure that we don't forget that we have .a lot of
8 work left yet with the EPA and DEP, and hopefully we
9 can continue the good work that's gone on so far.
10 Thank you.
11 .MR. CAVAGNERO: John Gloria. Kim Sterling.
12 MS. STERLING: I feel somewhat obliged to my
13 fellow SCAC members to say a little something in
14 defense of our group. I don't think any of us feel as
15 though we've been pawns by the establishment. Every
16 other Wednesday a group of citizens who come from all
17 walks of life meet in the basement of the library
18 because we all love this town and we all want to see
19 that the right thing is done. So I certainly don't
20 feel that we were played for a dupe or anything like
21 ' that.
22 My biggest concern about this plan is in the
23 .actual implementation of the demolition of the Raymark
24 building itself. I am a mother of two small children.
25 And fortunately, I've done enough reading to know that
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1 there is such a thing as ambient fallout regardless of
2 precautions that are going to be taken at the site.
3 And I would certainly do my very best to keep my
4 children away because they're very small bodies and
5 they're much more vulnerable to this kind of thing than
6 grownups are.
7 It's unfortunate that the actual site itself
8 isn't painted with bright yellow and blue markings.
9 People tend to think that if they can't see it- then,
10 well, it's probably not really there and it's not so
11 bad. They also tend to operate under the mindset that
12 if something is not an imminent threat, if people
13 aren't dying in droves tomorrow or next week that there
14 is not a real cause for concern, and that's not the
15 case. I know, as the people at the EPA know, as the
16 ATSDR know, as the health department knows, there are
17 things that have a cumulative effect that may not
18 manifest themselves for 15 or 20 years. But how sad
19 for me as a mother to think that one of my children
20 could possibly be diagnosed with some bizarre form of
21 ' cancer when they're in the prime of their lives.
22 So that's the concern that our group is
23 operating'under. And I would really strongly request
24 that while- the demolition is occurring neighborhood
25 forums do take place to notify, people in the area,
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1 people who may not know about it or even maybe care
2 about it. There are an awful lot of mothers coming in
3 and out of Stop & Shop. And you know, we certainly
4 don't want to damage their business, but I think we
5 really need to take in account that we need to protect
6 people who may not know about it. Thank you.
7 MR. CAVAGNERO: I've got one more name which,
8 I'm sorry, I cannot read. It's Steven W. from Shelton,
'9 Mizia. . ....
10 . MR. MIZIA: I happened to read the news and I
11 saw this article, and I'm with an environmental
12 remediation outfit in New Jersey. But this is close to
13 home and anything close to home I get involved in or
14 try to find out what's going on with it. I'd just like
15 to ask a couple questions, though. Is the lead
16 -content, which is 10,000 parts per million, that's
17 totals or is that TCLB's?
18 MR. CAVAGNERO: We're not going to do
19 questions and answers during the hearing, but we'll be
20 happy to do it afterwards.
21 MR. MIZIA: I was just curious about that.
22 And how many yards of that. Those are my questions.
23 You have similar situations in New York and places in
24 Connecticut with these type of toxics, and all _sites
25 are different and how you implement your program is
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1 basically related to site specific. All sites are
2 different. But I just wanted to ask these questions
3 because I was curious-about what's going on around my
4 area. And I've been involved in waste energy
5 facilities all over the United States, including
6 Connecticut, so I wanted to know more about what's
7 going on here.
8 MR. CAVAGNERO: Mike will be happy to speak
9 to you when we're through, either Mike. Is there
10 anyone who hasn't signed up who would like to make a
11 statement for the record? He can ask his questions for
12 the record, if he'd like. All I'm saying is we're not
13 answering questions. The answers will come as part of
14 the Responsiveness Summary. He can ask them if he
15 wants. If he wants the questions and answers on the
16 record, he can do that, or he can ask them informally
17 afterwards. Either one. Could we have your name, sir?
18 MR. HARGUS: Ed Hargus. All I want to know.
19 is who's paying for this project? Is the taxpayer,
20 Town of Stratford? I'm very disturbed. The reason I'm
21 disturbed is there's so many homes for sale, and I'm
22 wondering if this toxic business has something to do
23 with it. And if we have to pick up the tab as a
24 taxpayer, I think I'm ready to move out myself. It
25 give us some bad publicity in this town, and I don't
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1 think it was really needed. I didn't believe in this
2 toxics. I worked in Raybestos for one year. I played
3 on them softball fields for 40 years. I'm 73 years
4 old. I'm still here. No cancer, no nothing. I'm
5 still chasing women. So that's the reason I don't
6 "believe them.
7 Another thing is we're letting this developer
8 get off the hook. I think he should pick up the tab
9 for some of this, some of this work that's got to be
10 done. You know, everybody is looking,-these developers
11 are looking for everybody to do their work for them and
12 then they come in arid they start dictating the town.
13 Now, we don't need any more stores, any more in town
14 because we've got a lot of stores now that are empty.
15 So a project like that is not going to do Stratford any
16 good. We're looking for maybe some kind of small
17 industry in there, clean industry, that's going to pay
18 decent wages. Now, these stores are only going to pay
19 five-dollar minimums. So that's not going to help the
20 families in this town.
21 I don't like to lose the tax base that's .
'" '
22 going to go in there, but we got to think this thing
23 out before it goes through with it. We've got to get
24 . something better than stor.es in there; otherwise, I
25 don't believe in the project at all. So you guys look
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1 at it at a different view than the average taxpayer
2 does. You know, and we need industry, that's what we
3 need, some clean industry that will pay a decent wage
4 to a decent guy or a decent gal. Stores are not going
5 to do the work for us.
6 As far as the runoff, the water runoff, I go
7 along with Mr. Sammis. There's a guy that's very, very
8 knowledgeable in this town. I wish he was the Town
9 Manager, to tell you the truth. But if you listen to
10 this fellow, he knows what he's talking about. And
11 runoff is very important. So like I said, I just don't
12 simply don't believe in what's happening, and I wish
13 you'd look at it at a different view. Thank you.
14 MR. CAVAGNERO: Is there anyone else who
15 would like to would you like to get your questions
16 on the record?
17 MR. MIZIO: Yes, I think that might be
18 helpful. If the 10,000 parts per million is totals or
19 is it 10,000 parts per million of lead? That must be
20 totals, not the leachable, the TCLPs. I'm just curious
21 what the TCLPs are.
22 MR. HILL: We'll answer you after.
23 MR. MIZIO: Okay.
24 MR. CAVAGNERO: If anyone read from a
25 prepared text and would like to, we'd appreciate if you
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1 could leave the stenographer a copy of that to make
2 sure we get it accurately transcribed, if that's
3 possible.
4 If there is no one else who'd like to make a
5 comment for the record, I'd like to thank you all for
6 coming. And I remind you again that those who did not
7 make comments or who did make comments may still submit
8 any written comments in addition to what you^ve said
9 tonight or have chosen not to say. You have to get
10 them postmarked, no later than June 8, sent to Michael .
11 Hill. And the address is in the Proposed Plan, which
12 hopefully you have a copy of. If not, there are extras
13 on the table in the back of the hall. And like I said,
14 we'll be here for another hour or so and be happy to
15 speak to anyone that has any questions. Thank you very
16 much.
17 (The following questions were submitted in
18 writing by John Gloria of 250 East Main Street,
19 Stratford, Connecticut, 06497.)
20 "How did EPA determine where Raymark had
21 deposited their waste?"
22 "How would anyone know if their site has had
23 waste deposited on it?"
24 ' ' ' " '
25 (The Hearing was officially closed at 8:35 p.m.)
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CERTIFICATE
I hereby certify that I am a Notary Public,
in and for the State of Connecticut, duly commissioned
and qualified to administer oaths.
I further certify that the record of the
proceedings held in this matter was taken by me
stenographically in the presence of counsel and reduced
to typewriting under my direction, and the foregoing is
a true and accurate transcript of said proceedings.
I further certify that I am neither of counsel
nor attorney to either of the parties to said matter,
nor am I an employee of either party to said matter, nor
of either counsel in said matter, nor am I interested in
the outcome of said cause.
Witness my hand and seal as Notary Public
this \ day of lUl£- 1995.
'Notary Public
My Commission expires:
bo , \°\o,tp
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ATTACHMENT C
SUMMARY OF QUESTIONS AND ANSWERS FROM THE
OPEN HOUSES, APRIL 8 AND 11. 1995
-------
EPA OPEN HOUSE MEETING SUMMARY
STRATFORD PUBLIC LIBRARY
STRATFORD, CONNECTICUT
APRILS AND 11, 1995
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RAYMARK II
STRATFORD, CONNECTICUT
For
U.S. Environmental Protection Agency
By
Halliburton NUS Corporation
EPA Work Assignment No. 47-1LH3
EPA Contract No. 68-W8-0117
HNUS Project No. 4847
April 1995
/sSi Halliburton MIS
* CORPORATION
-------
EPA OPEN HOUSE MEETING SUMMARY
STRATFORD PUBLIC LIBRARY
STRATFORD, CONNECTICUT
APRILS AND 11, 1995
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RAYMARK II
STRATFORD, CONNECTICUT
For
U.S. Environmental Protection Agency
By
Halliburton NUS Corporation
EPA Work Assignment No. 47-1LH3
EPA Contract No. 68-W8-0117
HNUS Project No. 4847
APRIL 1995
-------
TABLE OF CONTENTS
EPA OPEN HOUSE MEETING SUMMARY
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
RAYMARK II
STRATFORD, CONNECTICUT
SECTION
1.0 INTRODUCTION 1
2.0 SUMMARY OF PRESENTATIONS 1
3.0 COMMENTS AND RESPONSES . 2
3.1 Proposed Cleanup Plan 2
3.2 Other Alternatives -. . 5
3.3 Costs . . . 5
3.4 Site Re-Use 6
3.5 Off-Site Impacts, Including Groundwater 7
3.6 Risk Assessment 9
3.7 Miscellaneous 9
4.0 EPA COMMITMENTS 10
APPENDIX
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1.0 INTRODUCTION
On Saturday, April 8, and Tuesday April 11, 1995, the U.S. Environmental Protection
Agency (EPA) hosted open houses to present its proposed cleanup plan (attached in
the appendix) for the Raymark Industries, Inc. Superfund Site to the public. The
events, held in the Lovell Room of the Stratford Public Library, began at 11:00 am and
ended at 3:00 pm (on Saturday, April 8) and began at 4:00 pm and ended at 8:00 pm
(on Tuesday, April 11). Thirty-four people signed the sign-in sheet on April 8,
including the Town Manger and Chair of the Waterfront Harbor Committee, four
representatives of the State (Department of Environmental Protection - DEP and
Department of Public Health and Addiction Services -DPHAS), four representatives of
the media (The Fairfield County Weekly, the Bard, the Connecticut Post, and WICC
radio), five members of Stratford Citizens Advisory Committee (SCAC), and three
representatives of Leach Family Holdings (who hold a purchase and sales agreement
for the Raymark Facility). Approximately 50 people attended the April 11 event,
including the Stratford Health Director and Town Engineer, five representatives of the
State (DEP, DPHAS, and the Department of Transportation - DOT), four members .of
SCAC, two persons representing Raymark, one person representing Raytech, and
three representatives of Leach Family Holdings.
The meetings were held to discuss the results of the Remedial Investigation (Rl) and
risk assessment, describe the remedial alternatives evaluated in the Feasibility Study
(FS), and articulate the components of the proposed source control cleanup plan.
From 11:00 am to 12:30 pm (on April 8) and from 4 pm to 6:30 pm (on April 11),
those attending the open house were able to review aerial photographs of the site and
poster boards depicting the highlights of the Rl, the FS, and the proposed plan and ask
one-on-one questions of EPA staff. A question and answer session folio wed the forty-
five minute presentations, ending at 1:42 and 7:53, respectively.
2.0 SUMMARY OF PRESENTATIONS
Wendy Hyman, from the Fairfield County League of Women Voters, who volunteered
to be the open house moderator, opened the one and one-half hour presentation
session (12:35 pm on April 8 and 6:30 pm on April 11), and introduced the speakers.
They included Liza Judge, the site Community Involvement Coordinator; Michael Hill
and Michael Jasinski, Remedial Project Managers, and Margaret McDonough, Risk
Assessor, from EPA. Ms. Hyman reviewed the agenda (attached in the appendix) and
outlined the presentation ground rules (the project only addresses waste at the
Raymark Facility, and excavated residential and Wooster School soils consolidated at
the Raymark Facility). At the April 11 meeting, she also indicated that all questions
should be written on the 3 by 5 inch cards that were passed out. Ms. Judge then
reviewed the three methods of participating in the public comment period process and
encouraged those in attendance to write their comments on the single-sheet handouts
available by the sign-in sheet. Mr. Hill reviewed the history of the site, stated that to
-1-
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date, excavation had been completed at 29 of 41 residential properties that had
Raymark waste, and described the highlights of the Remedial Investigation through
use of overhead graphics and slides. Ms. McDonough discussed Chapter 6 of the Rl
report, the baseline human health risk assessment. She also indicated that no
ecological risk assessment was performed because no significant amount of wildlife
habitats or ecological receptors existed on the site. Through use of overhead
graphics, she described the risk assessment process, the contaminants of concern,
and the potential human population that was evaluated in the assessment.
Mr. Jasinski identified the existing threats to the public and groundwater if action is
not taken at the site, described the remedial alternatives evaluated in the FS,
discussed the components of EPA's proposed cleanup plan, and identified the nine
criteria EPA uses to evaluate remedial alternatives. Ms. Judge described the criteria
the public should focus on in providing public comments on the proposed cleanup plan
and confirmed the public hearing date of May 4, 1995, at 7:00 pm in Council
Chambers.
Ms. Hyman then opened the session to questions and answers.
3.0 COMMENTS AND RESPONSES
Questions and answers from the open houses have been merged into one summary
to provide a broad picture of issues of concern to Stratford citizens. The topics
covered have been grouped: proposed cleanup plan; other alternatives; costs; site re-
use; off-site impacts, including groundwater; risk assessment; and miscellaneous.
3.1 Proposed Cleanup Plan
Comment: Will it actually take 1 to 4 years to complete the cap?
Response: Mr. Jasinski indicated that a 33-acre area typically takes this long to cap.
However, since the developer is on a fast track, cleanup activities may
have to be speeded up. For example, the excavation of the Wooster
Middle School and the remaining residential parcels would have to be
completed immediately and building decontamination/demolition may
have to be performed for more than eight hours a day and on weekends.
EPA will keep the community informed.
Comment: Will implementation of Alternative 2 hamper the litigation against
Raymark?
Response: Mr. Hill indicated it would not.
-2-
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Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
Comment:
Response:
The chart on page 7 of the proposed plan indicates that Alternative 2
would only partially provide long-term protection. Why is that?
Mr. Jasinski stated that all caps involve some uncertainty. The concern
involves cap maintenance and the existence and enforcement of
institutional controls such as local ordinances. As long as controls and
monitoring are conducted properly, long-term protection is ensured. If
maintenance and enforcement could be guaranteed, the half circle would
be an open circle, indicating it meets or exceeds the criteria.
Does the half circle indicate that something could happen to the cap to
keep it from being effective?
Mr. Jasinski stated that nothing should happen to keep the cap from
performing as expected if it is properly installed and maintained. The cap
itself should be approximately 3 feet below the surface.
What is the expected life of the cap?
Mr. Jasinski responded that EPA typically assumes 30 years for costing
purposes. Caps are permanent remedies, provided necessary
maintenance is performed. Monitoring will help tell if the cap is
functioning properly.
Could the cap handle the weight of heavy machinery? What about
installing a foundation?
Mr. Jasinski indicated that the cap could be constructed to
accommodate construction and buildings.
Who will be responsible 50 years from now for cap maintenance?
Mr. Jasinski said that in situations where funding for site cleanups
comes from the Superfund Trust, the state must pay for 10 percent of
the costs (the operation and maintenance provisions). Five million dollars
of the $40 million estimate for the proposed cleanup plan is for operation
and maintenance. The state must ensure future maintenance of the
remedy.
Comment:
Will the developer maintain the pavement?
ensure this is done?
What is our recourse to
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Response: Mr. Hill indicated that any developer would have to sign a prospective
purchaser agreement that would address these kinds of responsibilities.
The incentive to sign would be the trade-off for liability protection.
Comment: How would airborne contamination be contained during demolition?
Response: Mr, Jasinski indicated that among the control options are wetting the
material or conducting the activity under a tent-like structure. Since the
capping option is still out for comment, the design features of the
cleanup have not been identified. Once an approach has been proposed,
EPA would seek the public's view on details of the demolition activity.
What does the vapor collection system do?
Mr. Jasinski said it collects potential VOC gases generated and protects
the cap. The VOCs collected would be treated with activated carbon.
Has the vapor control system you are proposing for the cap been u$ed
successfully elsewhere?
Mr. Jasinski stated that caps and vapor control systems are a standard
approach in dealing with landfills. These devices have been used in
tandem many times.
Would EPA select Alternative 2 if the developer was not in such a hurry?
Mr. Hill indicated that Alternative 2 is the most logical alternative to
implement based on EPA's evaluation of the criteria. Mr: Jasinski stated
that EPA supports the Town's position that cleaning up this facility is a
priority, because of its re-development potential.
Comment: How would the sewer line be repaired if the cap was lying over it?
Response: Mr. Jasinski stated that this issue was recently discussed with the
potential developer and will be discussed with the Town Engineer in the
near future. EPA has been exploring whether the line could be relocated
to an off-site route. EPA may also design the cap so the sewer line
could be repaired on site by lining the existing pipe.
Comment:
Response:
Comment:
Response:
Comment:
Response:
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3.2
Other Alternatives
Comment: What is the difference between Alternatives 4 and 5?
Response:
Comment:
Response:
3.3
Comment:
Response:
Comment:
Response:
Mr. Jasinski stated that Alternative 4 would excavate facility waste and
dispose of it off site. Alternative 5 would excavate the waste and treat
it on site. In both cases, waste below the water table would remain on
site.
Are there any facilities that could accept the waste that would be
generated by implementing Alternative 4?
The treatment options evaluated for on-site treatment include
solidification to treat the lead and thermal desorption to address PCBs
and solvents! Both were analyzed in treatability studies conducted on
Raymark waste. A question exists whether there are vendors that can
accommodate the vast waste volumes to be treated under Alternatives
4 or 5. Of course, anything can be done for a high enough price.
Is the cost of the five-year review factored into the costs indicated in the
proposed cleanup plan?
Mr. Jasinski indicated that it is, and is stated in terms of present worth.
Of the $40 million estimated to implement Alternative 2, $35 million is
the cost for the cap (and $10 million of that $35 million is for
decontamination and demolition). An estimated $5 million would be
used for long-term monitoring and five-year reviews over the 30-year
period assumed for costing purposes.
Why isn't Raymark paying for all this? Where will the $40 million come
from and to whom will it be paid?
Mr. Hill stated that EPA is currently in litigation with Raymark. He is
sure Raymark will have to pay but the actual amount is in question since
the issue is part of a settlement that involves all those suing the
company, including people with health problems caused by exposure to
asbestos. This should be resolved within a year or so. .
Mr. Jasinski indicated that money for the cleanup will be borne by the
Superfund Trust Fund and that the US Army Corps of Engineers will be
conducting the cleanup design. The Corps has hired Foster-Wheeler to
do the actual cleanup.
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Comment: How much will the groundwater cleanup cost?
Response: Mr. Jasinski indicated that he had no idea how much it would cost
because insufficient groundwater data exists. The groundwater study
EPA will initiate may show that no remedial action is necessary.
Comment: What would it cost to excavate all the waste, not just the waste above
the water table?
Response: Mr. Jasinski stated that alternative had not been analyzed but that he
would guess that such activity would involve approximately 550,000
cubic yards and would cost approximately 2 to 3 times the $1 billion
estimate for Alternative 4.
Comment: How were the costs developed?
Response: Mr. Jasinski stated that the costs specified in the proposed cleanup .plan
are not design costs. They are estimates calculated on assumptions
developed on the concept embodied in Alternative 2. According to EPA
guidance, the costs estimated in the FS could increase by as much as 50
percent or decrease by 30 percent.
3.4 Site Re-Use
Comment: If the proposed plan is implemented, what type of commercial activity
could be allowed?
Response: Mr. Jasinski indicated that EPA policy encourages site re-use. However,
EPA is not involved in any decisions about what type of development
could occur on site except that any development that would not damage
the cap would be acceptable. A developer would have to work closely
with EPA to ensure that its plan and the EPA cleanup plan were
compatible. For instance, the pilings could be extended early in the
process so the cap could be laid around them. Raymark and a potential
developer of a retail establishment (Leach Family Holdings) have signed
a purchase and sales agreement; representatives of Leach Family
Holdings are here and any questions concerning the development plan
should be directed to them after the question and answer session.
Comment: The graphic of the mall configuration the representatives of Leach Family
Holdings have on display indicates extensive plantings on the property.
Will they hurt the cap?
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Response: Mr. Jasinski observed that the types of plantings would have to be
limited by their potential impact on the cap. The Town of Stratford is
also considering a zoning ordinance on large trees. The cap design
envisions 2 feet of soil to control drainage and parking lot impacts.
\
Barry Knott, a local attorney hired by Leach Family Holdings, stated that
the developer intends to plant the trees in earthen berms; only plants
with shallow roots will be allowed.
Comment: I want to hear more about the proposed redevelopment.
Response: Ms. Judge recommended that since the focus of the open house was to
discuss the proposed cleanup of the Raymark Facility, anyone interested
in talking about site redevelopment could discuss the matter with Leach
Family Holdings representatives after the meeting. Mr. Jasinski assured
the audience that the proposed redevelopment plan had no effect on
EPA's proposed cleanup plan.
3.5 Off-Site Impacts. Including Ground water
Comment: What is the fate of the contamination that would be buried under the
cap?
Response: Mr. Hill stated that it could be there forever. Solvents are the primary
contaminants found on the site that migrate; the proposed cleanup plan
envisions removing solvent pockets. Since the other contaminants are
less likely to migrate, they are not as great a threat to groundwater,
which the EPA will be investigating soon. Even if a groundwater
problem is determined* it would not affect the capping proposal because
qontaminated groundwater typically is addressed by pumping through
extraction wells.
Mr. Jasinski reminded the audience that the cap would keep water from
seeping into the waste from above, so leaching would be reduced.
Comment:.._ Why has EPA separated cleanup7 of the soil and the groundwater?
Is EPA not dealing with it because Raymark did not monitor the
groundwater?
Response: Although there are many monitoring wells on site, Mr. Jasinski reiterated
that no monitoring wells were installed downgradient of the Raymark
Facility so EPA does not know what impact contaminated groundwater
is having off site, including on the Housatonic River. Raymark is not the
only possible source of groundwater contamination in the area. EPA will
-7-
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need to initiate and complete a comprehensive study of the ground water
and may come back in a public forum proposing a groundwater cleanup
strategy. In the interim, EPA has proposed to remove the concentrated
pockets of liquid solvents to reduce the release of contamination to the
groundwater.
Comment: How much contaminated groundwater has gone beyond the site?
Response: Mr. Hill stated that EPA has no idea how much or how far it has gone,
only that it is flowing off the site.
Mr. Jasinski indicated that of the site contaminants, the solvents are the
ones that would migrate but they would not likely have ecological
impacts. EPA also needs to determine if recreational impacts should be
reviewed.
Comment: Will laying the cap impede any groundwater cleanup?
Response: Mr. Hill stated that it would not. The groundwater study will analyee
data collected from off-site wells. If analysis of these samples indicates
a risk, one alternative could be to pump and treat the groundwater
through wells installed at the edge of the Raymark Facility property. If
the study indicates no risk exists, no pumping would be necessary.
Comment: Does the big sewer pipe across the property leak TCE?
Response: Mr. Hill stated that the pipe contains sanitary waste and not chemicals.
However, the path in which the pipe lies could be a conduit for
contamination.
Comment: Is there any evidence that the Raymark Facility waste was in the
Housatonic River?
Response: Mr. Hill stated that none had been found yet. Disposal areas from the
facility exist along the river. Raymark discharged its wastewater to Ferry
Creek for many years. Ferry Creek continues to flow to the Housatonic
River. EPA is currently investigating the extent of contamination in Ferry
Creek and, if necessary, the Housatonic River.
Mr. Jasinski added that fish sampling has been completed in various
ponds around town. DPHAS will be issuing a press release on the
results in the next few weeks.
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3.6 Risk Assessment
Comment: What cleanup levels are EPA using and how are they derived?
Response: Ms. McDonough explained that no soil cleanup standards exist; EPA uses
the results of the risk assessment to develop soil cleanup levels. Only
groundwater has cleanup standards (maximum contaminant levels
established under the Safe Drinking Water Act).
Comment: The risk assessment was conducted using only the 33 acres of the
Raymark Facility. What about the impact on people who live adjacent
to the facility? Are we safe?
Response: Mr. Hill said that to date, no airborne contaminants have been migrating
off .site at levels that pose a concern, based upon available sampling
taken at the Facility.
Comment: Was the risk assessment based on actual or hypothetical conditions?
Response: Ms. McDonough indicated that the evaluation is based on. the
hypothetical situation in which nothing is done to the site in the future.
3.7 Miscellaneous
Comment: Why wasn't the scientific information about the proposed cleanup plan
placed in the library until just recently?
Response: Ms. Judge indicated that the reports were completed last week
and were placed in the information repository at the library by the start
of the public comment period on April 8.
Comment:. Has the town hired a technical consultant to review this material?
Response: Ms. Judge stated that SCAC had not pursued obtaining a technical
assistance grant .from EPA to pay for a technical advisor. Elaine
O-'Keefe, Director of the Stratford Health Department, said that the town
had had a technical advisor but that Andrea Boissevain was now serving
in that capacity.
Comment: Will we be subject to suit by Raymark?
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Response: Mr. Hill reminded the audience that on January 10, 1995, EPA New
England Regional Administrator John DeVillars wrote a letter pledging
that EPA would protect Stratford residents from any suits by Raymark
resulting from the cleanup of residential properties.
Comment: What if the state disagrees with EPA's proposed cleanup plan?
Response: Mr. Jasinski stated that EPA has kept the DEP informed of the
development of the proposed cleanup plan; it appears the state is
supportive of the concept set forth in the plan . However, until EPA
receives written documentation from the state, EPA will not know the
State's official position.
Ms. Elsie Patton from the DEP indicated that her agency had reviewed
the proposed cleanup plan and concurred with its concept. However, no
official letter supporting the action has been sent.
Comment: What is brownfields?
Response: Mr. Hill related that it is an EPA initiative to expedite cleaning up
contamination in urban areas to lure back industry and shore up
communities' economic base. EPA has brownfields projects underway
in Bridgeport.
Comment: Will EPA clean up all the contamination in Stratford?
Response: Mr. Hill stated that 29 of the 41 residential properties identified as
needing excavation have been completed to date. The remaining 12 will
be finished by the fall. EPA expects that the proposed plan for dealing
with commercial properties and Ferry Creek will be in place by the
summer of 1996. The state is dealing with municipal properties.
Ms. Judge reminded the audience of the three ways to participate in commenting on
the EPA's proposal and requested that comments focus on criteria numbers 3 through
7 identified on page 7 of the proposed cleanup plan.
4.0 EPA COMMITMENTS
1. EPA will keep the community informed of issues involved in the
decontamination/demolition construction schedule, including extended hours,
weekend work, etc.
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APPENDIX
-------
&EFA
New England
Superfund Program
April 1995
Proposed Cleanup Plan
Raymark Industries, Inc.
Stratford, Connecticut ________
for
The Proposed
Cleanup Plan
After careful study of the Raymark
Facility, the EPA has developed a
plan to reduce risks from the sources
of the facility's contamination. EPA
is proposing the following cleanup
plan that would:
Decontaminate and demolish
all buildings and structures
Remove the highly
concentrated pockets of liquid
(solvent) contamination from
contact with groundwater
Cover the entire facility with
a cap to prevent people from
coming into contact with the
contamination and to
minimize the amount of water
seeping into the waste
Ensure the integrity of the cap
try inspecting it regularly,
minimizing intrusive activities,
and monitoring groundwater
and surface water
More on the components of the
proposal appears on page 2.
Learn More About the
Proposed Plan's Potential
Effects on Stratford
Hie EPA will describe this proposed
plan and how it compares with the
other cleanup options evaluated for
the Raymark Facility, and respond
informally to yOUf qUGSUOns »"d
concerns at two informational open
houses.
Open Houses
Saturday, April 8, 1995
11:00 AM to 3:00 PM
(presentation and Q&A
12:30 to 1:30)
Tuesday. April 11. 1995
4.-00 PM to 8.-00 PM
(presentation and Q&A
6:30 to 7:30)
Lovell Room
Stratford Public Library
2203 Main Street
See page 8 for details.
Official EPA responses, however,
will only be provided if presented to
EPA at the May 4. 1995 public
hearing (7:00 PM at the Town Hail)
or submitted in writing anytime
during the 30-day public comment
period.
Tell Us What You Think ...
EPA is accepting your comments on
the proposed plan from Saturday,
April 8 through Monday, May 8.
1995. You do not need to be a
technical expert to comment. If you
have any concerns or preferences oa
this proposal, EPA wants to hear
them before making a final decision
on how work should proceed at the
Raymark Facility.
There are three ways tf formally
register a comment:
1. Write down your comments on
thg attached **"*ff. or on other
paper, and leave thqn with us a>
one of the two open bouses.
2. Send written comments
postmarked no later than
Monday, May 8, 1995 to:
Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, MA 02203
3. Offer oral comments during tht
public hearing scheduled for
Thursday, May 4, 1995. in
Council Chambers. Town Hall
(see page 8 for details).
In accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (Section 117). the U
that established the Superfund program, this document summarizes EPA's proposal for site cleanup to help the public
understand and comment on the proposal. For detailed information on the proposed cleanup plan and other options
evaluated for use at the facility, see the Raymark Facility Remedial Investigation and Feasibility Study available for
review at the information repository at the Reference Desk, Stratford Public Library, 2203 Main Street in Stratford.
: Priaud on RieyeM Ptpv
-------
A Closer Look at the
EPA's Proposal...
The cleanup proposal can be divided
into four principal component!.
This cleanup plan will address only
the soil-waste material being
excavated from residential properties
(approximately 40,000 cubic yards),
waste historically buried on the
Raymark Facility, and approximately
30,000 cubic yards of soil to be
removed and brought to the facility
from the Wooster Middle School.
The site map on page 3 shows the
locations discussed in thy following
paragraphs.
L THfYn^prinatf «"* Demolish
Facility Buildings and
Structures
All buildings and other structures on
the facility would be dnonntammated
and demolished. ^«-«^-«~«
building
would likely be
removed from the property and
appropriately disposed, while
uncontammated material may be used
to level the ground surface. It is
Wt mtmft
2. Remove the Highly
(Solvent) Contamination from
Contact with Groundwcter
Highly concentrated pockets of liquid
the i former acid neutraUzation pits and
the former toluene spffl area appear to
serve as a continuing source of
contamination to the groundwater.
These sources of contamination would
be removed to the reasonable extent
possible.
3. Cover the Entire Facility with
aa Impermeable Cap
A multi-layered barrier (cap) would
be constructed over dw facility to '
prevent people from coming into
contact with the contaminated soil
either by direct exposure (touching) or
by 'n"^**^*** ingesthm (accidentally
soil-waste material on the property
and moving thi« fr»qtMfflti«ti««i |QtO the
groundwater.
Two other important features would
be incorporated into the cap. One
would be to collect water that may
seep through the top layer of the cap,
but not into the waste, and discharge
it into a storm water drain. The
second would be to construct a piping
system to collect solvent vapon that
could potentially build up below the
cap and treat them in an on-site
omission control system.
Before the cap is constructed, the
residential properties and the Wooster
Middle School would be used to level
4. Ensure the Integrity of the Cap
S0VQIU
wOlalsobe
neceeaary to protect the cap and
the cleanup's effectiveness. Cap
inspections to ensure the system is
working as '*"'§""* Formal
restrictions on site use would prohibit
activities that could damage the cap.
Quarterly groundwater and surface
w«ttBr QKoilon&g would dotcxmoc tLw
quality of the water leaving the facility
and the effectiveness of the chosen
cleanup plan. Every five yean, EPA
would review site conditions to stiff i
whether the cleanup action is working
as punned.
The EPA will also begin additional
studies to further evaluate the
groundwater contantiiiff*!***! *w$ at the
same time; the effectiveness of the
chosen cleanup plan. The additional
information from existing and newly
installed groundwater monitoring wells
will allow the EPA to identify
potential groundwater cleanup options
in the future, if necessary. If they are
needed, these options would be
presented to the public for comment at
Why is Cleanup Needed?
The Raymark Facility field studies
contained in the EPA's Remedial
Investigation Report found the
following:
Waste exists throughout the
Raymark Facility.
The property contains
contaminants including asbestos.
lead, solvents, potyaromatic
hvuKMjufixais, ]
biphenyis (PCBs), and dtoxias
and furans.
nispffted to be flowing beyond
the facility boundary.
The Remedial Investigation Report
to public health, which quantified the
current and Aihm neks to workers
and trespassers to die property. This
: of risk concluded that
i (70 yean through
periodic accidental ingestion or skm
above presents a potential pubtic
health risk. No ecological risks were
I on the property.
From mis information, the EPA's
that
cleanup is needed to reduce the
p«««iti«i exposure to the <
to ensure the area is safe for those
who might, work on the property
during ""i""*"*"' activity, now and
in the future, and for trespassers.
Additionally, EPA determined that
mininiJTinf rainwater entering the
sated materials would reduce
contamination in the groundwater.
2 EPA Superiund Program Proposed Plan
-------
RAYMARK FACILITY SITE MAP
FORMER
ACID NEUTRALIZATION
PIT AREAS
LAGUON no a -
LAGOON NO. 3
FORMER TOLUENE
SPILL AREA
SPILL AREA I
LAGOON NO. 4
NOTE:
1. NOT TO SCALE - AU LOCATIONS APPROXIMATE
'r- UTH
III 5 I
rfN1
en
LEGEND:
APPROXIMATE PROPERTY LINE
BUILDING OUTLINE
FORMER COVERED
LAGOONS
TEMPORARILY STORED RESIDENTIAL WASTE
-------
Review of Site History
1919 - 1989: The plant manufactured automotive and
heavy vehicle friction parts. The production processes
generated waste by-products.
1919 - 1984: Waste by-products were disposed in
lagoons on the Raymark Facility property. As the
lagoons became full, waste was excavated and used as
fill on the Raymark property. Waste from these
lagoons was also used by the Stratford community.
1978 and 1993 present: The town and the Connecticut
Department of Environmental Protection provided cover
for a number of municipal properties, temporarily
protecting area residents from exposure to contaminated
wastes.
Fall 1992 - present: Win EPA oversight, Raymark
covered four lagoons, removed bags and containers
rilled with hazardous material generated from
manufacturing operations, secured the property with
fencing, boarded up buildings, and re-routed the on-site
drainage system to mmnnize movement of the
contamination off the Raymark Facility.
Spring 1993: Dioxins were discovered on the Raymark
Facility. ^*np**"t of fi'^'T^M, municipal, ""^
'"""""'' properties revealed extensive amounts of
lead, PGBs, and asbestos in areas where Raymark fill
was used in Stratford. The levels of these *»*tm***Mt»
were reviewed by the federal public health agency
(Agency for Toxic Substances and Disease Registry)
and an considered a health risk.
EPA began collecting and testing soil samples from
properties located throughout Stratford when Raymark
fill was suspected to have been used. To date,
approximately 40 msufcntial areas show contaminati
enough to need l*1*aning up.
Summer 1993: EPA began residential cleanups. The
excavated material has been tracked to and stored at the
Raymark Facility, pending EPA's decision on how best
to dispose of it. Cleanup of the last of these residences
is scheduled to occur in the fall of 1995.
Winter 1994: To provide long-term funding, EPA
proposed to add the Raymark Facility to the National
Priorities List, a roster of abandoned or uncontrolled
hazardous waste sites that EPA deems are potentially
harmful to public health and the .environment.
How the EPA Approaches Cleanup Options
The EPA considers a number of technical approaches when
evaluating the best way to address risks posed by a
Superfund tite. The process narrows these approaches to
only those that would protect human health and die
environment and comply with all laws/regulations. The
resulting approaches can be grouped into four fairly simple
categories:
No action: Do nothing except:
idwaterand
conduct periodic reviews of site conditi
manic
Contain it: Leave the
cover or contain it m son
spread of > This ranthod reduces risks, but
does not destroy or reduce the contamination.
way to pro
where it is and
; toor
Handle it off Site: Remove the contaminated material
and dispose and/or treat it elsewhere.
Handle it on Site: Use a treatment process arthe site
to destroy or remove the contaminants. The treated
material can often be left on site.
The Raymark Facility Feasibility Study evaluated several
different options for addressing the sources of
i at the facility. To compare the options, the
Feasibility Study also evaluated hew well the nine cleanup
criteria described on page 6 would be met. The options
are refeiied to as 'cleanup alternatives,* aad ate generally
different combinations of processes to contain or handle the
tin» ** M^M^AM* ^M*^J«4« k^^lftik mmtt tfhA ^MWMWMM^M*
T*tM<*' to protect prone neaun ana me ?ni>ii'Tiin*ni
During the upcommg ""inn"** period, the EPA welcomes
your comments on me mmmmmdnd cleanup plan as well
as the other technical approaches briefly described below.
Please consult die Feasibility Study for detailed information
about all the options evaluated for site cleanup. A copy of
the Remedial Investigation, which describes the types and
extent of contamination, and the Feasibility Study are
available for review at the Stratford Public Library
Reference Deck, 2203 Main Street, or at the EPA. 90
Canal Street, Boston, Massachusetts.
4 EPA Superfund Program Proposed Plan
-------
Cleanup Options for Your Consideration
The following section outlines the basic components of
each cleanup alternative analyzed in the Feasibility Study
for the Raymark Facility. See the Feasibility Study for a
more comprehensive description.
No Action Option:
* Alternative 1: &
-------
How Does EPA Choose a Cleanup Plan?
The EPA uses the nine criteria described below to evaluate
the pros and cons of til cleanup alternatives. The final
cleanup plan must meet the fint two criteria (protecting
public health and the environment and complying with
environmental laws and regulations), and must achieve the
best balance among the next five criteria. Because fedeal
regulations require the EPA to select a cleanup plan that
best meets these nine criteria, your comments will be most
effective if you focus them on the kinds of issues and
questions raised by these criteria.
1. Overall protection of human health and the
environment: Win it protect you and the ecological
systems supporting plant sod animal life on and near
the site?
2. Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs): Is it legal? Does
the alternative meet all federal and state environmental
statutes, regulations, and requirements or would a
waiver be necessary to legally proceed?
3. Long-term effectiveness and permanence: Will the
effects of the cleanup plan last or could contamination
present a risk ng*^n over tone?
4.
through treatment: Does the alternative reduce the
spread, and the amount of
-------
COMPARISON OF CLEAN-UP ALTERNATIVES
NINE
CR/7BVA
PROTECTS HUMAN
HEALTH A/*> THE
ENVIRONMENT (|j
MEETS STATE AND
"^ (2)
PROVIDES LONO
TERM PROTECTION
(3)
opinircg MOCILTTY.
Toxicmr. OR
VOLUME THROUGH
TREATMENT ^j
SHORT-TERM
(5)
IMPLCMENTAiLE
(CAN IT BE
DONE?} (ft)
COST
(OVER 90 YEARS)
(7)
STATE A6ENCY
ACCEPTANCE
(8)
COMMLNTTY
ACCEPTANCE
<9)
PROPERTY
RE-USE POTENTIAL
TIME TO REACH
CLEAN-UP GOAL
ALTERNATIVE I
NO ACTION
o
$ 6 MILLION
STATtACOfTAHCea
. CBtWn AOfTAH
NA
ALTERNATIVE £
:::::::£Aft?wG::::::
U ):J
u< u
H H
H H
::-*:-fco-:MRi:ioN-:
rgMy/mju>m^.ns
ar OF w* s H9fs
-------
...More on the Open Houses and
Next Steps
The EPA encourages you to participate in deciding how the
Raymark Facility will be cleaned up. Ask all the questions
you wish at one of the open houses. The dates and times
are listed on the front page of this document. The format
will allow you to review the proposal discussed in this
document. Technical experts will be available, one-on-one,
to answer any questions you have about what you are
reviewing. Put way through each open house, EPA staff
will give short presentations of findings about the Rtymark
Facility contamination, explain the proftflT that lead the
EPA to choose its proposed cleanup plan, and discuss the
other cleanup options that were studied. The open houses
are your opportunity to ask questions and become familiar
with the cleanup proposal.
You may also provide EPA with your thoughts about what
you hear by using the attached sheet. All you need to do is
'drop it off at one of the two open houses or mail it in to .
us, postmarked by May 8, 1995. You can also attend a
formal public hearing, scheduled for 7:00 pm on Thursday,
May 4, in Council Chambers at Town Hall to deliver your
comments orally. This session will be recorded by a
stenographer and a transcript win be available at the
Library's Reference Desk when EPA's final cleanup
decision is announced. Remember that the effect* of the
facility on groundwater contamination in the am will
require more study, so potential groundwater cleanup
options win be subject to subsequent EPA action, if
necessary.
The EPA will evaluate and answer all public i
received in writing or at the hearing. While we i
respond personally to your letters, all comments will be
consolidated and the EPA will write responses to each
question or comment received. The entire set of comments
and responses (the Responsiveness Summary) will be
evaluated to assist the EPA in selecting the final cleanup
plan to control the source of contamination at the Raymark
Facility. What you tell us can impact our decision. The
responsiveness summary is part of the official EPA
decision document, the Record of Decision, that will be
available for public review at the Stratford Public Library
reference desk. When the Record of Decision is signed, a
notice will be sent to the local media and our community
This is anticipated to occur in June 1995.
If the proposed plan is finalized, the EPA anticipates that
df.vmt.mmrtinB «nd demolition of buUdinfS at the facility
will begin in the summer/fall of 1995, and that residential
cleanups will be completed during the tall of 1995.
For further information, call the EPA Community
Involvement Coordinator Liza Judge at (617) 565-3419
or the Boston link at (203) 380-6034 and leave a
message with your name, telephone niirnhftr, and
question. An EPA staff person will return your call as
soon as possible.
8 EPA Superfund Program Proposed Plan
-------
Use This Space to Write Your Comments
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raymark Facility
is very important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8,1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by close of business, 5:00 pm, on May 8, 1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to avoid a long distance toll charge, use the "Boston link" by calling (203)
380-6034, leave a message, and your call will be returned. PLEASE WRITE LEGIBLY.
Name
Address
Town
State ZipCode_
-------
RAYMARK FACILITY SUPERFUND SITE
PUBLIC COMMENT SHEET
Fold on Dashed Lines, Staple, Stamp, and Mail
'Name .
Address
Town State_
Zip Code
Michael Hill (HSL-CAN5)
Remedial Project Manager
US EPA
JFK Federal Building
Boston, MA 02203-1911
-------
Mailing List Additions
If you orsomeone you knowwould like to be placed on the Raymark Facility
site mailing list, please fin out and mail this form to: '
Liza Judge (REA)
:-.:, . ; Community Relations Coordinator
: : :' U.S. Environmental Protection Agency
John F» Kennedy Federal Building
Boston, Massachusetts 02203
: (617)565-3419
Name: ;...... .:.
Address:
Affifiation (if any):
Phone:
ADD
DELETE
CHANGE
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION I - REA
JOHN F. KENNEDY FEDERAL BUILDING
BOSTON, MASSACHUSETTS 02203-1911
Forwarding and Address Correction Requested
Raymark Industries, Inc. Superfund Site
Official Business
Penalty for Private Use
$300
Fnt OMW Mai
Postage and Fees Paid
EPA Permit No. G-35
-------
AGENDA
12:30-1:30 PRESENTATION
SATURDAY, APRIL 8, 1995
U.S. ENVIRONMENTAL PROTECTION AGENCY
PROPOSED CLEANUP PLAN TO ADDRESS
THE RAYMARK FACILITY, E.MAIN STREET, STRATFORD
WENDY HYMAN, CONNECTICUT LEAGUE OF WOMEN VOTERS
- Open Meeting
- Introduce Presenters
- Review Agenda
LIZA JUDGE, EPA COMMUNITY INVOLVEMENT COORDINATOR
- How Can you Comment? * Questions Today
* Official Comments
MICHAEL HILL, EPA REMEDIAL PROJECT MANAGER
- Manufacturing & Cleanup History w/Slides
- Type & Extent of Contamination in Soil & Groundwater
MARGARET MCDONOUGH, EPA HEALTH RISK ASSESSOR
- Which contaminants are we concerned about?
- What are the risks to public health?
MICHAEL JASINSKI, EPA REMEDIAL PROJECT MANAGER
- Why is cleanup needed?
- Cleanup options considered
- Why EPA selected this Proposed Cleanup Plan
LIZA JUDGE, EPA COMMUNITY INVOLVEMENT COORDINATOR
- How to make your comments effective
- How to submit formal comments
- Date of formal Hearing
WENDY HYMAN, CONNECTICUT LEAGUE OF WOMEN VOTERS
- Question & Answer Session
-------
ATTACHMENT D
COMPLETE TEXT OF COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD
-------
LOG OF PUBLIC HEARING COMMENTS Page 1
RAYMARK INDUSTRIES, INC., STRATFORD, CT j
i
COMMENTER
i
| Henry J. Themal
1 55 Short Beach Road, Apt 305
Stratford, CT 06497
I Frank A. Del Vecchio, Jr.
65 Riverside Drive
Trumbull,CT 06611
! Betty Pagliaro
i DID NOT GIVE AN ADDRESS
j Henry J. Themel '
155 Short Beach Road, Apt. 305
Stratford, CT 06497
iJphnt. Harrigan
66 Burbank Drive
Stratford, CT 06497
John B. Wilson
90 Bittersweet Lane
Stratford, CT 06497
Joseph Zakhar
1 20 Cutsping Circle
Stratford, CT 06497
Jason Santi
29 Longbrook Avenue
Stratford, CT 06497
Robert H. Sammis, Chairman
Waterfront & Harbor Management
Commission
2725 Main Street
Stratford. CT 06497
Barbara Heimlich
91 College Street
Stratford,. CT 06497
No Name Given
No Return Address Given^.
Michael Brown Osbonw
The Dock, Inc.
955 Ferry Boulevard
P.O. Box 368
Stratford, CT 06497 i
DATE OF
COMMENTS
Apr. 4, 1995
Apr. 10, 1995
Apr. 9, 1995
No Date
Apr. 10, 1995
Apr. 11,1995
Apr. 10, 1995
Apr. 11,1995
Apr. 13, 1995
Apr. 17, 1995
No Date
I
DATE RCV'D
BY EPA
Apr. 6, 1995
DATE NUS RCV'D !
FROM EPA i|
Apr. 7, 1995 |
j
VIA FAX !
Apr. 12, 1995 Apr. 12, 1995
i VIA FAX
Apr. 12, 1995
Apr. 12, 1995
Apr. 12, 1995
Apr. 13, 1995
Apr. 13, 1995
Apr. 17, 1995
FROM NUS
Apr. 18. 1995
Apr. 17, 1995
VIA FAX
Apr. 12, 1995
VIA FAX
Apr. 12, 1995
VIA FAX
Apr. 13. 1995
VIA FAX
Apr. 13, 1995
VIA FAX
Apr. 13, 1995
VIA FAX
Apr. 11,1995
AT OPEN HOUSE
Apr. 18, 1995
VIA FAX
Apr. 19, 1995
VIA FAX
Apr. 20, 1995 Apr. 20, 1995
i
[ VI A FAX
Apr. 19, 1995 jApr. 20, 1995 Apr. 20, 1995
'VIA FEDEX , VI A FAX
Mark & Michele Sparano i Apr. 1 8, 1 995 Apr. 26, 1 995 i Apr. 26, 1 995
116 Willow Avenue . . i
Stratford, CT 06497 ' VIA FAX
John R, Morton Apr. 21 , 1 995 May 2, 1 995 , May 5, 1 995
4005 Main Street
Bridgeport, CT 06606 I VIA FAX
-------
LOG OF PUBLIC HEARING COMMENTS tage 2
RAYMARK INDUSTRIES, INC., STRATFORD, CT
. COMMENTS*
Henry J. Themal
155 Short Beach Road, Apt 305
Stratford, CT 06497
Carl Weigand
1 22 Shantey Street
Stratford, CT 06497
LeGrande L Young
Raytech Corporation
., Suite 512, One Corporate Drive
Shelton.CT 06484
i Robert H. Sammis, Chairman
.Waterfront & Harbor Management
' Commission
1 2725 Main Street
i Stratford, CT 06497
iJohnW.Caldwell
i Dresser Industries
1250 East Main Street
i Stratford, CT 06497-0536
James A Thompson, Jr., Attorney
: LeBoeuf, Lamb, Greene & McRae
Goodwin Square
225 Asylum Street
Hartford, CT 06103
> J. Roger Shull
1 335 Ml Pleasant Avenue
:i Stratford, CT 06497
,
-------
LOG OF PUBLIC HEARING COMMENTS
RAYMARK INDUSTRIES, INC., STRATFORD, CT
Page 3
;, COMMENTER
David & Deborah Tvardzik
2981 Broadbridge Avenue
, Stratford, CT 06497
;j. Robert Osbome
.: The Dock, Inc.
955 Ferry Boulevard
:: P.O. Box 368
Stratford, CT 06497
1 Angela Notarino
71 Roosevelt Avenue
: Stratford, CT 06497
Denise H. Nalezynski
': 145 Phillips Street
Stratford, CT 06497
Chris Lacas/Ron Curran
CT Department of Env. Protection
i 79 Elm Street
Hartford, CT 061 06-51 27
DATE OF
COMMENTS
JuneS, 1995
June 7, 1995
June 6, 1995
June 6, 1995
June8, 1995
DATE RCVD
BY EPA
June 7, 1995
JuneS, 1995
VIA UPS
JuneS, 1995
JuneS, 1995
JuneS, 1995
VIA FAX
l DATE NUS RCVD i
I FROM EPA
I June 8, 1995
i '
VIA FAX
June 8, 1 995
VIA FAX
June 12, 1995
VIA FAX
June 12, 1995
VIA FAX
June 9, 1995
VIA FAX
Randall J. Foster
Brake Systems, Inc.
100 Double Beach Road
Branford, CT 06405
June 8, 1995
i June 8, 1995
VIA FAX & FEDEX
| June 9, 1995
I
I VIA FAX
Steven L Law
; 267 Soundview Avenue
: Stratford, CT 06497
Janet Carlucci
Stratford Citizens Advisory Council
2730 Main Street
Stratford, CT 06497
Mark S. Bamhart
Town of Stratford
2725 Main Street
Stratford, CT 06497
June 6, 1995
June 7, 1995
JuneS, 1995
June 9, 1995
June 9, 1995
June 12, 1995
VIA CERTIFIED MAIL
! June 12, 1995
j VIA FAX
; June 12, 1995
; VIA FAX
; June 12 1995
VIA FAX
Nancy Casazza
114 High Park Avenue
Stratford, CT 06497
! June 7,1995
Elizabeth McNamara
20 Helen Place
Stratford, CT 06497
June 7, 1995
June 12,1995
June 12, 1995
June 13,1995
VIA FAX
June 13,1995
VIA FAX
J. Robert Osbome
The Dock, Inc.
955 Ferry Boulevard
P.O. Box 368
Stratford. CT 06497
JuneS, 1995
June 14,1995
-------
^^U ^f- |~WWMW I l*"*^ ««»w^ ^^'"'
RAYMARK INDUSTRIES, INC., STRATFORD, CT
Pag* 4
Waterfront & Harbor Management
Commission
2725 Main Street
Stratford, CT 06497
-------
Henry J. Themal, B.S. (203) 375 7287
155 Short Beach Road,apt.305
Stratford, CT»- 06497-7681 April 4, 1995
Mr. Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, MASS. 02203
Dear Mr. Hill:
As a resident of Stratford, CT., I have received the one-page
EPA ENVIRONMENTAL NEWS LETTER, regarding the "PROPOSED CLEANUP
PLAN FOR THE RAYMARK FACILITY" in Stratford. Although I am
aware that you must be fully up-to-date with all the implica-
tions of this matter, I am taking the liberty of adding the
following comments, based upon my own experience in the matter
of environmental protection.
That experience includes my ten years as a Buildings Manager for
the U.S. General Services Administration at the Jacob Javits
Federal Building, 26 Federal Plaza, New York City, until my so-.
called "retirement" in 1984, - although I have been busier than
ever since then. For five years, I was also a Hospital House-
keeping Officer at the 1200-bed Naval Hospital of St.Albans,NY;
and I have also worked as a Quality Control Inspector and Teacher
of Professional Training Classes for service employees of the
City of New York and with a private Cleaning Company in New York
and New Jersey.
My main reason for mentioning all this, Sir, is the tendency by
contractors', such as will be required for the cleanup job at the
Raymark Facility, to.employ numbers of employees, whose experienc
and whose numbersof-hours-worked, will be difficult to control,
whose reas; nable time-limit for completion of the job will be
difficult to assess. In addition, since I often have occasion to
observe the Raymark location from the outside, I have noticed thai
almost all the buildings and grounds are in a terrible state of
neglect and probably beyond repair. Of course, since I am not a
scientist, I can not tell how much of the pyior pollution of air,
grounds or buildings may still present an environmental danger.
To conclude, Sir, - should you feel that my background, and my
residential proximity to the facility, as well as my professional
contacts might be helpful in the solution of the various Raymark
efficiency and cost problems /I might be helpful in the implementat
of the program, please do not hesitate to contact me. Meanwhile,
I thank you for ijour interest,
Sincerely,
Henry J.
Encl.
-------
Henry J. Themal (203) 375 7237
P.O. Box 1042.
155 Short Beach Road
Stratford, CT. 06497-8542 January 1995
RESUME
Education: Bachelor of Science Degree, Business & Economics
State of New York University 1982
Ecole Professionnelle de la Societe' Suisse des
Hoteliers, Lausanne, Switzerland 1938/39
Management Courses & Seminars,600 Hrs. 1970/80
Experience:Buildings Manager
U.S.General Services Administration
Region 2, New York City 10 years 1973/84
Hospital Housekeeping Officer
U.S.Naval Hospital, St. Albans, N.Y.
1200 Beds 5 years 1968/73
Director of Buildings & Grounds
N.Y. University Medical Center 5 years 1963/68
Buildings Manager and Director of Blood Distribution
The American Red Cross in Greater New York
9 years 1953/63
Maltre d'Htftel and Front Office Manager
Hotels in New York City, Atlantic City,
Lisbon, Portugal; Duesseldorf, Germany;
Geneva, Italy; Trieste, Italy. between 1935/53
High-School Substitute Teacher in New York City;
Montevideo, Uruguay; Hamden, CT; Stratford, CT.
Languages; English, German, French, Spanish, Italian, Portuguese.
Insfcruetdtrrlftglish-for-foreign-born;
CAREER DEVELOPMENT TRAINING for young people.
Technical & motivational Training Courses for
service personnel. Quality Control Inspections:".
"Distance Learning"-College Instructor.
Other Services: Hand -written CALLIGRAPHY for all occasions.
"Made-to-order" personalized POETRY .
Translations, Diplomas, Invitations, etc.
Available; Part-time, mornings pref'd.,work-at-home; -
subject, to interview. Driver's License.
Documentation upon request.
-------
Use This Space to Write Your Comments
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raymark Facility
is very important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8, 1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by dose of business, 5:00 pm, on May 8,1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to avoid a long distance toll charge, use the "Boston link" by calling (203)
380-6034, leave a message, and your call will be returned. PLEASE WRITE LEGIBLY.
Please have the fogsite to install public water and sewer
lines under the cap at strategic locations so that when
the EPA is through, the property may be more easily
, developed without the endless delay of permits,
inspections, etc, for the future contractors.
We need this location to produce lobs and additional
tax base for the town and its people.
Born and raised in Stratford. Real estate broker intown
since 1971.
Name Frank A. Del Vecchio Jr.
Address65 Riverside Drive
Town Trumbu11
State CT Zip Code 06611
-------
/
-------
Use This Space to V»'rite Your Comments
0
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raymark Facility
is very important. Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8, 1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by dose of business, 5:00 pm, on May 8, 1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to avoid a long distance toll charge, use the "Boston link" by calling (203)
380-6034, leave a message, and your call will be returned. PLEASE WRITE LEGIBLY.
Dear Mr. Hill:
As I already indicated in a previous letter to Ms. Liza Judge, rr\y
-- - -- - - . - -r
interest in the Raymark Facility stems from ^4- factors : 1 . As a
former Buildings Manager (GS12) for the United Sates General Ser-
vices Administration, Region 2, New York City, I have repeatedly
come in contact with similar private and/or Government facilities
exposed to pollution. And 2. As a resident of Stratford, CT., it
pains me to see such a large site, with large industrial potential
in such a disrepair and obvious neglect. I would be proud to be
able to assist in its cleanup. 3. Eased upon my former experience
I am taking the lilfcrty of enclosing a brochure of a cleaning con-
tractor, whom I consider more honest and more qualified than some
others. 4. I consider the "Five Years", allegedly needed to com-
plete the cleanup, exagerated and unrealistic. Therefore I recom-
mend; 1 . Any company; or individual, who anticipates a long-term _ _
and high-income contract involving this "cleanup", will obviously
exagerate its urgency ! 2. If Raymark Industries still exist, they
should be best qualified to indicate where and how and to what ex-
tend the pollution took Name _ Henry J. Themal, B<; _
place, and how it can be
removed. They_ should pay Address 155 shnr-t- Rg.P.nh Pnar) _
for mos.t of the cost !
Town Stratford, CT. 06497
(Next page, please : ) -
State CT- Zip Code 06497
-------
RAYMARK FACILITY SUPERFUND SITE
PUBLIC COMMENT SHEET
(Continued from page 1):
2. Rather than financing the c eanup through E.P.A. alone, all
interested future occupants (housing developers, industrialists,
commercial entrepreneurs) should be expected to contribute
toward the costs of the cleanup. This would also help in a
speedup fo the expected work, ther than an "indefinite com-
pletion time" of a "Government Contract".
Kindly forgive my bluntness, Sir; but it is based solely on
previous experience, although I am no longer in a positiono
document it.
Fold on Dashed Lines, Staple, Stamp, and Mail
Name //.
Address MT
Town
OldGlorv
Zip Code
Michael Hill (HSL-CANS)
Remedial Project Manager
US EPA
JFK Federal Building
Boston, MA 02203-1911
REpEIVED
-S '
-------
HENRY J. THEMAL (203) 375 7287
P.O. Box 1042
Stratford, Connecticut 06497-8542
RESUME
Education; Bachelor of Science Degree; Business & Economics
State University of New York 1982
Graduate, Professional School for Hotel ManagorucnJ:
Lausanne, Switzerland 193h/3<> '
EmploymentrBuildings Manager(GS-11/12) United States GenornJ
Services Administration,Region 2, New York City:
Supervision of Maintenance- & Cleaning Services in the GSA
Services Area. Supervision of contract compliance of servi.ro
contractors. In-house training conducted. In-house Newsletter
edited. Tenant & Public Relations. 1973/84
Hospital Housekeeping Officer. U.S.Naval Hospital,
St. Albans, New York (1200 beds) Environmental Sanitation Pro-
gram for hospital designed and supervised. Training conducive!
for Naval A civilian personnel. Lecturer at the Surqr.on-
General's Conference in Bethesda,Md. in 1971. l9f">M/v:j
Director of Buildings & Grounds; New York Univer-
sity Medical Center, New York City. Supervision of environ-
mental maintenance of hospital and adjacent grounds & parking
areas. 1963/GR
Director of Blood Distribution and Buildings
Manager; THE AMERICAN RED CROSS IN GREATER NEW YORK.
Supervision of storage & distribution of daily bloodcqjlecl.i onr-.
Organization & supervision of ARC Headquarters'move from midtovn
to Lincoln Center area. 19r>Vr>3
Languages; Experience as teacher of English-f or-f ore icjn i">rn;
Fluent German, French, Spanish; some Italian & Portuguos"..
Other Activities: Registered Substitute Teacher (High School.r, )
Hand-written CALLIGRAPHY for all occasions (Gothic S. Script. ).
Personalized Poetry written upon request.
CAREER DAYS conducted for young people.
An INTERNATIONAL NETWORK OF PENPALS, encouraging children and
teenagers from all over the world to correspopd with eachoUier.
Documentation and References upon request.
-------
3909 DYRE AVENUE Tel. (718) 994-1150
BRONX, NEW YORK 10466 Fax (718) 994-1731
SPECIALISTS IN INDUSTRIAL AND COMMERCIAL INTERIOR AND EXIERIOR CLEANING
April 5, 1995
Mr. Henry Thema1
155 Short Beach Road
Stratford, Conn. 06497
Dear Mr. Themal:
I am pleased to introduce Urban Cleaning Contractors, Inc.,
one of the most reputable cleaning contractors in the New
York/New Jersey Metropolitan area.
As you might expect, there is more to cleaning than meets
the eye. Our wide range of services, coupled with our
expertise allows us to provide you with a flexible
custodial program geared to enhance your surroundings
and tailored to meet your needs and budget.
Since it is possible that our services might be of interest
to you, I am enclosing a brochure with a partial listing
of references of our Clientele and services we offer.
There is no doubt in my mind, if given the opportunity,
my firm can be of invaluable assistance in maintaining your
properties.
Needless to say, I'm looking forward to your reply and the
opportunity to be of service to you and your organization.
Thanking you for your time and consideration.
Sincerely,
'/?-j* Li
Mike A. Moreno
President
ENCL.
-------
John T. Harrigan
66 Burbank Drive
Stratford, CT 06497
Michael Hill (HSL-CANS)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, MA 02203
Dear Mr. Hili,
I am writing this letter in reference to the cleanup of the Raymark Facility in Stratford,
Connecticut.
Because of the close proximity of the "Waste" to Long Island Sound, and The New York
Metropolitan Area, the "Waste" should be packaged into containers and sent to the
Nevada Desert, where it is away from any population centers or a large mass of water.
This would minimize the exposure to people, and the food chain which starts in Long
Island Sound.
You should make Raymark purchase the Land in the Nevada Desert where the "Waste"
would be placed in, and have them pay the property tax on the land.
hn T. Harrigan
-------
Use This Space to Write Your Comments
Your input on the EPA's recommended deamip plan to control the source of contamination at the Raymark Facility
is rery important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space bdow to write your
about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8,1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by dose of business, 5:00 put, on May 8,1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to avoid a Ions distance toll charge, use the "Boston link" by calling (203)
380-6034, leare a message, and your call wffl be returned. PLEASE WRITE LEGIBLY.
-------
Use This Space to Write Your Comments
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raymark Facility
is very important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8, 1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by close of business, 5:00 pm, on May 8,1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to avoid a long distance toll charge, use the "Boston link" by calling (203)
380-6034, leave a message, and your call will be returned. PLEASE WRITE LEGIBLY.
With reference to the contamination problem I feel thatAlternative 5
(On^Site Options) is best. Mainly because no other area should
be burdened with our problems. HOWEVER, RAYMARK SHOULD BEAR
.THE BURDEN OF EXPENSE. NO ONS ELSE.
. , . j_:
.During the recent wind and rain storm we were unfortunate.
enough to be in the area of the property where the contaminated
soil is now stored. It was blowing all over the place and I
am sure both my wife and I inhaled a great^of it.
It will be a relief when this particular problem is finally
taken care of.
4-
Name
Joseph
Address 120 Cutspring Circle
Town Stratford
State Conn Zip Code 06497
-------
Use This Space to Write Your Comments
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raynurk Facility
is very important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8, 1995. You may also telefax your comments to Mr. Hill
at (17-573-9662 by dose of busmeac, 5:00 pm, on May 8, 1995. If you have questions about the comment period,
contact Liza Judge at 617-565*3419 or, to avoid a long distance toll charge, use the "Boston fink" by calling (203)
3804034, leave a message, and your call wifl be returned. PLEASE WRITE LEGIBLY.
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TOWN OF STRATFORD
CONNECTICUT
06497
WATERFRONT AND
HARBOR MANAGEMENT COMMISSION
2725 MAIN STREET
STRATFORD. CT O6497
Mr. Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, Ma. 02203
Re: Raybestos Remediation April 13,1995
Dear Mr. Hill;
Thank you for the opportunity to review the actions that have been undertaken and
those anticipated for the Raybestos principal site. The information available on the 8th
was extremely helpful. Of particular concern is the disposition of the downstream area
known as Ferry Creek.
This body of water and the sediments are alluded to be contaminated with various
. elements from the Raybestos site as this is the primary surface and subsurface
drainage path. With that in mind, we are interested to know what the remediation
plans are in this regard. Again, it is our understanding that from the site to the junction
with the Housatonic River there are sediments that should be addressed. As this body
of water is tidal from the river to Broad Street, and was tidal to Ferry Boulevard prior to
the installation of tide gates (circa 1985+/-), we understand that this is considered to be
the property of the State of Connecticut below the mean high water mark.
If you would address these issues we would be most appreciative as the disposition of
Ferry Creek has a significant impact of the long range plans of development of
Stratford's waterfront.
Serjly,
Robert H. Sammis, Chairman
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Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, MA 02203
April 19, 1995
RE: Request for Extension of Public Comment Period
Dear Mr. Hill,
The Dock Incorporated of Stratford
Connecticut formally requests that the Public Comment Period be
extended for the Proposed Cleanup Plan for Raymark Industries in
Stratford, Connecticut.
Our property is very close to the Raymark
Site and we need more time to study the proposed cleanup plan
materials in the Stratford Library in order to objectively assess the
proposed plan.
Sincerely yours,
Michael Brown Osborne
President
cc. Liza Judge
The Dock Inc. 955 Ferry Boulevard P.O. Pox 368 Stratford, CT 06497 (203)377-2353
-------
Mark & Michele Sparano
116 Willow Avenue
Stratford, CT 06497-6038
(203) 381-9879
April 18,1995
Michael Hill (HSL-CAN5)
Remedial Project Manager
US EPA
JFK Federal Building
Boston, MA 02203-1911
Dear Mr. Hill,
This letter will serve as our comments related to the proposed cleanup plan for Raymark Industries, Inc.,
Stratford, Connecticut. Our comments are based on information, both oral and written, obtained in the
well organized and delivered Aphl 8,1995 Informational Open House conducted the EPA in the Stratford
Public Library. Our comments relate to the five alternatives proposed by the EPA.
Alternative 1
* Not a viable option in our opinion since it is not cleanup or remediation.
.* Don't understand how testing ground and surface water and visiting the site every 5 years can cost 15%
of the total cost of Alternative 2 which includes demolition, cap building and cap maintenance. These
present value costs do not seem reasonable to us.
Alternative 2
* This option addresses all the major concerns except groundwater. How can we make an intelligent
overall decision of not all facts/costs are known? No matter what, we believe groundwater testing is
crucial and should be performed more frequently than every 5 years.
* When one considers that interference to the cap is a major concern, commercial/retail use of the
property appears to be the highest and best use. In addition, the area around Barnum Avenue Cut-off and
East Main Street is highly commercialized already and therefore, retail use of the property would be
minimal disruption to the surrounding area. The proposal by the Leach Family Holdings is well received
by us because it involves landscaping for beautification of the area and blacktop paving which further
prevents puncturing the cap. Retail use also preempts recreational usage which may puncture the cap
(digging, erosion, etc.).
Alternatives 3 to 5
* Excavation and treatment are not favored by us because the less you move the contaminants, the lower
the health rides. Also, dumping sites for the highly contaminated soil were not explored. We doubt that
other municipalities would embrace our problem without exorbitant charges.
* Costs do not match benefits. Off-site treatment is much too pricey. :
4/18/95 8:17 AM
-------
Mark & Michele Sparano
116 Willow Avenue
Stratford, CT 06497-6038
(203) 381-9879
Of all the proposals on the table, we support Alternative 2 the most due to relative costs, short-term
remediation and reuse of the property. We've concluded that each consecutive alternative gets better and
better in terms of long-term safety and health. The support for whatever alternative really comes down to
money - the benefits derived from the costs incurred, since safety and health issues are addressed in most
options. We must stay realistic with our spending, but we wonder if Superfund moneys are available for
Alternative 3 to 5. Also, funds should be exacted from Ravpngrk for tKis T*fffliWPi Improper corporate
ethics, supervision and decisions need to be severely punished! The euiltv should pav as much as
possible!
All the proposed alternatives do not rid us of the entire problem, they only address concerns noted to date.
Not to sound like alarmists, but we can't help but wonder what the future holds for the site - earthquake
disruptions, flooding, etc. At least we are attempting to correct the known problems. Action is much
better than inaction. It seems that one man's carelessness takes the work of an army of men from five
plus agencies to correct.
We'd like to take this opportunity to thank the various community, town, state and federal agencies
working on this project. To date, we have found all agencies and their representatives to be helpful,
concerned and informative. This teamwork approach needs to continue to produce the proper cleanup for
the generations of today and tomorrow.
Sincerely,
Mark Sparano Michele Sparano
Stratford, Connecticut residents since 1987
Stratford, Connecticut homeowners since 1989
4/18/95 8:17 AM
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Use This Space to Write Your Comments
Your input on the EPA's recommended cleanup plan to control the source of contamination at the Raymark Facility
is very important Public comments assist the EPA in selecting its final cleanup plan.
You may use the space below to write your comments about the EPA's recommended plan. Comments should be
directed to Michael Hill and must be postmarked by May 8,1995. You may also telefax your comments to Mr. Hill
at 617-573-9662 by dose of business, 5:00 pm, on May 8,1995. If you have questions about the comment period,
contact Liza Judge at 617-565-3419 or, to ayoid a long distance toll charge, use the "Boston link" by calling (203)
380-6034, leaye a message, and your call will be returned. PLEASE WRITE LEGIBLY.
Name
Address Mark * Mlchel« Sparano
«»""=» __ m Wlllow AVBnue
Stratford, CT 06497-6038
Town
State ZipCode_
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153 short rieacb doad, apt. 305
Stratford, CT. 06497 May 2, 1995
Mr. Michael Hill (IISL-CAN?)
Remedial Project Manager
U.S.Environmental Protection Agency
JFK Federal Building
Boston, Mass. 02203
Dear Mr. Hill:
This letter comes to you in response to your ENVIRONMENTAL NEWS
issue #95-4-10, regarding tbe cleanup plans for the facilities
of the RAYMARK INDUSTRIES here in Stratford, as well as the area
for Short Beach Park, across the street from my own residence.
Your letter is asking for commentary from the public, and since,
as a former Buildings Manager with the U.S. General Services Ad-
ministration in New York City, I have some experience related to
such efforts, - as a manager, - NOT as a scientist, I am talking
the liberty of making you aware of a few point*.
As a resident of Stratford, I have occasion to pass the Baymark
facilities almost daily; - I know the approximate sice of the
area, as well as the deplorable and neglected condition* of the
buildings and ground*. Perhaps there are some reasonable explana-
tions for this, and probably yon are already aware of some possible
solutions. However, since you are asking for comment*, Sir, here
are some actions which I consider particularly important :
1. Establish priorities in the cleanup process, i.e. removal
of contaminated waste; destruction and/or rebuilding of existing
structure*; designation for future uses.
2. Establish work standards, employee qualifications and numbers,
time guidelines and time limits for work completion.
3. Carefully compare contract proposals by private contractors
with a) Government established standards and b) similar proposals
by competitor-contractors.
4. Follev up tbe eventual award of cleanup- and construction
contract* with frequent Quality Control Inspections, Progress
Control Inspections, technical and motivational Employee Training
Program* for both Government and/or Contract personnel; continuing
publication of periodic newsletters to report progress and good
accomplishments to officials, employees, and to the local community.
During my previous professional experience, Sir, I have found that
such steps may be fruitful in reaching the goals of this program.
If you feel that I.night te qf further help, please contact me.
Sincerely yours,
Encl.Iesume
-------
Henry J. Thsmal . C^'jt 3i> 7-^7
P.O. Box 1042
Strntford,Connecticut 06497-8542 Summer 1995
B t S U M E - CURRICULUM VITAE
Interested in part-time occupation based upon the following
Professional Background;
Bl'ILDINGS .MANAGER. U.S.General Services Administration, Kegion 2,
New York, N.Y. Building maintenance, environmental con-
trol and contract-supervision. In-house training classes
conducted." 1974-19^4
HOSPITAL HOUSEKEEPING OFFICEB. U.S. Naval Hospital,St.Albans,NY,
Similar responsibilities as above. 1969-74
BUILDINGS MANAGER A DIRECTOR OF BLOOD DISTRIBUTION.
The American Red Cross in Greater New York.
Distribution of ARC Blood Supplies in NY City.
Move to new ARC Headquarters Building. 1959-^9
Front Office Manager & Maitre d'Hotel in various Hotels in'New York,
Atlantic City.NJ; Lisbon, Portugal; Genoa and 'Trieste,
Italy. 1935-1959
Mucation;
Bachelor of Science, (Business & Economics), SUNY -
State University of New York, NY City 1983/4
Professional School for Hotel Management, Lausanne,
Switzerland (Diploma) 1938
Specialty Courses in Business Management Subjects in
New York City (appr.900 hours) 1975-80
German, French, Spanish, Italian & Portuguese languages.
English-for-foreign born (Tutoring).
Current Activities;
Substitute Teacher, High School Level, Connecticut & NYC.
Hand-written CALLIGRAPHY for all occasions. Family Trees,etc
Made-to-order- POETRY - for all occasions.
Photomontages , - Collages, - Translations, -Newsletters.
Available for work-at-home or temporary assignments. Recommendations
and documentation upon request. Driver's License. Married, two
daughters (married); two stepdaughters. U.S. Citizen.
-------
122 Shanley St.
Stratford, CT 06497
203-375-5392
Michael Hill
Project Coordinator
US EPA
JFK Federal Building
Boston, MA 02003-1911
Dear Mr. Hill
I am writing this letter in response to the presentation at the
Stratford Library on the proposed cleanup plan for Raymark Industries
Inc. I've been a resident in the community for my entire life (28
years) and I am a student at Sacred Heart University where I am pursuing
a Master's Degree in Environmental Chemistry. At present, I am taking a
course in hazardous waste management.
In writing this response I have also read some of the extensive material
included in the 21 volumes published by the EPA on all available data
of course I concentrated on the last two because of the sheer volume of
material. In reviewing the data I've focused on the criteria
established on p. 6 of the April 1995 New England EPA newsletter.
I concur that Alternatives 2 and 3 appear to be the best choices.
Although Alternatives 4 and 5 provide long term protection they do so at
the risk of exposing workers and residents in the area during the period
of excavation required to remove and treat the contaminated soil.
Although the technology exist to remove organics (by thermal desorption
or incineration) and inorganics (by encapsulation) I doubt the taxpayer
is willing to spend $1 billion on complete removal. Additionally, it
would be difficult, if not impossible to guarantee 100% containment of
400,000 yd3 of soil which would have to be excavated and treated during
the project. A spill would create pandemonium because I've found that
the general population is especially sensitive with chemicals,
especially hazardous ones.
In contrast, alternatives 2 and 3 would still provide long term
protection by removing the most contaminated sites (such as the former
1,1,1-TCA spill area) while minimizing short term risks to local
residents. Any remaining leachable compdunds couiu be addressed when
EPA proposes its water remediation plan.
Sincerely
C(.1i^<_. t^'.^t'T-TZ.
Carl Welgand'"
-------
y Sr~f.4
_z
CORPORATION Suite 512. One Corporate Drive
Shelton. Connecticut 06484
Phone: 12031 925-8000
FAX /2G3,925-3088
May 3, 1995
Ms. Linda Murphy, Director
Waste Management Division
U.S. Environmental Protection Agency
JFK Federal Building
Boston, MA 02203-1911
Re: Rayraark Industries, Inc.
Stratford, Connecticut, Facility
Dear Ms. Murphy:
This is in response to your letter dated April 3, 1995 addressed
to Craig R. Smith, President of Raytech Corporation, in the
above-referenced regard. Attached to the referenced letter was a
Proposed Cleanup Plan wherein recipients of the letter were
invited to make comments concerning the EPA's recommended plan.
To assure you and the entire EPA of the position of Raytech
Corporation in the above regard, be advised that Raytech
Corporation vehemently denies any liabilities of Raymark
Industries, Inc., or any of its predecessors or affiliates, based
upon any conceived or actual theories of successor liability, and
further, specifically denies the unsupported allegations set
forth in the sixth paragraph as well as inferred in other
paragraphs of the above-referenced letter suggesting being a
potentially responsible party based upon a belief of successor
liability. The above-stated position of Raytech Corporation has
been its position since its incorporation in 1986, and it
currently is litigating similar allegations in the Federal Court
system, including the Bankruptcy Court in cases begun in 1989.
Be assured that Raytech Corporation will vigorously defend its
position with respect to said EPA allegations including
litigation if necessary.
-------
Ms. Linda Murphy
May 3, 1995
Page 2
With respect to the Proposed Cleanup Plan referenced in the
letter, Raytech Corporation believes that the recited costs of
cleanup are exorbitant and extremely excessive. Such belief is
based upon inefficiencies observed to date at the site and
inefficiencies known to exist in governmental involvement of.this
kind.
To prevent any misunderstanding as to the position of Raytech
Corporation, this is to advise that in the event it is ever
finally deemed to be a successor to the environmental liabilities
in Stratford by any court, Raytech Corporation fully intends to
seek recourse against all other involved parties, including
individual home and property owners of sites containing fill from
Raymark's Stratford facility and all other responsible parties.
As I believe you are fully aware, Raytech Corporation is
currently an active participant in sett ement discussions in this
entire matter with the EPA, Departme
and state agencies and other involve
f Justic
rties.
Btflft regards
other federal
Vice Fr esident,
and General Cou
ary
LLY:mar
cc: Michael Hill
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TOWN OF STRATFORD
CONNECTICUT
O6497
WATERFRONT AND
HARBOR MANAGEMENT COMMISSION
272T) MAIN STREET
STRATFORD. CT 7
Mr. Michael Hill, (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, Mass. 02203
May5,1995
Re: Raymark Industries, Inc.
Proposed Cleanup Plan
Dear Mr. Hill,
On behalf of the Commission I would like to convey to you and your organization our
profound concern with regard to the disposition and remediation with regard to Ferry
Creek in Stratford. As I mentioned in our letter of April 13,1995, we expressed a
desire to have an indication as to what activities would be undertaken to eliminate the
contaminants found in the Creek below the high water mark. To this date we have not
received a reply.
In the interim we have had an opportunity to review some of the documentation placed
at the Stratford Library by your organization. A review of this material reinforces our
belief that Ferry Creek is, has been and will continue to be the focal point of storm
water discharge from the noted site. In fact with the "capping" of the 33 acres, it would
appear that the storm water runoff will be increased as the property will no longer have
retention properties. As to the ground water, this too is of some long term concern.
As the Proposed Cleanup (Alternative 2), does not remove the most contaminated
soils(with PCB) these and other organics will continue to leach as they are doing
currently toward the river and in particular toward Ferry Creek. It is interesting to note
that much of the ground water, at shallow and deep levels, is brackish. This would
lead one to surmise that salt water has infiltrated this area and concludes that there is
a subsurface transport system at work.
-------
-2-
The remediation plan calls for on site testing, through wells, the ground and surface
water. We would suggest that it might be prudent to establish a number of strategic
wells or test sites off the property in the area of Ferry Boulevard and perhaps one or
more between the site and the Housatonic River more northerly of the Creek.
We look forward to having a response to our concerns in a fashion that we can
respond to it prior to the end of the comment period on June 8,1995.
Robert H. Sammis, Chairman
cc: Commissioners
Town Manager Barnhart
: Commissioner Sidney Holbrook, ConnDEP
Senator George Gunther
Representative Terry Backer
Representative Vincent Chase
Representative Lawrence Miller
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INDUSTRIES
I'NSTRUMENT DIVISION.
250 East Main Street
Stratford, Connecticut 06497-5145
Telephone 203-385-0536
FAX 203-385-0330
John W. Caldwell
President
May 16, 1995
Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building .
Boston, MA 02203
Subject: Proposed Clean-Up Plan for Ravmark Industries. Inc.
Suoerfund Site. Stratford* CT
Dear Mr. Hill:
In response to EPA's invitation to participate in the remedy selection process for the cleanup
of the Raymark Site, we submit herewith our comments on the Agency's "Proposed Plan
("preferred alternative") as described in EPA's summary document dated April, 1995
(presented to me with EPA's letter dated April 3, 1995) and your presentation at the public
hearing held April 11,1995 at the Town of Stratford, CT Public Library.
Given the feasible alternatives, risk of harm, economic cost and other factors, we concur with
EPA's choice of Alternative 2: Capping, and support it as a good common sense cost-
effective approach to resolving the problem.
Your presentation at the public hearing was clear, thorough and more reflective of current EPA
thinking that also recognizes the important of being cost effective as well as protecting public
health and the environment and complying with environmental laws and regulations. Your
selected plan is reasonably achievable and prudent.
The May 10, 1995 issue of our local newspaper, the Stratford Star, reports that the Leach
Development Corp. has purchased the Raymark property and is looking forward to completing
the construction of a retail shopping center there by the end of 1996. The paper also
indicated that public input to EPA may lead to excavation at the site rather than a cap which
would significantly delay clean-up and dramatically increase the cost and risk to the neighbors.
We trust that common sense will prevail and you will go forward with your present preferred
alternative 2.
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-2-
We also concur with your decision to defer further expansion of ground water monitoring until
surface remediation has been fully addressed. With GB classification and the fact that this
community is entirely served by public water, and there is no significant potential for use of
the groundwater as a future public water supply, it is logical to treat this with a lesser priority.
We look forward to the completion of this cleanup project and the ensuing benefits.
Sincerely,
P.S. I understand John Gloria has invited
you to speak at the Dresser Corporate
Environmental Council Quarterly Meeting
on 6/27/95 held at the Stratford plant.
Your participation is most welcome and we
look forward to your presentation of the
proposed Raymark cleanup plan..
JWC/cb
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LEBOEUF, LAMB, GREENE & MACRAE
L.L.P. >
* LIMITED LIABILITY PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS ~~ ..
LOS ANGELES
NEWYORK GOODWIN SQUARE NEWARK
WASHINGTON . 225 ASYLUM STREET PITTSBURGH
ALBANY HARTFORD, CT O6IO3 SALTLAKECITY
SAN FRANCISCO
SOSTON ,203! 293-3500 _
DENVER - ,
FACSIMILE. I3O3I 293-3555 -. :~'i- ::-'.' BRUSSELS
HARRISBURG ' ' LONDON
HARTFORD ,; . ....Jji. MOSCOW
JACKSONVILLE. WRITER'S DIRECT DIAL- ' ''
(203)293-3507 . ...
May 24, 1995
VIA FACSIMILE AND U.S. MAIL
Mr. John Deviliars
Regional Administrator
U.S. EPA, Region 1
JFK Federal Building
Boston, MA 02203
Re: Comments of Raymark Industries, Inc. to EPA's
Proposed Cleanup Plan for Raymark's Stratford Facility
Dear Mr. DeVillars:
Raymark Industries, Inc. ("Raymark") submits the
following comments to the Environmental Protection Agency's ("EPA"
or the "Agency") Proposed Cleanup Plan (the "Proposed Plan" or the
"Plan") for Raymark's facility located at 75 East Main Street in
Stratford, Connecticut (the "Facility") and various satellite
locations (the "Satellite Sites" or "Satellites") that EPA proposes
to remediate in connection with the Facility. These comments
supplement Raymark's earlier comments pertaining to the EPA's
proposed listing of the Facility and Satellites on the National
Priorities List ("NPL") and incorporates by reference Raymark's
memorandums of law as filed with the United States District Court
for the District of Connecticut in United States v. Raymark
Indust.. Inc. (Civ. No. 3:94-CV-1872 (PCD) (Jan. 24, 1995 (D.
Conn.)). Initially, it is important to note that Raymark has
supported and continues to actively support all efforts by Leach
Family Holdings ("Leach") to return the Facility to economically
productive use. Raymark not only negotiated the sale of the
Facility to Leach, but continues to work closely with Leach to
achieve a timely closing.
-------
Mr. John DeViliars
May 24, 1995-
Page 2
I. Introduction
The EPA's Proposed Plan for the Facility and the
Satellite Sites encompasses a broad and expensive remedy that can
be summarized, in general terms, as follows: (1) Decontamination
and Demolition; (2) Removal; (3) Capping; and (4) Monitoring. This
methodology equates to a roughly $40 million remediation plan. The
EPA believes that this methodology will achieve cleanup goals
better than or as well as the other cleanup alternatives that it
considered. However, as discussed more fully below, the scientific
data pertaining to the Facility, and to the City of Stratford in
general, clearly does not support such a remedy. Even if any
supporting data did exist, the Agency has still failed to develop
a sufficient amount of data upon which to rely to select a remedy.
Yet, despite the inadequacy and inaccuracy of the EPA's supporting
data and a host of other uncertainties pertaining to the alleged
risk posed by the Facility, the Agency formulated not only the
remedy described above, but several proactive alternatives ranging
in cost from $110 million to $1 billion. The fact that this range
is so wide tends to indicate the inability of the EPA to tie the
potential remedies to any concrete scientific data.
EPA's failure to address the problems and uncertainties
described more fully below militates against expenditure of the
extraordinary resources proposed to be spent under the Plan (and
which have already been spent on prior remediation of the
Facility). Up until now, the Agency has consistently deferred a
full consideration of these issues. When Raymark initially
commented on the EPA's proposal to list the Facility on the NPL,
the Agency deferred an evaluation of these issues because such an
evaluation would be premature. When Raymark raised the same issues
during the United States' litigation to expand its access to the
Facility, the Government argued that such an evaluation should be
postponed because CERCLA does not permit pre-enforcement review.
Even if an analysis of these issues was premature during
prior stages of this matter, although Raymark does not believe that
to be the case, it is clear that the time for such evaluation is
now, prior to the implementation of a remedy. CERCLA's
administrative process calls for the development of a Record of
Decision ("ROD") on the remedy selected by the Agency and a full
evaluation of all alternatives, including the technical data
supporting or contrary to each, for the administrative record.
Therefore, an analysis of the problems and uncertainties identified
by Raymark can no longer be postponed. Based on currently
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Mr. John DeVillars
May 24, 1995
Page 3
available information, such an analysis will demonstrate that the
Proposed Plan is neither appropriate nor cost-efficient.
Accordingly, Raymark requests that the Proposed Plan be re-
evaluated.
II. Scientific Data Contradict The Initial ATSDR Health
Advisory And Do Not Support Listing Of The Facility And
Satellite Sites On The NPL
The cleanup itself stems from the Agency's identification
of the Facility and the unspecified Satellite Sites as a potential
candidate for listing on the NPL. The NPL identifies those sites
that the EPA has determined pose the most significant threats to
the public or the environment. Yet, the EPA continues to have no
basis for its conclusion that the Facility and the unspecified
Satellites pose a significant threat to public health and
therefore, should be listed on the NPL.
The EPA may list a site on the NPL by ranking the site
according to specific EPA criteria under the Hazardous Ranking
System ("HRS"). See 40 C.F.R. § 300. Under the criteria, if the
site has an HRS score of 28.5 or greater, it must be listed on the
NPL. See id. §300, Appendix A. The EPA also has the authority to
list a site where the Agency for Toxic Substances and Disease
Registry ("ATSDR11) has issued a health advisory that recommends
dissociation of individuals from the release or threatened release
of hazardous substances, but only if two additional criteria are
met. See 40 C.F.R. § 300.425(c)(3). First, the EPA must determine
that the release poses a significant threat to public health.
Second, the EPA must anticipate that it will be more cost-effective
to use its remedial authority, rather than its removal authority,
to respond to the release.
EPA usually lists a site for the NPL by conducting a
ranking under the HRS. In contrast, the Agency has rarely used the
health advisory procedure for listing a site. However, when the
health advisory procedure has been used, the EPA has ordinarily
conducted a ranking as well, so that each method for listing
supports the other.
A. Absence of an HRS Ranking
In this case, however, EPA never calculated an HRS score
for the Facility and the Satellite Sites under the required
criteria. If such a calculation was made, the Facility and the
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Mr. John DeViliars
May 24, 1995
Page 4
Satellites would not score high enough to warrant listing on the
NPL. The scientific facts which support this conclusion include
the following:
Lead in the soil waste does not leach unless it is
exposed to acidic conditions with a pH of less than four;
Dioxins are considered isolated and are not statistically
significant;
PCBs are not mobile unless in the presence of solvents
(and it should be noted that significant solvents do not
exist off site);
Asbestos is present in the chrystile form (which is not
as significant as other forms of asbestos in terms of
risk) and is not free to the atmosphere (as confirmed by
analysis of the air data collected on and off -the
Facility);
Assessment of local water supply contamination and
impacts on the food chain yielded the following:
1) the community uses city water rather than private
wells, thus reducing the score for NPL status. In
fact, there are no known drinking water supply
wells within four miles of the Facility.
Therefore, groundwater is an incomplete exposure
pathway because there is no population which is
either actually or potentially exposed to any
groundwater contamination which might exist from
disposal at the Facility; and
2) Shellfish from the Housatonic River have been
tested by the State and not found to be
contaminated (thus eliminating the concern that the
multi-million dollar shellfish industry or the
health of shellfish eaters across the country are
impacted). See State of Connecticut Department of
Agriculture, April 12, 1994 1993 Annual Assessment
for the Shellfish Growing Waters in the Town of
Stratford. CT. The State Department of
Agriculture, in conjunction with the EPA and the
Connecticut Department of Environmental Protection,
conducted excessive testing as a result of the
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Mr. John DeViliars
May 24, 1995
Page 5
ATSDR advisory. Since that time, at least five
additional samples per year have been collected and
analyzed under adverse pollution conditions (after
rainfall). The scientific evidence resulting from
these efforts, collected and analyzed under the
most rigorous conditions by the State's Shellfish
Control Laboratory in Milford, Connecticut, shows
conclusively that no chemical contamination of
concern exists in shellfish growing in the
Housatonic River.
Despite these findings, and without any contradictory
data to support its determinations, the EPA still stands by its
initial decision to implement a costly, expansive clean-up of the
Facility and the Satellites. It is unlikely that even the
Stratford community would support the expenditure of tens of
millions of dollars on such remediation in the absence of any
scientific justification or any demonstration of the health
benefits to be gained.
B. Absence of a Finding of significant Threat
Without an HRS score to rely on, the EPA instead relies
solely on the basis of the ATSDR health advisory. However, the EPA
has failed to meet the necessary requirements for listing a site
based on an ATSDR advisory. The Agency has never determined, as it
is required to under federal regulations, that the Facility and the
Satellites pose a significant threat to public health.
In fact, the Facility does not pose a significant threat
to public health. The same scientific facts (on lead, dioxins,
PCBs, asbestos, water supply and the food chain) which prevent the
Facility from scoring high enough for an HRS ranking also
demonstrate why a significant threat to public health does not
exist. In addition to the previously mentioned findings, detailed
epidemiological analysis of Connecticut Health Department data
shows that town-wide cancer rates are within the normal incidents
of cancer experienced on a state-wide basis and state records also
indicate that the Stratford community has not suffered rates of
cancer greater than that of.any town in Connecticut of equal size.
In addition, no other evidence of adverse medical or environmental
effects from the Facility has been identified. EPA simply has no
basis for concluding that the Raymark Facility poses a significant
threat to public health.
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Mr. John DeViliars
May 24, 1995
Page 6
Although a full and proper risk assessment for the
Facility and the Satellites has never been completed, Raymark
itself conducted a draft worker risk assessment for a utility
trench scenario under a limited excavation program. The risk
assessment identified a risk to the workers only while they were in
the trench with contaminated soil. The assessment was based on
several assumptions and actual soil analytical data for the entire
Facility.
Although Raymark's risk assessment was not a complete
assessment of the Facility, it remains the only scenario in which
any risk to human health has been shown. Importantly, this risk
only exists if a person is almost physically touching the
contamination. Therefore, at the worst, such risk would only apply
to trench workers at the Facility or trespassers who actually fall
into a trench at the Facility.1
On the other hand, the parameters and assumptions for a
public risk assessment of the Facility would be very different than
the Raymark worker risk assessment and would assuredly demonstrate
little or no risk to the public. For instance, due to restricted
access to the Facility, there is virtually no likelihood of
exposure to the public unlike the trench workers. In addition,
Raymark covered the allegedly contaminated soil at the Facility and
filled in pot holes to limit possible exposure to any alleged
contamination to an even greater extent. As a consequence, the
upper two feet of soil at the Facility is comprised of "imported
fill," which has chemical characteristics a full order of magnitude
less than the lower "process fill." Obviously, the less
contaminated fill covering the Facility would yield a much lower
risk assessment than one performed under a utility trench scenario.
C. Inadequacy of the AT8DR Advisory
In the absence of a full risk assessment, the EPA instead
relied on the preliminary data which led to the ATSDR Health
Advisory. However, available evidence demonstrates that the
Agency's reliance on the ATSDR data and report has been, and
However, trespassing at the Facility is highly unlikely. As
discussed more fully later in these comments, the Facility is
enclosed within a fence and entrance to the Facility is only
. possible through a locked gate. Even the early ATSDR Advisory
recognized that the Facility is secure from public access.
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Mr. John DeVillars
May 24, 1995
Page 7
continues to be, unjustified. The Agency's reliance on premature,
unsubstantiated ATSDR data has not been, and cannot be,
scientifically supported. For instance, the EPA initially
requested the ATSDR to review the Facility based on its concern
over dioxin data collected, in addition to data on lead and PCBs.
However, EPA has since determined that the dioxin data is
statistically insignificant. Raymark itself completed a risk
assessment to determine the risk to drillers at the Facility. This
risk assessment showed no significant risk to the drillers, even
during intrusive work..
The Health Advisory enumerated a number of. hypothetical
pathways in which human exposure could occur. However, none of
these are borne out by the actual data, and are in fact
contradicted by it. Potential exposure through food or groundwater
pathways has already been discussed earlier and dismissed. Other
potential exposure pathways that were identified by the ATSDR are
equally hypothetical. For example, the Health Advisory suggests
the possibility of exposure through inhalation, direct dermal
contact, or ingest ion. As even ATSDR acknowledged in the Advisory,
however, the Facility is secure from public access. The Facility
is surrounded by a fence, with access only through a locked
entrance gate. The majority of the Facility is covered with
asphalt and, therefore, soil is generally inaccessible. In
addition, the alleged soil contamination at the Facility only
exists in the soil column below blacktop, steel reinforced concrete
floors, and soil caps. Moreover, there are no. residents,
agriculture or grazing at the Facility. Accordingly, the risk of
public contact with the alleged contamination is remote at best,
and this, too, is therefore an incomplete exposure pathway. The
Health Advisory itself conceded that because access to the Facility
is restricted and the waste is covered, "no health hazard is
currently posed by the presence of dioxins on the Raymark
Facility."
Considering these facts, the EPA should have completed a
full risk assessment to determine the risks present not only at the
Facility, but at the Satellite Sites. In the absence of such an
assessment, there is no available evidence which indicates that the
Facility or the Satellite Sites pose a significant threat to public
health. In fact, available evidence leads to the opposite
conclusion. Yet, the Agency's basis for its Proposed Cleanup Plan
relies completely on this incorrect assumption.
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Mr. John DeViliars
May 24, 1995
Page 8
0. Lack of Evidence That Any Satellite Sites Pose
A Significant Threat To Public Health
EPA has not demonstrated that any alleged off-site
contamination is attributable to the Facility or that it poses a
significant threat to public health. In fact, the Agency has
refused to even identify the location of any such off-site
contamination. In order to list a site on the NPL, EPA must
establish with specificity the location of the site where a release
has occurred. See, e.g.. United States v. Conservation Chemical
Co.. 619 F.Supp. 162, 163 (D. Mo. 1985). In this case, the Agency
has failed to do so. Instead, the EPA expects that the public will
approve its $40 million proposed remedy without even knowing where
the alleged contamination is and was located.
III. EPA'8 Proposed Plan Calls For Costly Remediation That Ls
Scientifically Unsupported and Economically Unjustified
Under the EPA's Proposed Plan, an estimated $40 million
will be spent for remediation at the Facility beyond the
substantial funds already expended on excavation at various
locations throughout Stratford. However, early estimates of
demolition costs alone have been estimated by government
contractors to be approximately $30 million, nearly three times the
estimate which Raymark has prepared for the same work. Such
demolition costs were not fully taken into account in the EPA's
Plan, yet they would increase the Agency's $40 million dollar
proposal by 50 percent. The absence of these costs from the
Proposed Plan precludes a fair and accurate assessment of it by the
public. Moreover, despite the enormous costs at risk, the Agency
has continued to stand by the controverted conclusions of the ATSDR
advisory. As discussed above, the very basis for the Agency's
cleanup of the Facility and the Satellites is scientifically and
economically suspect. The EPA's Proposed Plan simply should not be
adopted because it relies on "bad" science to justify a scientific
determination.
However, assuming for a moment that the basis for the
Proposed Plan is not at issue, a number of aspects of the Plan are
still questionable. Among these is the Agency/s refusal to
consider the redevelopment use of the property after remediation.
The EPA itself has publicly announced that the Site is targeted for
redevelopment. In developing the Proposed Plan, however, the EPA
never considered the probable uses for the Site pursuant to
redevelopment. As a result, the Plan contains numerous costly
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Mr. John DeVillars
May 24, 1995
Page 9
components which could have been eliminated had a consideration of
redevelopment uses been made. Accordingly, even if the Proposed
Plan had a legitimate basis, which it does not, significant
portions of the Plan remain wholly inappropriate. At the very
least, the Proposed Plan should be more properly scrutinized to
eliminate its great potential for wasting public and private party
resources.
First, EPA's Proposed Plan encompasses the excavation of
various, unspecified Satellite Sites. In fact, significant
excavation of Satellite Sites has already been completed and
further excavation is currently proceeding. This excavation
includes removal of all waste, even that below the water table. On
the other hand, the ATSDR Health Advisory recommended that only the
upper soils (three to four inches from the surface) need be removed
to reduce the risk identified. As a consequence of EPA's
requirement to remove all waste present, the costs of excavation
have increased by tens of millions of dollars. Yet, these costs
appear entirely unnecessary. In the absence of a proper risk
assessment or NPL scoring, no scientific data has been identified
which would justify the expenditure of these enormous sums.
Second, the EPA's Proposed Plan acknowledges that the
waste at the Facility and the Satellite Sites does not require
removal or on-site treatment, except in certain, unspecified,
isolated areas. Such an acknowledgement indicates that the waste
from the Satellite Sites that has already been excavated and moved
to the Facility by the EPA may not have been warranted, at least
not to the extent of removal that EPA has thus far taken. As a
consequence, millions of dollars may have been unnecessarily spent.
The EPA's Proposed Plan further indicates that the
Facility will be covered with a double thick cap and that the cap
will be drained by a designed-under-cap drainage system. However,
the pavement currently existing on the Facility has clearly reduced
the infiltration of waste to the underlying soils. Since the
infiltration is significantly reduced by the pavement, a less
costly cap is appropriate rather than a double thick cap with
drainage. The EPA's Proposed Plan, however, ignores this fact,
once again adding to the vast resources that may be unnecessarily
spent.
The Proposed Plan further encompasses the design and
installation of a gas vapor, extraction system, which arguably may
be appropriate in solvent areas. Installing such an intrusive and
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Mr. John DeViliars
May 24, 1995
Page 10
expensive system so early in the process, however, may ultimately
require the expenditure of substantial additional costs to ensure
that proposed foundations on the site are properly degassed. To
avoid these potentially unnecessary costs, the Plan should allow
the design of the extraction system to be completed in conjunction
with the end-user of the property.
The Agency also plans on installing additional wells and
completing additional studies to determine if groundwater
remediation will be required. Yet, the Proposed Plan does not
Consider groundwater and the costs of the additional wells and
studies has not been evaluated. This also adds to the uncertainty
as to the real costs of the cleanup.
All of these questionable aspects of the Proposed Plan
warrant further consideration, especially in light of the
uncertainty as to the very basis for the Plan. Even if a risk
assessment for the Facility and the Satellite Sites is .not
conducted, the validity of certain elements of the Plan, on both a
technical and economic level, should be re-assessed.
IV. A Full Consideration of the Data Supporting the EPA's
Proposed Plan Should Be Conducted At This Tin*
Raymark has raised its concerns over the listing of the
Facility and the Satellite Sites in previous comments and in
various litigation papers. Those concerns, as well as the issues
raised in these comments, specifically question the basis for the
EPA's decisions in connection with the Facility and the Satellites,
including the remedy selected in the Proposed Plan. Rather than
being hypothetical, like the Agency's support for many of these
decisions, Raymark has identified real, specific problems which
should be addressed prior to the implementation of the Proposed
Plan and the expenditure of enormous resources.
In the past, opposition to Raymark's arguments has
consistently relied on the position that review of the Agency's
administrative determinations, including its proposed listing of
the Facility on the NPL and its proposed remedy for cleanup, should
be postponed until an unspecified later point in time. That time
is now. The Agency is on the verge of implementing a Proposed Plan
under which tens of millions of dollars may be spent in the absence
of a full risk assessment or NPL study. Numerous aspects of the
Proposed Plan, as identified above, remain questionable and could
be addressed in a much more cost-efficient manner. Scrutiny of the
10
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Mr. John DeVillars
May 24, 1995
Page 11
administrative record, which has constantly been deferred, is now
absolutely necessary for the simple reason that the data may no
longer support, and may never have supported, the extreme response
that has been taken and is being called for. The Agency never
fully developed the data necessary to make the determinations it is
calling for. And more importantly, the data that it does rely on
fails to support its determinations. Therefore, before the.EPA's
Proposed Plan is implemented, a full risk assessment must be
completed to avoid the very likely possibility that millions of
dollars will go to waste on an ambitious, yet unnecessary, cleanup.
At the very least, the remedy selected under the Proposed Plan
should be re-evaluated to justify the costs anticipated.
V. Conclusion
Based on the foregoing reasons, the EPA's Proposed Plan
seeks to justify cleanup methods and costs which are clearly
unwarranted. A number of elements of the Proposed Plan are either
completely unnecessary. or achievable through more efficient and
less expensive means. In light of the failure to properly assess
the risk associated with the Facility and the Satellite Sites, and
to properly justify, scientifically and economically, the methods
and costs required to effect the remediation proposed, the EPA's
Proposed Plan should be withdrawn pursuant to further review.
Very truly yours,
RAYMARK INDUSTRIES, INC.
Jaipes A. Thompson,Vlr
Attorney for Raymar
Industries, Inc.
cc: The Honorable Jerry Lewis, U.S. House of Representatives
The Honorable Michael G. Oxley, U.S. House of Representatives
The Honorable John G. Rowland, Governor of Connecticut
Sidney J. Holbrook, Commissioner, Connecticut Department
of Environmental Protection
Michael Hill, U.S. EPA Region 1, Remedial Project Manager
HA 63302 00818 HA33445.2
05/24/95 2:42pm 11
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355 Mt. Pleasant Ave.
Stratford, Ct. 06^97
May 30, 1995
Mr. Michael Hill (HSL-CAN5)
U.S. Environmental Protection Agency
JFK Federal Building
Boston MA 02203
He: Wooster Middle School athletic field cleanup, Stratford, Ct.
Dear Mr. Hill:
I reside in close proximity to the Wooster Middle School and am interested
in returning to full operation the athletic field bordering the school on
the northwest. I do not know the precise area of the field, but, prior_ to
the summer of 1993, it supported two baseball diamonds with separate outfields,
used primarly by Stratford's budding athletes.
Prior to the spring of 1993* the EPA, and perhaps the Connecticut DEP,
suspected that PCBs and asbestos brake linings were buried in the field.
In the spring and summer of that year, the top four feet of dirt was
scraped off the field and stockpiled. The exposed surface was then cov-
ered with two feet of gravel and a plastic blanket, topped with two feet
of the original soil. When the job was completed, the children and their
parents expected to resume play, but a barrier fence was erected around the
perimeter and the interior became a hayfield. That condition persisted in
1991* and to date in 1995.
Stratford officials state that the Town cannot open the field until the
underground hazardous waste is disinterred and trucked to the Raymark park-
ing lot about 1$ miles east. -. The present delay is because legal experts are
trying to determine who will get sued if this comes to pass, a study which
could continue into the next century. Meanwhile» The Dock Shopping Center
located east of Raymark, for rather baffling reasons, is protesting the trans-
fer of PCBs and brake linings to the lot on which a competing shopping cen-
ter may be located.
If the buried junk at Wooster is contaminating underground water, that water
is not entering residential taps. There are no wells between Wooster and
Long Island Sound. Youngsters cannot be harmed playing four feet above the
nearest contamination.
Please advise whether the EPA has objection to the immediate opening of the
northwest field at Wooster Middle School. The next meeting of the Stratford
Town Council is June 12*. I hope you will be able to provide an answer by
that date.
Yours very truly
&s^y
J. R^er Shull
-------
un & Dana
Counsellors at Law One Century Tower
New Haven
Connecticut
Telephone
203.41)8.4400
Telefax
2.03.782.2889
This mobile is intended
t'nr rhe uw of the individ-
ual or ennu' 10 which ir
i.s .id dressed .iod may
contain information that
is privileged, eonfideminl
' ami exempt from disclo-
sure. If the reader of rhi>
message is noi the
intended rccipicnr or
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rcspimsihlL1 for delivering
the message to the
intended recipient, you
are hereby notified that
any disseminnciun. distri-
bution, or i-npyinp of this
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notify us immedim-ly
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Thank vou.
TF. LHFAX TRANSMITTAL
To:
Michael Hill (HSL-CAN5)
JEEA, ......................................... ...
Telefax number:
From:
TelcphoilC inimher:
Abbie.Erejmcbj-Esq*
1..203..49&4397
Cliem/matter code:
isc copy:
NX'o will eopy:
imtructions;
PLEASE DELEVER TO MICHAEL AS SOON AS
POSSIBLE. THANK YOU.
follnvV ihis
-------
Wiggin dr Dana
Counsellors at Law
Offices in New H»ven
and Hartford
One Century Tower
New Haven, Connecticut
06508-1831
Telephone 103.498.4400
Telefax zo3.78i.iMj
Abbie Ercmich
BY FAX AND OVERNIGHT MAIL
June 6, 1995
Michael Hill (HSI^CANS)
Remedial Project Manager
United States Environmental
Protection Agency
John F. Kennedy Federal Building
Boston, MA 02203-0001:
Re: Utility Comments to Proposed Cleanup Flan -
Raymark Sites, Stratford, Connecticut
Dear Mike:
Attached are the comments to the Proposed Cleanup Plan for the Raymark Facility
in Stratford, Connecticut submitted on behalf of The Bridgeport Hydraulic
Company, Southern New England Telecommunications Corporation, The United
Illuminating Company and the Southern Connecticut Gas Company. I have sent
another
comments
closes,
to you through the overnight mail to ensure that you receive these
fore June 8, 1995, which is the date when the public comment period
Please call me if you have any questions or concerns relative to these comments or
more generally to utility issues in and around Stratford.
Best wishes.
Ve r truly yours,
Ercmich
Attachment
cc all by regular mail:
Eric Conrad
Jim Hart
Robert Silvestri
Anne O. McCrory, Esq.
92M\2500M.TtMH_.UE
-------
FOR INCLUSION IN THE
ADMINISTRATIVE RECORD
COMMENTS SUBMITTED ON BEHALF OF;
1. The Bridgeport Hydraulic Company ("BHC");
2. Southern New England Telecommunications Corporation ("SNET);
3. The United Illuminating Company ("UT); and
4, The Southern Connecticut Gas Company ("SCGC")
COMMENTS SUBMITTED BY*
Abbie Eremich, Esq. - Wiggin & Dana for BHC, SNET and UI
Anne O. McCrory, Esq. - Counsel for SCGC
COMMENTS SUBMITTED BY OVERNIGHT MAIL TO;
Michael Hill (HSL-CAN5)
Remedial Project Manager
United States Environmental Protection Agency
John F. Kennedy Federal Building
Boston, MA 02203-0001
COMMENTS TO;
Proposed Cleanup Plan
Final Source Control Feasibility Study Report
Remedial Investigation/Feasibility Study ("RI/FS")
RaymarK Industries, Inc. Facility
Stratford, Connecticut
Dated in April 1995
COMMENTS DATED. SENT BY OVERNIGHT MAIL AND SUBMITTED ON;
June 6, 1995
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1. Introduction
The four above-referenced Utilities submit these comments in response to several
specific aspects of the Proposed Cleanup Plan for the Raymark Industries, Inc. Facility
(the" Raymark Facility") located in Stratford, Connecticut (the "Site") as set forth in the
Final Source Control Feasibility Study Report, Remedial Investigation ("RT^/Feasibility
Study (the "PS", "Cleanup Plan" and ""RI/FS", respectively). The comments set forth
herein are directed, as applicable, both to the United States Environmental Protection
Agency (TEPA") and the Agency for Toxic Substances and Disease Registry ("ATSDR"),
but for convenience, reference below is only to EPA. The comments are directed at the
following topics and will be addressed below in the same order:
a. The Risk Assessment and the so-called residential excavation protocol
employed or alleged by the EPA to be employed during the residential
excavations in and around Stratford (the "Protocol"), as both documents relate to
utility worker safety and residential health and safety issues at and around
residential areas where EPA has left, or will leave, behind at depth certain wastes
containing at a minimum any two of the following constituents: asbestos; lead:
and/or polychlorinated biphenyls ("Raymark Waste");
b. Disposition of Raymark Waste-contaminated soils left behind at depth and the
question of the Utilities' obtaining access to, and performing utility servicing in
and around residential areas if, as, and when it becomes necessary in connection
with routine and/or emergency utility servicing of the subject residential areas to
excavate such Raymark Waste-contaminated soils.
2. EPA's Risk Assessment and Protocol
EPA's Risk Assessment addresses the health threat to utility workers who may contact
contaminated surface and subsurface soils during repair or excavation activities at the
Raymark Facility.
The Risk Assessment concluded that the potential for adverse human health effects
exists fon utility workers both on the Raymark Facility and off-site in the vicinity of the
Raymark Facility.
EPA has conducted, and is in the process of conducting, a series of removal actions from
residential properties in and around Stratford which were/are contaminated with
Raymark Waste. These waste materials were removed, and will be removed, from the
residential properties, and apparently were studied together with the wastes on the
Raymark Facility as part of the Feasibility Study.
EPA's excavation of Raymark Waste-contaminated soils from the residential properties is
ongoing, occurring both during and after this public comment period for Operable Unit
One as set forth in the Cleanup Plan. However, the health effects to both Utility
employees, agents or representatives and homeowners relative to EPA's Protocol for the
-2-
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residential excavation is not evaluated in the FS or in any other document available for
public comment. The significance of this omission from the RI/FS - Risk Assessment is
as follows.
EPA's Risk Assessment relative to utility workers on the Raymark Facility proper
indicates a potential threat to utility workers on the Raymark Facility and in the area of
the Raymark Facility. In EPA's Protocol for residential excavation, EPA apparently has
decided to leave behind Raymark Waste-contaminated soil - in some cases the very
same type of soil studied at the Raymark Facility and as to which EPA concluded there
is a potential threat to utility workers - at certain depths at certain Stratford residences.
Utility infrastructures may run through and beneath the depths at which EPA elected to
leave Raymark Waste-contaminated soils behind. Accordingly, when these utility
infrastructures require routine or emergency maintenance, the Utilities' employees,
agents or representatives will have to dig into, and thereby disturb, the Raymark Waste-
contaminated soils thus left behind by EPA. Not only will the Utilities' employees,
agents or representatives be at risk (as EPA's Risk Assessment could be read to
conclude in this context), but the homeowners also will be subject to the potential for
health risk or actual health risk due to the disturbance of the Raymark Waste-
contaminated soils EPA decided to leave behind.
The Utilities believe that EPA should have evaluated these risks to the Utilities'
employees, agents or representatives and.homeowners in connection with both the
development of the Protocol, and the Risk Assessment evaluation hi the FS.
3, Disposition of Raymark Waste
EPA has not addressed the case when the Utilities must service the Stratford residents
upon whose property EPA either has not excavated the Raymark Waste-contaminated
soils that exists thereon, or has left behind Raymark Waste-contaminated soils thereon.
Such utility servicing requires accessing such properties through the streets and curbs,
including areas where utility poles servicing the residences may be located. EPA has not
given the Utilities the sampling/analytical data regarding such properties and areas. The
Utilities do not know the exact identity of the residential lots or other areas where EPA
has identified Raymark Waste-contaminated soils, the extent of contamination thereon,
and precise information as to the nature and extent of Raymark Waste-contaminated
soils left behind on and around these residential properties.
Based upon the limited information the Utilities have been able to collect from the
Town of Stratford relative to EPA's residential sampling and excavation activities, it
appears that the Utilities may have to disturb Raymark Waste-contaminated soils in the
course of utility operations at and around such properties. :
The Utilities believe that EPA should have involved the Utilities in the development of
the residential excavation Protocol. Such involvement would have acknowledged both
the ongoing need to the homeowners of utility servicing and the potential or actual
health-based risk to utility employees, agents or representatives and the homeowners if
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the Utilities have to perform their operations through Raymark Waste-contaminated
soils on and around residential properties and areas where utility poles necessary to
service the homeowners may be located. The Utilities also believe that EPA should
have studied this issue as part of the Risk Assessment to develop a dear and complete
understanding of the source of the Raymark Waste-contaminated soils being brought
onto the Raymark Faculty and the potential or actual health risk to all individuals who
may now or in the future first or ever come into contact with such Wastes. Unlike
concerns expressed as to the reasons for not having studied groundwater at the Raymark
Facility and around Stratford, the potential or actual health risks herein described will
not be studied and evaluated by EPA at a later time, for example, in connection with
operable unit two as will groundwater. Therefore, this is the correct and only time to
effectively study and evaluate these issues.
Hie Utilities believe that EPA needs to develop a method to provide for EPA's or the
Lead Agency's removal off-site of Raymark Waste-contaminated soils from such areas
when Utilities encounter same during utility servicing operations now and in the future.
The Utilities believe that such EPA method should include reserving space under the
proposed cap at the Raymark Facility for such Wastes and having the On-Sccnc
Coordinator arrange for the removal, transportation and off-site disposal of such Wastes,
whether directly, or indirectly through an appropriately trained contractor retained by
EPA or the Lead Agency, when called to do so by the Utilities. In connection with this
issue, the Utilities also believe that EPA inadequately evaluated and under-estimated the
volume of Raymark Waste from the residential excavations that need to be disposed of
at the Raymark Faculty and that a revised estimate needs to be developed to account for
the volumes accumulated during utility operations herein described.
4. SnmmaTy
As set forth above, EPA inadequately studied and evaluated the risk to utility employees,
agents and representatives and homeowners relative to necessary utility servicing in and
around the residential properties and in areas servicing those residences at which EPA
has sampled and found Raymark Waste-contaminated soils. Further, EPA
underestimated the amount of Raymark Waste necessary to be disposed of at the
Raymarl^ Facility because it did not estimate the amount of such Waste that will need to
be disposed of at the Raymark Faculty when the Utilities perform routine or emergency
maintenance work at, in and around the subject residences and in areas servicing those
residences as set forth above.
The Utilities believe that EPA should re-evaluate, re-study and redevelop the Protocol
and the Risk Assessment and FS associated with the issues raised herein so as to be
appropriately protective of the health and safety of the Utilities' employees, agents or
representatives and homeowners described in this comment The Utilities also believe
that EPA should ensure that adequate space is reserved at the Raymark Faculty for the
disposal of Raymark Waste-contaminated soils encountered during utility operations in
and around Stratford.
-4-
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June 7, 1995
Richard Cavagnero
Raymark Team Leader
U.S. E.P.A.
Northeast Region
J.F. Kennedy Federal Building
Boston, MA 02203-2211
Dear Mr. Cavagnero:
Enclosed are the comments of The Dock, regarding EPA's
Proposed Cleanup Plan for Raymark Industries, Inc., Stratford,
Connecticut. If you have any questions, please call my
attorney, Mr. Thomas F. Harrison, at 203-275-0480.
Very truly yours,
Robert Osborne
The Dock Inc. 955 Ferry Boulevard P.O. Box 368 Stratford, CT 06497 (203) 377-2353
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Comments of The Dock on EPA's Proposed Cleanup Plan
[production
The Dock's preparation of Comments on EPA's Proposed Cleanup Plan has been made more
difficult because of the government's failure to respond in a timely manner to requests for
information made under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552.
FOIA requests were submitted to EPA on May 16, 1995 and May 24, 1995; to The Department
of Justice on May 23, 1995; and to The Agency for Toxic Substances and Disease Registry,
Centers for Disease Control on May 24, 1995. The Dock reserves the right to submit
additional comments once the above information has been provided.
As discussed more fully in Section 9.00 below, the administrative record located in both
Boston, Massachusetts, and in Stratford, Connecticut was missing 113 key pages of information
until late May 1995. The lack of this vital information in the administrative record deprived
the public of important information necessary for preparing comments. EPA refused to extend
the comment period, thereby restricting the public's ability to provide constructive comments.
The following comments have been prepared as best as possible, given the delay in obtaining
information.
1.00 Overview of Proposed Cleanup Alternative (SC-2)
EPA in its April 1995 Proposed Cleanup Plan stated that it will "begin additional studies to
further evaluate the groundwater contamination ... to identify potential groundwater cleanup
options in the future, if necessary." (Emphasis added). This approach is both technically
unsound and unworkable as well as contrary to EPA's laws and guidance. A rational decision
at this site cannot be made which treats one operable unit (on-site soils and NAPL) without
determining the appropriate remedial options for the other operable units (groundwater and
surface water) which by both legal and technical necessity should be related to the remedy for
the on-site soils and NAPL.
Since the Proposed Cleanup Plan also states that "contaminated groundwater is suspected to
be flowing beyond the facility boundary," EPA's expectations without having undertaken any
off-site studies must comply with 40 C.F.R. § 300.430(a)(l)(iii)(F), i.e., that groundwaters will
be returned "to their beneficial uses where practicable," and otherwise "to prevent further
migration of the plume, prevent exposure to the contaminated ground water, and evaluate
further risk reduction." The Dock believes that EPA's Proposed Cleanup Plan for the pn-site
soils and NAPL will impede, be inconsistent with and ultimately preclude implementation of
this expected final groundwater remedy in violation of 40 C.F.R. § 300.430(a)(l)(ii)(B). Once
the site is capped and a building is constructed thereon, it will be impractical to collect or
contain contaminated groundwater on-site in a technically sound and cost-effective manner.
EPA should not sign a Record of Decision (ROD) until the appropriate on-site and off-site
investigations haVe taken place. At that time, it will be clear, for example, whether recovery
wells are required on-site and where they should best be located, whether a barrier wall is
required around part or all of the site, etc. The Dock believes that the EPA will not be able
to compress the schedule for all further studies of on-site and off-site conditions between die
period June 1995 and anticipated construction of the cap in late 1995 or early 1996. The
requirement for the necessary on-site and off-site investigations and associated modeling of
complex groundwater and surface water flow conditions cannot be effectively completed in this
short time frame. Installation of a barrier wall or monitoring wells must be done before
construction of the cap. Based on EPA's Proposed Cleanup Plan, it appears EPA envisions
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allowing construction of a building on the site before the remedy for other operable units is
selected. If this were to happen, at best the integrity of the cap would be compromised during
the installation of recovery wells or removal of soils. At worst, contaminated soil or
groundwater beneath the building would require removal, which would be nearly impossible.
To date, EPA has not made clear who will be responsible for inspecting and maintaining the
cap. Conceivably, EPA, the current owner, Raymark, or the prospective owner, Leach
Development, may bear this responsibility. It is important for accountability purposes that the
public be provided this information.
In addition, the EPA contractor chose not to present off-site data when available. In Section
2.1.2 of the Remedial Investigation conducted by Haliburton/NUS, reference is made to off-
site sediment sampling conducted as part of an EPA Site Inspection Visit. These data must be
made available to the public before a ROD is signed so that an adequate evaluation of study
area natural resources can be conducted.
Without the appropriate off-site studies, we can only estimate the environmental areas of
concern. The following areas of concern may require additional on-site and off-site remedial
or removal activities which would be impeded by, inconsistent with and precluded by capping:
Groundwater quality off-site is likely several orders of magnitude above maximum
contaminant levels (MCLs) in certain areas.
The Raymark site drainage is discharging contaminated materials to Ferry Creek.
This surface discharge and current groundwater discharge may be causing adverse
impacts to Ferry Creek and the Housatonic River and their associated sediments and
aquatic ecosystems.
Contaminated groundwater may be discharging to surface water, wetlands, and
residents' basements.
Residents may be eating homegrown food grown in contaminated groundwater.
LNAPL vapors (e.g., toluene) may be entering homes creating a health and explosion
hazard.
People may be eating fish/shellfish contaminated by the site groundwater discharges
to surface water/sediments.
Contaminated groundwater may be reaching homeowners' wells (potable) or more
likely their swimming pools (non-potable use).
There may be industrial/commercial pumping wells causing exposure to the public
(e.g., car wash).
The EPA must determine which of these are of concern before an appropriate alternative is
selected.
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-3-
2.00 Selection of Proposed Cleanup Alternative without Consideration of the Relationship
Between Affected Soil and Groundwater
The EPA failed to consider in its selection of the Proposed Cleanup Alternative the effect that
soils are having and will continue to have on groundwater. On December 30, 1994, EPA
released to the public its Draft Soil Screening Guidance (Federal Register, Volume 59, No.
250, p. 67706). Although the numerical levels and detailed implementation outlined in this
document may be subject to change, this document clearly reflects EPA's policy of 1) setting
appropriate remedial objectives for soil and 2) considering the potential impact of contaminated
soil on groundwater. In fact, analysis of contaminant fate and transport, and of the pathways
whereby contaminants move from one medium to another, are central to a Remedial
Investigation. As such, the effect of contaminated soils on groundwater should have been
considered in both the RI and the FS as well as in the ROD.
The Haliburton/NUS RI states in Section 3.3.1 that the groundwater quality, classified by CT
DEP as GB, is unsuitable for treatment based on Reference 7 (Final Site Inspection Report
for Raymark Industries, Roy F. Weston, Inc., 1993), presumably due to salt-water intrusion.
However, before signing a ROD, EPA must articulate its position regarding the most beneficial
use of the groundwater. Based on the investigations to date, restoration to potability (i.e.,
MCLs) should be the primary objective with elimination of adverse surface water and sediment
effects as a secondary objective. If these objectives are impracticable, containment of
groundwater must be implemented to prevent further migration of the plume. EPA must state
how this can be achieved if a cap is to be installed on the site.
3.00 Management and Disposal of PCB-containing Soils
EPA's proposed remedy would violate its own PCB Spill Cleanup Policy. 40 C.F.R. Part
761. Under this policy, "PCB's at concentrations of 50 ppm or greater must be disposed of
in an incinerator which complies with § 761.70." 40 C.F.R. § 761.60. Sections.(a)(2) through
(5) contain various exceptions to this requirement, only one of which applies to contaminated
soil. Under (a)(4), PCB-contaminated soil may be disposed of in either an incinerator or "in
a chemical waste landfill which complies with § 761.75." This language is mandatory-it does
not allow for disposal of PCB-contaminated soils at the Raymark Site. Clearly, under this
policy, EPA may not dispose of soils containing greater than 50 ppm of PCBs on the Raymark
Site. But in the face of this unambiguous policy, EPA intends to dispose of such PCB-
contaminated soils, which were excavated off-site, at the Raymark Superfund Site.
In addition, the PCB Spill Cleanup Policy requires that sites of PCB spills having a
concentration of PCBs greater than 50 ppm must be remediated. 40 C.F.R. § 761.60(d).
Although the policy purports to apply to "spills which occur after May 4, 1987," according
to EPA and die case law, the PCB Spill Cleanup Policy applies to spills occurring before the
regulations were promulgated. In the Matter of Standard Scrap Metal Company. TSCA Appeal
No. 87-4, 1990 LEXIS 10 (August 2, 1990); accord In the Matter of Citv of Detroit Public
Lighting Department. TSCA Appeal No. 89-5, 1991 LEXIS 1 (February 6, 1991). Thus, under
these precedents, EPA is required to clean up the PCB-contaminated soil on the Raymark
Superfund Site by either incineration or by meeting the requirements applicable to a chemical
waste landfill.
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4.00 Issues Relating to Bringing Off-Site CERCLA Wastes Back to the Site
In short, EPA's management of the CERCLA wastes removed from off-site locations and
brought back to the site is a violation of EPA's Off-site Rule as well as RCRA's regulations
concerning land disposal restrictions ("LDRs"). The EPA's actions have in effect convened
the Raymark site into a RCRA treatment, storage or disposal facility subject to regulations
under subtitle C.
EPA promulgated its Off-site Rule in 1993. 58 Fed. Reg. 49,200 (1993). The rule "applies
only to actions being taken under a CERCLA authority or using CERCLA funds." Id. at
49,203. It mandates that a facility used for off-site management of CERCLA wastes "must be
in compliance with RCRA or other applicable Federal and State laws" and must meet the
following criteria:
Units receiving CERCLA wastes at RCRA subtitle C facilities must not
be releasing any hazardous wastes, hazardous constituents or hazardous
substances;
Receiving units at subtitle C land disposal facilities must meet minimum
technology requirements;
All releases from non-receiving units at land disposal facilities must be
addressed by a corrective action program prior to using any unit at the
facility; and
Environmentally significant releases from non-receiving units at Subtitle
C treatment and storage facilities, and from all units at other-than-Subtitle
C facilities, must also be addressed by a corrective action program prior
to using any unit at the facility for the management of CERCLA wastes.
Id, at 49,202
EPA is clearly in violation of this policy. EPA has excavated or will excavate, and allowed
other parties (including the State of Connecticut) to excavate, contaminated soil from numerous
locations in Stratford, Connecticut, and has moved this soil to the Raymark site, where EPA
plans to dispose of the waste by landfilling. Since the Stratford Superfund Site does not meet
the requirements discussed above for a facility used for the management or disposal of
CERCLA wastes, to do so will violate the Off-site Rule.
EPA clearly states in the Preamble to the Off-site Rule that the purpose of the rule is to avoid
having CERCLA wastes contribute to future environmental problems.
Congress and.EPA have always believed that a CERCLA cleanup should
be more than a relocation of environmental problems, and have attempted
to ensure the proper treatment and disposal of CERCLA wastes removed
from a CERCLA site. EPA believes that the process set out in this rule
for ensuring that JCERCLA wastes are transferred only to properly-
permitted facilities that have no relevant violations or uncontrolled
releases, assures that the receipt of CERCLA waste will not pose adverse
effects on the environment.
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58 Fed. Reg. at 49,201.
In addition, EPA is required to comply with land disposal restrictions ("LDRs"). According
to EPA's guidance, LDRs are applicable when 1) placement occurs (EPA has conceded that
placement occurred--$ee EPA Memo dated April 5, 1995 from Kathleen E. Woodward and
Michael Hill), 2) of a RCRA hazardous waste, and 3) the RCRA hazardous waste is restricted
under the LDR. Superfund LDR Guide #5, "Determining When Land Disposal Restrictions
(LDRs) Are Applicable to CERCLA Response Actions," dated July 1989.
EPA concedes that the LDRs are applicable but argues that it would be impracticable to comply
with them. See EPA Memo. Further, EPA argues that waste excavated from residences and
"placed on the site during the removal action did not trigger LDRs during the remedial action
so long as the waste remained within the area of contamination." EPA Memo. According to
the NCP,
placement occurs . . . when waste .is moved from one [area of
contamination ("AOC")] to another. Placement does not occur when waste
is consolidated within an AOC, when it is treated in situ, or when it is left
in place.
55 Fed. Reg. at 8758.
EPA appears to be arguing that contaminated soil that was excavated from residences and
temporarily stored at the Raymark facility can now be disposed of at the site without complying
with LDRs because the contaminated soil was "placed" at the site and thus is now within the
same AOC as the pn-site waste. This would only be the case if LDRs were complied with
when the waste soil was "placed." EPA should not be allowed to avoid LDRs hi the first
instance and then argue that because the waste soil was "placed" on the site, that LDRs need
not be complied with because of the AOC concept. '
The excavated soil was removed by EPA and placed on the Raymark site without complying
with LDRs because the removal was considered to be a Time Critical Removal Action. See
EPA Memorandum From Michael Hill Regarding "Raymark Industries, Inc.: Waste Subject
to the RCRA Land Disposal Restrictions (LDRs) And Addressed Through The Raymark Time-
Critical Removal Action Does Not Trigger LDR For The Remedial Action At The Raymark
Site" dated March 17, 1995. However, the justification for concluding that compliance with
the LDRs was impracticalthat is, that "[t]he time required to treat the waste would delay the
Removal Action at residential properties, thereby compromising the protection of public
health"~np longer exists. Since the immediate threat to the public is over, EPA must now
comply with the LDRs during the remedial phase.
Further, the area of contamination concept applies only to the movement of waste within a
single AOC; it does not apply to wastes that are consolidated from different AOCs into a single
AOC. See Superfund LDR Guide #5. EPA is attempting to "boot-strap" its way out of
also Section 2.4.3.6 of the FS, which states that soils containing contaminants
restricted under LDR and not already "placed" would have to be treated to acceptable levels
prior to landfilling. This contradicts the statements in the Proposed Cleanup Alternative (page
5) and elsewhere in the FS (section 3.2.2) which imply that off-site soils would be placed
without further treatment.
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complying with LDRs by asserting that by "placing" off-site contaminated soil on the Raymark
site, EPA has somehow converted "off-site" waste into "on-site" waste.
Finally, EPA's disposal of a hazardous waste after RCRA requirements became effective
mandates that RCRA closure requirements be complied with. In addition, EPA's Proposed
Cleanup Alternative constitutes landfill closure. As such, postclosure care as specified in 40
C.F.R. §§ 264.117, 264.228(b) should be included in EPA's Proposed Cleanup Alternative.
Without these prescriptions, EPA's Proposed Cleanup Alternative violates both CERCLA and
RCRA.
5.00 Scope of the Remedial Investigation
An RI/FS, such as that completed for the Raymark Superfund Site, that does not consider
impacts of soil and NAPL to groundwater, surface water and human receptors both on and off-
site is inherently inadequate. The RF inadequately characterizes the soil and groundwater under
the existing buildings: limited soil sampling was carried out, and no groundwater monitoring
was conducted. One clear example is illustrated by Figures 4-2 and 4-9 of the RI. In Figure
4-9 the concentration of trichlorethylene (TCE) in monitor well M2 on the southern boundary
of the site was 1,100 jug/kg (ppb), which is a concern because it is 220 times the MCL and
because no soil sample to the north or northwest (i.e., presumed upgradient) contained such
high levels of TCE. This result suggests that either the groundwater flow direction was
characterized inadequately, or more likely, that there is another area of high soil TCE
concentrations or NAPL that has not been found. From the location of M2, this TCE source
could very likely be under a building. This example emphasizes the need to conduct further
sampling before deciding on a final remedy for the soils.
Another problem compounding the failure to characterize the potential impact of soils on
groundwater is the lack of reliable hydraulic conductivity data for any horizontal or vertical
portion of the site. All hydraulic conductivity data have been established -by slug test, a
notoriously unreliable method as indicated by the fact that, for example, the reported hydraulic
conductivity for the Stratified Silty Sand Unit as reported in Table 3-3 of the RI varied from
0.075 to 96.4 ft/day i.e., more than a factor of 1,000. This is not indicative of a singly
homogeneous geologic unit. Since no off-site studies have been carried out nor attempts been
made to ascertain how soil contaminants will migrate to groundwater, it is not clear how errors
in the hydraulic conductivity would affect the groundwater or surface water remediation..
However, it is clear that the on-site characterization has been inadequate.
6.00 Public Involvement Process
The materials presented at the public meeting are of necessity brief summaries of the overall
RI/FS. However, the small color figures representing contamination of groundwater are
misleading. Although off-site studies had not been conducted, the clear message of the figure
"Highest Toluene Concentration in Groundwater" is that contamination is an on-site problem
and that contamination is moving southwest. Neither is correct. The use Of the "Site Planner"
program at this site was invalid for the following reasons. First, the method of interpolation
used was linear and restricted to the site itself, which was inappropriate. A geostatistical
variogram-based approach would be more appropriate and would probably give a very different
picture of the contamination, including the ability to predict off-site concentrations.
Additionally, the "contouring" for both soil and groundwater contamination was based on
samples at many different depths. Contouring for soil should only be carried out with samples
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taken at the same depth, whereas for groundwater, the samples should be in the same geologic
unit.
7.00 Scope of the Feasibility Study
Four problem areas were noted in the FS:
1. By considering the soil/NAPL separately from the other operable units and not
considering soil/NAPL impacts on groundwater and surface water, the alternatives
contained are incomplete. Slurry walls or groundwater containment/treatment were
not investigated fully. These alternatives, theoretically, could be installed after the
cap, but in practice would be impeded by and inconsistent with early installation of
a cap.
2. Even ignoring problem 1) the alternatives considered are incomplete. For example,
because of the high levels of soil contamination in the overburden, EPA should
consider building a slurry wall, dewatering, and excavating below the water tables
because of the high levels of soil contamination in the overburden (this approach is
ongoing at Schuykill Metals Superfund Site in Florida). In Section 2.4.3.3 of the FS
slurry walls were eliminated from consideration because of "concerns about the
effectiveness." Although a slurry wall is less effective when the bedrock is somewhat
fractured, this alternative should be re-examined because it could significantly reduce
groundwater flow through die waste material in the more permeable overburden.
This alternative must be properly considered and a supplement to the FS issued for
public comment.
3. The areas to be excavated are not equivalent to the areas requiring treatment/disposal.
For example, in Appendix B of die FS in the table "Volume Calculations by Location
- Subarea 1," the first entry for location MW-B4 shows only 1,926 cubic yards are
contaminated but 3,852 cubic yards need to be removed because die contamination
is 4 feet below grade. Thus, treatment/disposal costs should have been based on an
estimate of 1,926 cubic yards rather dian 3,852 since the top 4 feet can likely be used
on-site as fill. With the limited time available for comments, it has not been possible
to recalculate the exact volume of soil for which treatment/disposal costs were
estimated.
4. The costs for all alternatives were significantly overestimated. The most significant
error (akhough almost all costs seem to be overestimated, e.g., 590,000
decontamination of a trailer diat only cost $30,000) is in off-site treatment and
disposal costs for PCB-contaminated soil. For example, in Appendix C of dhe FS
(SC-4) die cost of hauling and disposing of 612,000 tons of PCB material is given
as $1,035,311,997, including subcontract cost, profit, health & safety monitoring,
contingency and engineering costs. This is equivalent to $1,691.69 per ton.
Soil removal and disposal estimates have been obtained by die Dock's consultant for
bodi die Wooster Middle School and the Raymark site. Cost estimates for soil
removal, off-site disposal and placement of clean backfill at the Wooster Middle
School site should not exceed $200/ton or $8,400,000 total. Approximately 42,000
tons of contaminated soil is present at the Wooster Middle School site.
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The EPA has estimated that between 420,000 and 700,000 tons of contaminated fill
is present at the Raymark site. Soil removal, off-site disposal and placement of clean
backfill at the site according to EPA estimates would cost 51,092,100,754 or about
$2,600/ton. The Dock's consultant estimates that a value of $300,000,000 or
$428/ton is more realistic.
In addition, Appendix C to the Feasibility Study (Volume XXI of the Administrative Record),
unrealistically estimates the costs of the various remedial alternatives. Inaccuracies in the cost
estimates include the following:
There is no basis for using these costs for comparing alternatives because they do not
include the additional costs of groundwater treatment and containment systems, which
will be incurred. The cost of a complete removal option, above and below the water
table, should be calculated by EPA and compared with the cost of Alternatives SC-
. 1 through SC-4, including appropriate on-site and off-site groundwater treatment,
before a remedial alternative is eliminated based on cost.
The flat estimate of Healdi and Safety Monitoring (percentage of Total Direct Costs)
is unrealistic. For example, in Alternative SC-4 health and safety costs for hauling
PCB soils and off-site incineration disposal is over $16 million even though mos,t of
' this activity requires minimal EPA contractor oversight. Assuming the excavation
takes 5 years, as set out in the Assumptions of Alternative SC-4, this is over S3
million per year for one or perhaps two people to watch trucks.
The $ 10,000,000 cost for decontamination and demolition of the on-site buildings and
structures is not justified in any way other than Raymark Industries Quote to EPA.
An independent evaluation or review by EPA is necessary.
No reason is given for taking 200 groundwater samples per year for 30 years at an
annual cost of $428,000 per year under all alternatives. It is clear the'number would
probably be reduced after, say, 5 years, especially for the alternatives involving
removal of significant amounts of soil.
Many estimates are based on a soil density of 1.5 tons/cubic yard. No justification
for this high density could be found. Cost estimates should be prepared based on
real field data rather than this overly conservative estimate.
The costs for thermal desorption/solidification stabilization represent reasonable
estimates for small quantities, but significant economies of scale would likely exist
for treating over 600,000 tons of soil. EPA should cite costs for comparable sized
thermal desorption/solidification stabilization operations.
All alternatives include laundry costs, but standard procedure is to use disposable
clothing. :
8.00 Decontamination and Demolition of the Buildings On-Site
No plan was presented in the Proposed Cleanup Alternative or in the RI/FS to explain how the
buildings currently on-site will be decontaminated and demolished. As stated in Section 3.2.2
of the FS:. "To date, a comprehensive environmental assessment of these buildings and
structures has not been conducted." Without this information, it is not clear what quantity and
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-9-
type of additional hazardous materials would require on-site or off-site treatment/disposal.
Since 1) decontamination and demolition of the buildings must occur before the cap is built,
and 2) these materials might affect the selection of a preferred remedial alternative, EPA should
not have chosen a preferred alternative until a detailed environmental assessment had been
carried out. Additionally, the safety precautions and monitoring that will be enacted during
decontamination and demolition should be specified and made available for public review as
part of the Proposed Cleanup Alternative.
9.00 Missing Pages
According to our detailed review of Phase IIB to date, 113 pages of information were missing
from the administrative record in Boston. The entire affected section including the initially
.provided 137 pages consisted of 250 pages. After discussion with EPA personnel in Boston,
the missing 113 pages were sent via overnight mail.
The Dock's consultant checked the Stratford Library data on May 25, 1995 and found that the
missing 113 pages were present. However, Ms. Connie Dewire of the EPA indicated that she
had reviewed the affected section of the Stratford file and believed that it was always complete
with a total page count of 137 pages not 250. The EPA has either added the missing pages to
the Stratford file prior to May 25, 1995 but after Ms. Dewire had counted the pages, or has
neglected to thoroughly review this section of the file.
In Volume III of the Administrative Record, the table "Preliminary Summary Statistics for
Groundwater Data" is missing the final page: Page 6 of 6. The Dock's consultant confirmed
that this page was missing in the Stratford Library file after the EPA file review.
10.00 Possible State CERCLA Liability
The Dock has one final concern with EPA's Proposed Cleanup Plan that is, the possibility
that the state of Connecticut will be named a potentially responsible party ("PRP") at some time
in the future and be sued' by EPA or private parties for all of the response costs at this site.
This draconian scenario is entirely possible.
EPA has named only two PRPs at this site: Raymark and Raytech, the purported successor to
Raymark. Both of these entities are in bankruptcy proceedings, and may therefore escape
liability for the costs of remediation.
At the same time, the state of Connecticut plans to excavate soil containing hazardous
substances from the Wooster Middle School and from a state-owned property and dispose of
these wastes on the Raymark site. EPA's documents refer to an estimated additional 8,000
cubic yards of "off-site fill to be consolidated onto the Raymark property." We understand that
a portion of that fill will be excavated from state-owned land located near Longbrook Avenue,
south of the railroad. If the state does excavate either that fill or fill located at the Wooster
Middle School and dispose of it at the Raymark site, the state could be held liable as a PRP
in future cost recovery actions. Given that the only named PRPs are in bankruptcy, the state
could be left as the only PRP at the site and thus responsible for the entire cleanup cost.
11.00 Suggested Actions for EPA
At this time, EPA should not sign a ROD for any operable unit. It is clear that the inadequacy
of on-site data and the total absence of off-site data preclude selection of any kind of final
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remedy. An appropriate action at this point should be either an interim remedial action or a
removal action. These actions would include collecting the NAPL data and limiting access to
soils that are grossly contaminated and present the most significant health risks. The EPA
should publish, in detail, the scope and schedule of the other on-site and off-site studies to be
completed and obtain public comments on these studies before signing the ROD.
DBH8M
/uir2/wpc/fflcfaddea/wodE/KMM011
June 7, 1995 5:39pm
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STATE OF CONNECTICUT
A I (Jt £.> v iKU.Wi£..N i.vi- fKUitL
June 8. 1995
Mr. Michael Hill (HSL-CAN5)
Remedial Project Manager
US EPA
JFK Federal Building
Boston, MA 02203-1911
RE: Proposed Cleanup Plan for Raymark Industries, Inc., Stratford, Connecticut
Dear Mr. Hill:
The staff of the Permitting, Enforcement and Remediation Division of the Connecticut
Department of Environmental Protection have reviewed the Proposed Cleanup Plan for Raymark
Industries, Inc. (the proposed plan). Following are comments related to the proposed plan.
In general, the State supports the remedial approach described as Alternative 2 in the
proposed plan. The proposed cleanup plan would decontaminate and demolish all buildings and
structures on the Raymark Facility, remove highly concentrated pockets of solvents (Non Aqueous
Phase Liquids, or NAPLs) from contact with groundwater, cover the entire facility with a multi-
layer impermeable cap (incorporating residential and Wooster School soil-waste and some building
debris under the cap) and ensure the long term integrity of the cap.
NON AQUEOUS PHASE LIQUID REMOVAL
Although the State supports the approach described as Alternative 2 in the proposed plan,
there is concern over the implementation of the NAPL removal as discussed in the Feasibility Study.
The Feasibility Study notes that NAPL recovery would be initiated by bailing the NAPL from
existing monitor wells. While we agree that NAPL removal is a necessary and appropriate element
of any remedy selected for this site, and that the approach described as Alternative 2 is consistent
with the Proposal for the Connecticut Clean-Up Standard Regulations, we do not consider the
specific measures
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Raymark Proposed Plan Comments
JuiieS, 1995
page 2
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Connecticut's Coastal Management Regulations (§§22a-90 through 22a-112, CGS inclusive)
were omitted from the ARARs tables in the Feasibility Study. Staff of the Office of Long Island
Sound Programs have reviewed the proposed plan and Feasibility Study and have indicated that the
proposed work is consistent with the substantive requirements of the regulations, but noted that the
regulations were not included in the table of Location Specific ARARs (see attached).
The following regulations should also have been identified as ARARs in the Feasibility Study. These
regulations are discussed in the attached letter from Ron Skomro to Arthur Clarke dated May 22,
1995.
Asbestos Abatement regulations (§§19a-332a-l through 19a-332a-16 Regulations of
Connecticut State Agencies)
Asbestos Licensing and Training regulations (§§19a-332a-17 through 19a-332a-23,
Regulations of Connecticut State Agencies)
Despite the above comments, I wish to again reiterate our support of the remedial approach
described as Alternative 2 in the Proposed Cleanup Plan for the Raymark Site. If you have any
questions regarding these comments please contact me at (203) 424-3764.
Sincerely,
Ronald H. Curran
Environmental Analyst
Permitting, Enforcement & Remediation Division
Bureau of Water Management
Department of Environmental Protection
RHC:rc
attachment
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STATE OF COVVFCTICI'T
MEMO
To: Ron Curran, DEP-Water Management Bureau
From: Margaret L Welch
Subject: Final Source Control Feasibility Study Report
Remedial Investigation/Feasibility Study
Raymark Industries, Inc. Facility
Stratford, CT
Date: May 23. 1995
Thank you for the opportunity to review and comment on the document noted above. As we
discussed, the project is subject to the federal coastal consistency review process set forth in
15 CFR 930 Subpart C. As such, a determination of project consistency with the standards and
policies set forth in the Connecticut Coastal Management Act must be made by the federal
agency responsible for the proposed activity. Because the project is intended to contain and
alleviate existing environmental hazards and it is a substantial distance from sensitive coastal
resources, particularly tidal wetlands, intenidal flats and beaches and dunes, we do not believe
there are substantive coastal management issues regarding the selection of any of the proposed
alternatives. Nonetheless, as a procedural matter, a consistency review must be conducted.
To assist the federal agency in conducting this review, I have provided a copy of the Connecticut
Coastal Management Act and a copy Of the Reference Guide to Coastal Policies and Definitions
for their use. I trust you will pass them, and these comments, along to the appropriate contact m
the U.S. Environmental Protection Agency. They may also be encouraged to contact me directly
at 203-424-3034 for more information or assistance in this process.
If you have any questions regarding this memo, or any other coastal management issues, please
do not hesitate to contact me at extension 2773.
( Primed on Recycled Piper)
"9 Elm Street Hartford. CT 06106 - 5127
An Eqvtl Opportunity Employ*'
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STATE OF CONNECTICUT
i
DEPARTMENT OF PLBL1C HEALTH AND ADDICTION SERVICED ';:
. fc
May 22, 1995 "" " "~''
MAT 2 6 1995
Arthur J. Clarke, J.D. .
Manager, Regulatory Affairs : # :: .!O" '<-£'-?*'2'.^..
Foster Wheeler Environmental Corporation , , - V-',' '..r"Jj:."
1290 Wall Street West "
P.O. Box 661 f,
Lyndhurst, New Jersey 07071-0661 I;
tj
RE: Comments Concerning May 9, 1995 Meeting Minutes. Raymark Demolition Superfund
Project, Stratford, CT
Dear Mr. Clarke:
I am in receipt of your May 17, 1995 correspondence containing minutes of our May 9.
1995 meeting concerning the Raymark Demolition Superfund Project located in Stratford, CT.
The following comments are provided concerning these meeting minutes.
1. The Connecticut Department of Public Health and Addiction Services (DPHAS)
Standards for Asbestos Abatement regulation (Section 19a-332a-l to Section 19a-332a-
16, inclusive of the regulations of Connecticut State Agencies) became effective in
August of 1988. The regulation has been enforced since that time. It was revised
effective December 27, 1990.
2. The DPHAS regulation concerning licensing and training requirements for persons
engaged in asbestos abatement and asbestos consultation services (Section 19a-332a-l 7
to Section 19a-332a-23, inclusive of the regulations of Connecticut State Agencies)
became effective February 9, 1989. This regulation was initially partially implemented
by the review and approval of training providers/courses required for asbestos abatement
workers, site supervisors and the four consulting disciplines. DPHAS established
November 1,1994 as the date to enforce the requirements for contractor and consultant
'licenses. To date, 148 contractors and 356 individual consulting licenses have been
issued. The number of consultant license application currently pending initial review is
four (4).
3. DPHAS training requirements mirror those of the initial EPA Model Accreditation Plan.
However, the requirements for initial worker and supervisor training are a 32 hour course
and a 40 hour course respectively. Additionally, DPHAS regulations detail requirements
for Project Monitors. -The Connecticut Legislature is currently considering a statutory
change to authorize DPHAS to adopt regulations consistent with the revised EPA Model
Accreditation Plan.
Phone: . TDD: 203-566-1279
150 Washington S'treet Hartford. CT 06106
An Equal Opportunity Employer
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Mr. Arthur J. Clarke. J.D.
May 22,1995
Page 2
4. The removal of roofing and siding material would be subject to the requirements of
Section 19a-332a-3.
5. The phone number for the Bridgeport OSHA office is (203) 579-5581.
6. Alternative work practice approvals allowing the demolition of facilities prior to the
removal of ACM have not typically been granted based upon serious space restrictions.
Serious space restrictions have served as justification for alternative work practice
approval such as that allowing no polyethylene sheeting on wall or floor surfaces.
7. The statement that CTDHS believes that there is no true reoccupancy in the case of the
Stratford demolition is inaccurate. The exact scope and sequence of work has not as yeti
been determined to provide a final determination.
8. DPHAS would require that a no visible residue criterion be achieved within the
established work areas.
9. DPHAS will make efforts to review any alternative work practice application as soon as
possible. A site visit can typically be conducted within five (5) working days of receipt
of such application with a final determination typically made within ten (10) working
days.
I hope that you will find these comments helpful in ensuring the accuracy of the meeting
'minutes. Please contact me should you have any further questions or comments.
Ronald Skomro
Supervising Environmental Sanitarian
Asbestos Program
Environmental Health Services Division
c: Mr. Ronald H. Curran, CT DEP
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May 24. 1995
Mr. Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. Environmental Protection Agency
Region 1
JFK Federal Building
Boston, MA 02203
Re: Raymark Industries Superfund Site,
Stratford, Connecticut
Deaf Mr. Hill:
I am writing on behalf of Brake Systems, Inc. ("BSI") to request a 90-day extension of
time (from June 8 to September 8) in order to provide written comments on EPA's-
proposed cleanup plan for the Raymark Industries Superfund Site (the "Site"). As you
know, BSI leased a portion of the Rayrnark property for a short period during the mid-
1980's and undertook extensive measures to comply with both EPA and DEP
environmental upgrading efforts while it operated and subsequently moved the
automotive brake production. Thus, BSI is interested in EPA's findings, conclusions, and
actions regarding the facility.
The additional time requested is necessary to provide BSI a reasonable and meaningful
opportunity to review and comment upon the plan and the voluminous technical materials
(including analytical data, site investigation reports, and risk assessments) which EPA
will rely upon to select its remedial actions. Much of this information has become
publicly available only recently. By way of example, the final remedial investigation
report and the final feasibility study were published in April 1995, and the Administrative
Record Index was compiled on April 5, 1995. BSI is still in process of obtaining copies
of key documents for its own use. Further, BSI anticipates that it will require the
.assistance of a consulting firm having expertise in multiple environmental disciplines in
order to evaluate the highly technical and complex matters addressed in those
BRAKE SYSTEMS i\'C.. 100 Double Beach Road. Branford. Connecticut 06405 203-481-5751
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documents.' This time is also necessary because of the length of time since BSI last had
access to its leased areas and because of the extensive operations which have been
conducted on the property since then.
BSI understands that the EPA is interested in proceeding expeditiously with work at the
Site; as such we intend to place a high priority on our review of this matter and are
optimistic that comments can be submitted by September 8. Completing this review
during this short extension of time will place a considerable strain on our resources given
the volume and complexity of the pertinent documentation. In this regard, we note that
the facility investigation report prepared by Environmental Laboratories, Inc., which
served as the basis for the remedial investigation report prepared by Halliburton NUS
Corp., took over five years to complete; therefore, an extension of the public comment
period to September 8 is reasonable in the context of the overall project schedule.
We appreciate your consideration of this request, and hope to receive a favorable
response. Please call me if you have any questions concerning this.
Very truly yours,
BRAKE SYSTEMS, INC.
r/
Randall J. Foster
Director of Safety and
Environmental Compliance
" From BSI's preliminary review of the materials placed at the Stratford Public
Library, it appears that some important documents are not yet on file there. These
include the laboratory data sheets for all samples collected as part of the work
performed by Environmental Laboratories, Inc. and Halliburton NUS Corp.
(including date on field blanks), and the quality assurance/quality control and data
validation reports prepared during the course of those firms' work. BSI would
appreciate receiving a copy of all such materials directly from EPA or, at the least,
receiving notification when they are available at the Stratford Library.
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2730 Main Street Stratford, CT 06497
June 7, 1995
Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, MA 02203
Dear Mr. Hill,
The SC AC would like to respond in writing, for the record, on the proposed cleanup plan for
Raymark Industries as outlined by EPA. As we stated at the public hearing on May 4, 1995, the
group is in favor of Alternative 2: Capping the site. We see this as the most viable and effective
option presented. While we realize comparisons were done between each alternative, we are also.
aware that the engineering details of how to implement the chosen plan and its' four principal
components, have not yet begun. When the engineering, health and safety plans are finalized by
EPA, we would like to request that ATSDR, DPHAS, Stratford Town Management, and SCAC
have the opportunity to review the plans prior to the start of the remediation. We would also like
to request the plans be available for public review and a public comment period before the
remediation proceeds.
The SCAC would like to reiterate the following points made at the public hearing on May 4, 1995,
and have them kept in mind when EPA develops the engineering, health and safety plans as they
relate to the four principal components outlined .by EPA:
Component #1 Decontaminate and demolish facility buildings and structures
A SCAC would like to review final plans:
To make sure all safety points are covered.
To see plans for communication with both residents of affected area(s) and the town in general
EPA to commit to specific dates and times for demolition and capping.
B. Public safety during demolition and remediation
Be aware of young children at shopping center and Wooster School exposed to ambient fallout
during demolition, removal of waste and capping process.
Older children curious about the site may try to get in and explore the area.
Measures to contain all debris (including airborne fugitive dust) during all phases ~ monitoring
will be necessary at the site and on the property perimeter.
Need for security guards
C. Notifying the public when demolition and capping will take place
Billet neighborhoods telling residents when demolition will take place.
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Post signs in and around the shopping center warning parents to keep young children away from
the area.
Post numerous items in the local papers indicating specific dates and times when work will be
done and indicate when conditions will be most critical
Notify PTA's at surrounding schools warning of the dangers at these particular remediation
sites to children.
Possibility of late night scheduling for demolition to minimize public exposure less traffic from
cars, trains, planes - fewer people in the shopping areas and roads?
Component #2 Remove the highly concentrated pockets of Liquid (solvent)
contamination from contact with groundwater
Since groundwater is of major concern - in regard to monitoring the groundwater on and off
the Raymark facility:
Who will do this testing and monitoring - who will be responsible for cost?
Since there are no plans to address the groundwater issue before the cap is put in placecan
groundwater problems be taken care of after the cap is in place?
The Housatonic and the Sound should be tested for contamination before, during, and after
remediation.
Component #3 Cover the entire facility with an impermeable cap
Test the clean ground fill being brought into the Raymark site. This is New England...any
soil could be contaminated. We don't need a cap that is more contaminated then what is
already there.
How frequently? e.g. every truckload, every 100 cubic yards?
Who will test?
What contaminants will the fill be tested for?
Sewer line running under Raymark property. Concerns re: Utility worker safety / access -
creation of a worker safety zone?
Component #4 Ensure the integrity of the cap
Policing the new ownersdetails need to be worked out:
Who will make sure they maintain the integrity of the cap?
What penalties will be implemented if they fail?
What are the deed restrictions to the Raymark property?
If the deed is broken who will be the responsible party?
Who would assume ownership of the property?
The SCAC would like to support viewpoints that were raised by other concerned parties at the
public hearing. In particular Elaine O'Keefe stated that one of her primary concerns of the
proposed cleanup plan is the tenuous nature of the groundwater contamination under the Raymark
facility and the extent of the contamination that has migrated beyond the perimeter of the Raymark
site. While removing the pockets of liquid solvents, will reduce the amount of contaminants that
could be available and mobile, it is only a partial remedy. Because the end receptor is the
-------
Housatomc River, we cannot know what the long-term impact will be once the contamination
plume meets the river, and what will occur in the next 15 to 20 years. Ms. O'Keefe also stated
that the uncertainties that surround the groundwater contamination poses public safety issues as
well. SCAC also feels it is imperative that some assurances be given to the Town that the
groundwater issue will be thoroughly addressed with expedience due to the fact we face a very real
possibility of diminishing Superfund monies and regressions in environmental regulations needed to
clean up the site.
Our group is also concerned with Ferry Creek and the position presented by Mr. Sammis of the
Waterfront Harbor Management Commission. A concern was expressed about Ferry Creek and the
downstream accumulation of sediments from Raymark since Raymark first started discharging. Mr.
Sammis also addressed the fact that everything below the high water mark happens to be state
controlled, state property, and felt the CTDEP should be highly concerned about the remediation
work which is being done upstream as well as on state property. The SCAC would like to request
that information on what activities would be undertaken to eliminate the contaminants found in the
Ferry Creek below the high water mark be sent to the Waterfront Harbor Management Commission
for their input. We support their suggestion to establish a number of strategic wells or test sites off
the property since the proposed remediation plan only calls for on-site testing. .
One final concern. The Raymark site is currently the recipient of the residential waste, as well as*
the possible recipient for some municipal waste (e.g.Wooster School) until the cap is in place. The
Proposed Cleanup Plan however, does not address how to deal with a discovery of Raymark waste
on residential property after the final cap at the Raymark site is implemented. The SCAC believes
an alternative plan must be develop as a contingency to the possible discovery of Raymark waste.
We feel there may be more waste that has gone undetected so far.
The SCAC still supports Alternative 2 of the Proposed Cleanup Plan as outlined by EPA. We feel if
engineered and executed properly, that it is the most intelligent and effective solution for this site
and for Stratford. Thank you for your consideration.
Sincerely,
The Stratford Citizen's Advisory Council
inet Carlucci
Co-Chair, SCAC
cc: The Honorable Rosa DeLauro
The Honorable Joseph Lieberman
The Honorable Christopher Dodd
Jacobi, Kappel & Case, PC., Legal Advisors to SCAC
Mark Barnhart, Town Manager, Town of Stratford
Elaine O'Keefe, Director of Health, Town of Stratford
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TOWN OF STRATFORD
Mark S. Barnhart 272S MAIN STREET 203-385-4001
Town Manager CONNECTICUT O6497 203 385-WOI
JuneS, 1995
CERTIFIED MAIL # P 241 423 989
Michael Hill (HSL-CAN5)
Remedial Project Manager
USEPA
JFK Federal Building
Boston, MA 02203-1911
re: Raymark Industries Site
Dear Mr. Hill:
On behalf of the Town of Stratford, I offer the following comments with regard to the proposed
remedial plan for the above-referenced site.
Groundwater
I understand the parameters and limitations of the proposed clean-up plan, and that issues related to
groundwater contamination will comprise a separate phase of your agency's on-going investigation
and remediation of this Site. I understand, too, that groundwater in this general area is not intended
to be a potable source either at present or in the future. Nevertheless, the likelihood that
contaminants are continuing to migrate from this Site via groundwater provides much cause for
concern within this community. In light of these well-founded concerns, I urge your agency to
thoroughly investigate and address this issue in the near term. It is especially troubling when one
considers that the true nature and extent of groundwater contamination beyond the perimeter of this
Site is largely unknown. While the evidence collected to date has been positive and generally
consistent with EPA's approachwitness the data collected from shellfish in the Housatonic River,
which exhibited no signs of Raymark-related contamination-it is far from a complete picture Only
the establishment of monitoring wells and the collection of data from points immediately beyond the
perimeter of the Raymark property can fill this data void.
At the same time, I welcome your agency's decision to extract and remove the highly concentrated
pockets of liquid solvents that can be found throughout virtually all of the Site. To the extent that
PCBs, in particular, dissolve more readily into groundwater in the presence of these solvents, this
"COUNCIL-MANAGER GOVERNMENT SINCE 1921"
-------
. 2 -
proposed action may alleviate concerns regarding the mobility and potential off-site migration of these
dangerous compounds. Moreover, the solvents themselves continue to be primary contributors to
groundwater contamination due to their mobility, and removing these so-called "hot pockets" will be
an important first step in addressing the larger groundwater issue. Nevertheless, I urge your agency
to commence its groundwater remedial phase as soon as possible.
Site Utilities;
Also of concern to the community is the presence of a 48" RCP sanitary trunk sewer which presently
traverses the Site. Relocation of this sewer line may not only be cost-prohibitive, but may not even
be feasible for a variety of other reasons. Alternatively, proposed slip-lining of this sewer may be
effective in ihe short-term, but may prove counter-productive in the long run, as eventually, I suspect
that the sewer line will require either replacement or abandonment. The latter option, abandonment,
is also not feasible at present. Slip-lining may alleviate some of our concerns regarding the present
condition of the trunk line, as well as forestall any decision regarding replacement. But, the
condition and integrity of the pipe's exterior is suspect, and may have been compromised already due
to its being situated in a highly acidic and corrosive environment. If so, slip-lining would not prote
effective. In any event, it seems likely that circumstances will eventually dictate that replacement is
necessary. In that eventuality, I am concerned for both the long-term integrity of the cap and for the
future health and safety of workers who will have the responsibility for performing this work. I am
recommending, therefore, that you give consideration to the creation of a worker safety zone around
this sanitary trunk sewer to provide workers with unencumbered access to the pipe.
Site Demolition:
I understand that no permits would be necessary should your agency proceed with site demolition or
construction work under CERCLA and in accordance with a Record of Decision issued for this Site.
I am also aware of your agency's obligations to substantively comply with the standards and
requirements contained in all applicable Federal or State laws. I would urge you to go a step further
by providing advance copies of your site demolition, cap engineering and health & safety plans to
appropriate State and local officials for substantive review and comment. Furthermore. I would
encourage you and your colleagues to continue to meet periodically with these officials to provide
status reports on work in progress and to respond to any questions or concerns that may arise. I
believe that all parties have found these meetings and the exchange of information to be productive
and mutually beneficial. To date, I have been pleased by the level of coordination and cooperation
displayed by your agency's representatives. I note that this perspective is shared by many others in
the community. We trust that this close working relationship will continue.
It is imperative that your, agency enact appropriate monitoring and containment measures before any
work commences. I have been informed that air sampling units will be established both on-site and
around the perimeter of the Site and that precautions will be taken to ensure that all debris, including
airborne fugitive dust, are adequately contained and will not pose a threat to abutting propertyowners
or passersby. I trust that your agency will also make arrangements'for on-site security during all
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-3-
phases of this operation. I believe that all of these measures are necessary to safeguard public health
and safety and to minimize to the extent possible the disruption to people's lives.
Public Communication;
Communication has been-and will continue to be-critical to the ultimate success of this project and
to the public's acceptance of your agency's proposed actions. I urge you to keep open the lines of
communication through on-going sponsorship of a community-wide newsletter; continued
participation in neighborhood forums; and periodic briefings with Federal, State and Local elected
officials and representatives of SCAC. I sincerely hope that you will also continue to hold regular
meetings with other State and local officials. As work gets underway, it will be necessary to post
notices and otherwise, inform residents as to schedules and work plans.
While we are anxious to see this project completed in a timely fashion, we are mindful that our
actions will have a lasting effect on our community. We are not prepared to sacrifice the health and
safety of future generations of Stratford residents for the sake of expediency or cost-effectiveness.
While we believe that the proposed clean-up plan, if properly engineered and executed, is a
responsible one and represents the most viable option presented to us, we have concerns nonetheless.
We have attempted to delineate those concerns above. We ask that you give these comments full
consideration, and continue to bear in mind your responsibility to effect a permanent and lasting
solution to the unique problems presented by this Site.
Thank you again for the opportunity to comment upon the proposed remedial plan.
lark S. Barnhart
cc: Town Council
E. OTCeefe, Director of Health & Welfare
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June 8, 1995
Richard Cavagnero
Raymark Team Leader
U.S. E.P.A.
Northeast Region .
J.F. Kennedy Federal Building
Boston, MA 02203-2211
Dear Mr. Gavagnero:
This letter supplements The Dock's June 7, 1995 comments regarding EPA's
Proposed Cleanup Plan for Raymark Industries, Inc., Stratford, Connecticut.
The Dock is concerned that EPA's Proposed Cleanup Plan could create potential
CERCLA liability for the Town of Stratford and for the owners of residential properties
from which contaminated soil was excavated and disposed of at the Raymark Superfund
Site. As discussed in section 10.00 of The Dock's comments, EPA has named only two
PRPs at this site, both of which are in bankruptcy proceedings. Thus, it is possible that
the Town of Stratford and the individual residential owners could be found to have
arranged for the disposal of hazardous wastes at the Raymark Superfund Site and be
held liable in future cost recovery actions.
We would like to have this issue resolved before the issuance of the ROD.
If you have any questions, please call my attorney, Mr. Thomas F. Harrison, at
203-275-0480.
Very truly yours,
J. Robert Osborne
The Dock Inc. 955 Ferry Boulevard P.O. Box 368 Stratford, CT 06497 (203) 377-2353
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TOWN OF STRATFORD
CONNECTICUT
06497
WATERFRONT AND
HARBOR MANAGEMENT COMMISSION
2725 MAIN STREET
STRATFORD. CT O64H7
Mr. Michael Hill, (HSL-CAN5)
Remedial Project Manager
U.S. EPA
JFK Federal Building
Boston, Ma. 02203
Re: Raybestos Remediation June 1, 1995
Dear Mr. Hill,
On behalf of the Waterfront and Harbor Mangement Commission, I
can assure yo.u of our disappointment that you or your office has
not had the courtesy to respond to what we believe was a
legitimate and reasonable request to address a part of the
"Raybestos" problem which is of particular concern to this local
agency.
Our letters of April 13 and May 5 have not elicited a written
response and if we are to effectively fulfil our mandate to
regulate and to assist in the orderly development of Stratford's
waterfront, we need and expect other governmental agencies to
provide a modicum of assistance and minimum of curteous dialogue.
We continue to see EPA sponsored remedial action at Housatonic
Avenue Extension and at the terminus of Stratford Avenue near
Bond's Dock. Although we can only speculate as to the cost of
these actions, we can feel comfortable that these costs run into
the many hundreds of thousands of dollars. We have simply asked
that a modest amount of the funds available be diverted to the
testing of the waters of Ferry Creek to determine what, if any,
toxins are present and in what dimension. Further that if toxins
are present, what action will be taken to remediate this area.
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-2-
If Ferry Creek was not the downstream path of
ground water from the Raybestos site/ we would
less concerned. Further, land on either side
instrumental to the long range development
waterfront and the renaissace of the Shakespeare
the postponement of remediation (if necessary)
affect considerably more than just water quality.
the surface and
be considerably
of the Creek is
of Stratford's
Theater so that
will adversely
We are also disappointed that the State of Connecticut whose
property we are discussing (below the hihg water mark) irs
strangely silent on this topic. We would have assumed that they
would be in the forefront for adequate testing and appropriate
follow through.
A timely
earliest.
and detailed response is once again requested at the
Sine
Robert H. Sammis, Chairman
cc: Congresswomah Rosa DeLauro
Commissioner Sidney J. Holbrook, ConnDEP
Senator George Gunther
Representative Terry Backer
Representative Vincent Chase
Representative Lawrence Miller
Town Manager Mark Barnhart
Commissioners
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DATE:
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2034816485
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By Facsimile and
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June 8, 1995
Michael Hill (HSL-CAN5)
Remedial Project Manager
U.S. Environmental Protection Agency
Region l .
:r'K Federal Building
.Ton, MA 02203
Re: Raymark Industries, Inc. Superfund Site,
Stratford, Connecticut
Dear Mr. Hill:
I am responding on behalf of Brake Systems, Inc. ("BSI"), 'to
the U.S. Environmental Protection Agency's request for public
comments on the proposed cleanup plan for the Raymark Industries,
Inc. Superfund Site at Stratford, Connecticut. Due to the
relatively short period of time available to BSI to review the
voluminous technical materials included in the Administrative
Record, the following comments are necessarily preliminary in
nature and are directed to the documentation supporting the
proposed cleanup plan. BSI anticipates submitting a more
detailed evaluation within the timeframe suggested by my letter
to EPA of May 23, 1995.
First, to clarify a matter of corporate identity, EPA should
note that BSI and not Echlin Inc. is the company that leased a
portion of the Raymark property in the mid-1980s. In the past
some correspondence from EPA has been directed to Echlin Inc.
which never owned or leased any portion of the Raymark property
.": which never .conducted any operations there. Insofar as EPA
. any questions concerning BSi's activities, inquiries should
Directed to BSI itself and, specifically, to my attention.
Second, BSI is concerned that confusion has arisen regarding
v.ne limited operations it conducted on the leased property. By
way of background, it should be noted that BSI first leased
manufacturing space at the Raymark property in :198'5 for the
purposes of automotive brake production. Within three years,
this manufacturing activity ceased and BSI vacated the premises.
During its brief tenure at the site, BSI operated in compliance
with state and federal environmental standards, including those
BRAKE SVITEMS. INC.. 100 Double Beach Road, Branforjd. Connecticut 06405 203-481-5751
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JUN 8 '95 17:42 FROM ECHLIN HQ 35 TO PftGE.003
applicable to the handling, storage and disposition of materials
and wastes.1' Unfortunately, BSI did experience a spill, quite
possibly due to vandalism in late 1987. The details of this
spill incident are not reported accurately in either the Remedial
investigation ("RI") or Feasibility Study ("PS") completed (dated
;pril 1995 prepared for the Rayinark site) by EPA's contractor.2'
BSI used an above-ground storage tank containing 111
-?hloroethane ("TCA") located in the area of Building 44. In
-rnber 1937, during the period after BSI had announced the '
! -5sure, of its operations and, prior to the planned tank removal
^sociated with the shutdown, a tank transfer line was severed,
possibly as an act of vandalism. From manifested delivery
records, BSI determined that about 600 gallons of TCA were
released. At the time of the spill, the ground was frozen and
the TCA flowed over land in an easterly direction to local storm
basins and drainage lines. BSI responded to this incident by
reporting it to the Connecticut Department of Environmental
Protection and by calling a spill response contractor to the
scene. BSI conducted a recovery of the TCA from storm basins and
drainage lines and removed several drums of contaminated aoil in
the immediate vicinity of the above-ground tank. Clean up
records establish that over 1,000 gallons of a TCA and water
mixture (approximately 50/50 solvent/water mixture) was removed
from the storm drain system. Therefore, most if not all of the
material appears to have been captured from the storm drains
y.ere it was pumped out and disposed of by a licensed waste
disposal company.
It should be noted that BSI had no involvement with the
shipping of waste manufacturing materials or sludge offsite
to local properties including residential and commercial
locations in Stratford,. These practices had been
discontinued long prior to 1985.
27 References to the incident in the RI and PS reports
incorrectly state that 6,000 gallons rather than 600 gallons
were spilled, and sometimes misstate the year as 1984 rather
than 1987. See, e.g., RI at ES-4, 4-5, 4-36 and 4-45; FS at
ES-2 and 1-7.
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20348164tto
35 17:43 FROM ECHLIN HQ 35 TO PAGE.004
The RI and FS state that groundwater samples taken
downgradient of the 1987 TCA spill show the presence of this
substance in groundwater. It is unlikely, however, that the
source of this TCA is the 1987 BSI spill. As noted above, the
frozen ground conditions at the site were such that the TCA was
not absorbed into soils but flowed into the storm drain system.
The more likely sources of any TCA contamination in groundwater
is the historical operational'practices of Raymark noted below
which occurred, at least in part, at Building 44 and adjacent
areas.
Third/ from our initial review of the RI and FS reports, it
appears that EPA has not gathered a detailed knowledge of the
manufacturing activities that took place at the property during
the seven decades prior to 1985 that Raymark conducted its
business there. For example, BSI believes that Raymark engaged
in large scale degreasing operations for several decades in order
.-. clean transmission plates and other metal parts. These
iterations were discontinued prior to 1985. Some of these
. ,;r.easing operations took place in or adjacent to Building 44,
-' '.nn undoubtedly accounts for the detection of solvents in the
.:! and groundwater in that vicinity. A more comprehensive
understanding of Raymark's practices (particularly in the decades
before stringent environmental regulations were in effect to
govern waste storage and disposal) should help to focus EPA's
future remedial actions by pinpointing potential sources of
contamination.3/
Finally, BSI has just been advised that its request for
additional time to comment upon the proposed plan has been denied
by EPA. BSI disagrees with EPA's rationale for this decision,
since a short public comment period cannot be adequate or
meaningful where the complexities of the site are such that it
took over four years just to complete the RI and FS,
Nevertheless, the company appreciates EPA's willingness to make
available the technical documentation in EPA's possession that is
necessary for BSI to undertake its review of this matter. With
respect to the technical documents that are being held by
contractors or other governmental agencies, we are hopeful that
EPA will obtain this material shortly and will then notify BSI of
its availability for inspection and copying.
In a very preliminary fashion, the RI identifies the
presence of a solvent recovery plant with extensive daily
waste water discharges generally into the acid
neutralization pit and lagoon network. See, e.g., RI at 2
2.
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95 17:43
2034816485
FROM ECHLIN HQ 3S
TO
PftGE.005
BSI's submittal of this letter is not a waiver of any rights
it may have to provide additional detailed comments on the record
or cleanup proposal once a thorough review has been completed.
Very truly yours,
for BRAKE SYST
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Pledge for a safe and sound Raymark cleanup
(Resident)
As a resident of Stratford, T favor the following re-
garding the cleanup of the Raymark Superfund
site:
1) I am pro health and safety. I favor removal of
dangerous PCBs and other toxins from the site. I
also favor safe demolition of the buildings, and re-
view of demolition plans in advance by our town
and state health officials. Right now, there are no
plans. .
2) I am pro environment I favor removal of the
dangerous chemicals that could ruin the Housaton-
ic River/ Ferry Creek and Long Island Sound.
3} I am pro taxpayer. Unless an iron-dad hold
harmless agreement is produced by the EPA, r op-
pose transporting toxic waste from town-owned
sites, such as Wooster School, to the Raymark site
for burying, as currently proposed. Based on past
similar cases, this could link the town as a third
party to the Raymark site and make it liable for
damages. The town should not take such a risk un-
less it has absolutely no risk or exposure for tax-
payers.
4) I am pro economic development I favor re-
moval of PCBs and other toxins before they destroy
the town's opportunity to develop its waterfront by
polluting the river. I also do not want to see devel-
opers shy away from Stratford in the future for fear
that their property could need expensive environ-
mental cleanup as the result of dangerous toxins
left in the ground from Raymark that could leach
onto their property.
5) I am pro common sense. I favor cleaning up the
site now, not in 30 years. The EPA wants to place a
temporary cap and make this our children's prob-
lem. I want to fix this now. while Suoerfund monev
is available, and while it is possible The EPA is
willing to allow development over a temporary
cap, reasoning that the site could be dug up later. I
favor simple logic that says no one wants to knock ,
down a new shopping center to dig, up and remove..
PCBs. Let's address the problem before the site is -
developed, - t * =;-- * ?»* #*-. * * -.-- -.*-
* -.' .-,> * * -3 *-.*. ».-/'. . \ .-v?^'
6) I am pro Stratford. I have a vested interest in '<-.-
the health and well being of the area. Fm tired of
seeing Stratford get the short end of the stick. The -,
EPA is trying to take the cheap way out instead of
fixing the problem correctly. I favor fixing the prob-
lem and giving Stratford the first-class treatment it
deserves. '..-' ,
7) I am pro development of the Raymark-proper- ,
ty, and lam in favor of removing this eyesore as .- .,'
quickly as possible I favor cleaning, the property
and having it developed properly in accordance
with our local planning and zoning and permit .
process. However, (favor a correct cleanup that is
not done in haste at the expense of the town's fu-
ture, either in terms of the best interests of Strat-
ford's economic or environmental well being.
JSigned,'
Note Public comment period ends June 8. Send com-
ments and/or Pledge to Michael H31'Remedial Project
Manager, US EPA, JFK Federal Building, Boston,
Mass. 02203-1911. - »* --*-«.-- >. -. .-
L
0^ o r«.
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APPENDIX B
STATE OP CONNECTICUT
CONCURRENCE LETTER
47
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'203 424 4057
JUN-29-1995 09:40
PERD
203 424 4057 P.02
STATE OF CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
June 29, 1995
John P. DeVfflara
Regional Administrator
U.S. EPA Region I
J.F.K. Federal Building
Boston, MA 02203
Dear Mr. DeVillars:
The Connecticut Department of Environmental Protection (CT DEP) concurs with the remedial
,.
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