XV EPA
Cleanup Enforcement in Action
Addressing Community Needs in
North Haven, Connecticut
The Value of Environmental Enforcement
At the Pharmacia & Upjohn Company LLC facility in North
Haven, Connecticut, the U.S. Environmental Protection
Agency's (EPA's) enforcement mechanisms and resources
have played a vital role in achieving protection of public
health, environmental restoration, and property reuse.
This case illustrates how EPA, Pfizer, and the community
achieved positive results through the use of a collaborative
enforcement process and the use of appropriate enforcement
tools. At this facility, the parties decided together that an
enforcement order on consent would be the most effective
way to manage the final cleanup. Today, this agreement is
creating long-term benefits for the North Haven community.
The successful use of enforcement tools at this facility
led to one of the largest cleanups in the history of EPA's
Resource Conservation and Recovery Act (RCRA) program.
Total cleanup costs for this large and complex facility are
estimated at more than $152 million. Through a series of
RCRA enforcement orders, EPA, Pfizer, and the Connecticut
Department of Energy & Environmental Protection (CT
DEEP) facilitated the cleanup of the 78-acre former
manufacturing facility. The most recent enforcement order
(2011) contains a master plan with deadlines that are
enforceable yet adaptable.
Incorporating ASTM's Standard Guide for Greener Cleanups
into the remedy helped Pfizer reduce the cleanup's
Environmental Enforcement
Benefits the Community
Environmental and public health impacts affect
people most significantly where they live. EPA works
to provide strong, effective enforcement support
to all communities. As the Agency implements
environmental and public health improvements
across the country, EPA is looking for new ways to
assist communities in environmentally overburdened,
underserved, and economically distressed areas
where the needs are greatest.
"[Pfizer and EPA have] done a remarkable job in the first phases of
deanup. Down the road ... we'll see not only a wonderful environmental
aspect, but a catalyst for future commercial development."
- North Haven First Selectman Michael Freda
Working Together to Achieve
Site Cleanup and Reuse
EPA, Pfizer, and CT DEEP worked together to
determine that an enforceable order was the best
mechanism to use at this facility, The resulting
order allows Pfizer to develop and modify, with EPA
approval, ambitious deadlinesthat keep thecleanup
ahead of schedule. Additionally, Pfizer focused
on community relationships and incorporated
community priorities into the final cleanup plan
which includes 17 acres of new light industrial and
commercial business space and roughly 60 acres
of restored wetlands and meadows that will include
nature trails available for public use.

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The site's location in North Haven, Connecticut.
Administrative Cleanup Orders
Legal agreements signed by EPA and an individual,
business, or other entity through which the property
owner or operator agrees to take the required
corrective or cleanup actions. They describe the
actions to be taken, apply to civil actions, and can
be enforced in court.
Miles
NORTH
Sources: Esri, DeLorme, AND, Tele Atlas, First American, UNEP-
WCMC and USGS.
and photo-initiators. The facility became contaminated
through historical releases of hazardous manufacturing
process wastes and wastewater treatment residuals. All
manufacturing ceased at the facility in 1993.
In 2003, pharmaceutical company Pfizer purchased
Pharmacia Corporation, the parent company of the
Pharmacia & Upjohn Company. Although Pharmacia &
Upjohn Company is the named party on the most recent
enforcement order, Pfizer is managing the cleanup and
working with EPA, CT DEEP, and the community on
facility-wide cleanup and reuse planning.
environmental footprint and ASTM's Standard Guide
for Integrating Sustainable Objectives into Cleanup
enabled the incorporation of economic and social best
management practices (BMPs). These practices helped
ensure the project's compatibility with community needs
and priorities.
Following cleanup, the once-contaminated facility will be
returned to productive and beneficial use. Seventeen acres
of the property's west side are planned for commercial and
light industrial use. An additional sixty acres of wetlands
and meadow habitat along the Quinnipiac River are being
restored and include walking trails and signage providing
for recreation and environmental education opportunities.
Facility and Community Overview
North Haven isasmall town in south-central Connecticut, a
few miles from New Haven. About 25,000 people live in the
community. For much of the 20th century, the Pharmacia
& Upjohn Company chemical manufacturing facility
was a major local employer. The facility made products
used in dyes and pigments; photographic chemicals;
sunscreen agents; additives for soaps, perfumes, and
cosmetics; agricultural herbicides; pharmaceuticals;
Project History
1989 - 2002
Initiating RCRA Corrective Action Cleanup
In 1989, EPA issued a RCRA administrative order
requiring facility investigations and cleanup. One facility
investigation identified 28 areas of environmental concern.
Pharmacia & Upjohn Company, the owner of the facility at
the time, began to implement a series of corrective action
interim measures.
Corrective action interim measures identify and correct any
actual or potential releases of hazardous waste or hazardous
constituents from regulated areas, sources, or areas at
facilities that may present an endangerment to human
health or the environment. Interim measures are often used
to achieve the initial goals of controlling the migration of
contaminated groundwater and controlling current human
and ecological exposure to contaminated media.
A second RCRA administrative order required Pharmacia
& Upjohn Company to continue interim measures already
in place, conduct human health and ecological risk
assessments, and prepare a corrective measures study
vvE
a
U.S. Environmental Protection Agency
Office of Site Remediation Enforcement

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RCRA Overview
Congress enacted RCRA in 1976. RCRA, an
amendment to the Solid Waste Disposal Act, was
designed to address the huge volumes of municipal
and industrial waste generated by operating
facilities. This includes hazardous waste generated
and disposed of by owners and operators who
contaminate land, water, and air. Under RCRA,
owners and operators are liable for the cleanup of
the contamination. RCRA protects human health
and the environment in two ways:
L Prevention: preventing future environmental
problems from being caused by waste.
2. Corrective Action: Cleaning up current
environmental problems caused by the
mismanagement of waste,
RCRA Corrective Action usually takes place at
facilities that treat, store, or dispose of hazardous
waste. Corrective action can also take place while a
facility continues operation and it may be required
through a RCRA permit, voluntary agreement, order,
or administrative or judicial action.
One of the walking trails on the Pfizer property.
(CMS), A CMS is used to develop and evaluate corrective
action alternatives and recommend the corrective
measures that the owner or operator should take at a
facility to protect human health and the environment.
As a result, all manufacturing buildings at the facility
were demolished, decontaminated, or disposed of. Other
interim measures included the installation of a state-of-
the-art groundwater recovery and treatment system, soil
and sludge capping, and facility security.
2003 - 2008
Rebuilding Relationships
In 2003, Pfizer took over financial responsibility for ongoing
facility-wide investigations and cleanup when it acquired
the Pharmacia Corporation. Pfizer also recognized the need
to rebuild community relationships and began an inclusive
stakeholder engagement process. For its part, EPA was also
committed to involving the public in the development and
implementation of cleanup decisions. One of the Agency's
central goals is to empower community involvement in
local activities by providing equal access to information
and an equal opportunity to participate.
With EPA's guidance, Pfizer developed a community
relations plan as a guide for sharing information and
obtaining public input during the corrective measures
implementation phase of the project. The outreach tools
outlined in the plan ensured a transparent and accessible
process and meaningful community stakeholder
participation.
To build the community's trust, Pfizer also worked closely
with the North Haven Citizens' Advisory Panel (CAP). CAP
representation includes the Quinnipiac River Watershed
Association (QRWA), the North Haven Land Trust, the
Regional Growth Partnership, the North Haven Trail
Association, and local town boards and commissions.
CAP was established as a conduit to the community for
information regarding the environmental investigation and
cleanup of the Upjohn property. Input and feedback from
CAP helped shape EPA's approved remedy and inform the
future vision for the property.
Through regular CAP meetings and facility visits with
community members, Pfizer established key objectives for
the future use of the property. The company's stakeholder-
driven reuse planning process included presentations
and discussions with hundreds of stakeholders, market
analyses, feasibility planning, and stakeholder interviews.
Through this effort, Pfizer learned that economic
development and the creation of an ecological preserve
with green space were local priorities and integrated them
into the cleanup plan.
For example, Pfizer worked closely with local
environmental resources - QRWA, the North Haven Land
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A
Use of ASTM's Standard Guide for Greener Cleanups
EPA worked with ASTM to develop the Standard Guide for Greener Cleanups, the consensus-based standard intended
to encourage property owners, regulatory agencies, responsible parties, developers, and communities to voluntarily
use greener practices for contaminated site cleanup. As a starting point for the standard development process, EPA
and state agencies developed a framework outlining the desired outcomes of a potential standard for greener cleanups.
ASTM issued the Standard Guide for Greener Cleanups in 2013 and updated it in 2016. The standard guide is
intended to complement regulatory and voluntary cleanup programs and accommodate each phase of a cleanup. It
includes:
•	A systematic protocol to identify, prioritize, select, implement and report on the use of BMPs to reduce the
environmental footprint of cleanup activities.
•	A list outlining 115 greener cleanup BMPs that are linked to the core elements of greener cleanups and to
relevant cleanup technologies.
•	Guidelines to quantify the environmental footprint of cleanup activities.
•	A reporting structure to promote public availability of information relating to the decision-making process and
communication of outcomes.
EPA anticipates that use of this private-sector standard guide wiii advance EPA's objectives by:
•	Providing clear definitions, methods, expectations, and goals that can be used by all stakeholders involved in a
cleanup, making it easier for regulators and the regulated community to implement greener cleanups.
•	Establishing a framework to support new tools for evaluating impacts from cleanups.
•	Building on state and local government incentives for greener cleanups.
To learn more, visit https: //www, e pa. go v/ar ee n ere lea n u ps.
Reuse plans designated a 60-acre ecological preserve on the
eastern side of the property (green areas above) and 17 acres
along its western side for commercial and industrial use (blue
and grey areas).
Final Corrective Action Components
•	Upgraded groundwater pump-and-treatment
system.
•	Perimeter groundwater hydraulic barrier wali.
•	Excavation and on-site consolidation of
impacted soils.
•	Sediment dredging.
•	Low-permeability and protective soil barrier
cover systems.
•	In-situ thermal remediation (ISTR) for dense
non-aqueous phase liquid (DNAPL) removal.
•	Ecological restoration,
•	Land preparation for future commercial/light
industrial redevelopment.
vvEPA
U.S. Environmental Protection Agency
Office of Site Remediation Enforcement

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Trust, Yale University, and the University of New Haven
-	as well as expert consultants in ecological restoration
and interpretive planning to develop detailed designs for a
well-functioning ecological preserve. The efforts resulted
in reuse plans for the property that designated a 60-acre
ecological preserve on the eastern side and 17 acres along
the western side for commercial and industrial use.
2009-2011
Final Cleanup Planning, Enforcement Excellence
By 2009, the facility had reached a critical milestone
-	it was time to select and implement the final cleanup
plan. EPA, CT DEEP, and Pfizer discussed whether a state
RCRA permit or an enforceable federal order would be the
best mechanism. After years of experience working with
both permits and orders, the agencies and Pfizer decided
that an enforceable order with EPA oversight was the best
option for the active cleanup phase.
An enforceable order offered several advantages. For
example, EPA could structure it to include a master plan
that increases flexibility and efficiency during cleanup
and supports Pfizer's use of ASTM's Standard Guide
for Greener Cleanups. It lists all key deadlines and any
proposed deadline changes, and shows a timeline for
the entire project. EPA retains authority to reject any
changes to the timeline; Pfizer submits a master plan
every quarter. Once the cleanup goals are achieved and
the site transitions to operation and maintenance, EPA
will transfer site care to Pfizer management under a state
stewardship permit.
in addition, the master plan allows Pfizer to develop
ambitious deadlines. In typical consent orders, EPA and
the responsible party must agree upon a compliance
schedule. Parties are often more likely to agree to
conservative deadlines to make sure remedial timelines
stay on track. The master plan allows Pfizer to modify
deadlines as needed, with EPA approval, and propose
deadlines to keep the cleanup on track to reach RCRA
Corrective Action program goals. Master plans also allow
facilities to respond in real time to redevelopment interest
by quickly shifting deadlines to prioritize cleanup of the
portion of the facility in which a redeveloper may be
interested - all while maintaining enforceable deadlines
for cleanup of the entire facility.
2012-2018
Innovating for the Future
Throughout its work, Pfizer prioritized environmental
sustainability. To inform its efforts, Pfizer followed
ASTM's Standard Guide for Greener Cleanups. This
voluntary, consensus-based guide provides a step-wise
process to assess, prioritize, select, and implement
BMPs that can help reduce the environmental footprint
associated with cleaning up contaminated sites. The
selected corrective action objectives maximize a range of
benefits - greater chemical mass removal, less impact on
Recognizing Community Leadership
In 2011, founding members of the North Haven CAP
were honored with EPA's Environmental Merit Award
in recognition of their long-term commitment and
outstanding efforts.
The Town of North Haven also honored CAP with
a proclamation recognizing members'1 service and
dedication.
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Principles for Greener Cleanups
A greener cleanup is a sustainable approach to cleaning up contaminated sites. EPA's "Principles for Greener
Cleanups" provides a foundation for planning and implementing cleanups that protect human health and the
environment while minimizing the environmental footprint of cleanup activities.
To learn more, visit: https://www.epa.gov/greenercleanups
Green Remediation
Green remediation - another term for greener cleanups - is the practice of considering all environmental effects of
remedy implementation and incorporating options - such as the use of renewable energy resources - to maximize
the environmental benefits of cleanups. EPA has a host of additional resources available at:
. EPA Green Remediation Report: https://www.epa.gov/remedvtech/green-remediation-incorporating-
sustainable-environmental-practices-remediation
• Contaminated Site Cleanup Information (CLU-IN) — Green Remediation Focus: https://clu-in.org/greenremediation
Above: Reuse of facility soil for grading significantly reduced
the volume of imported fill material.
Below: View of the facility's vegetated cover
the community, greater beneficial reuse, a lower carbon
footprint, reduced long-term groundwater pumping-and
are backed by strong public support.
The facility's remedy also conserves energy and resources.,
For example, Pfizer's contractors used repurposed slag
from a furnace blast to build a barrier wall to protect
the Quinnipiac River from groundwater contamination,
instead of excavating a 1-acre area and disposing of
contaminated soil off site, Pfizer used a thermal heating
process to remove the primary source of groundwater
contamination. This option reduced greenhouse emissions
and kept trucks filled with hazardous waste headed to
disposal sites off the community's streets. Additionally,
a 6-acre wetland constructed on site provides long-term
stormwater management without the need for active
pumping or treatment, while also providing critical habitat
for freshwater plant and animal species. The project also
used solar-powered air monitors, lowering energy costs.
A recent review of the corrective action activities found that
Pfizer successfully incorporated 87 greener cleanup BMPs
from ASTM's Standard Guide for Greener Cleanups as well
as nine social BMPs and eight economic BMPs (see ASTM's
Standard Guide for Integrating Sustainable Objectives into
Cleanup). These practices helped ensure the project's
compatibility with community needs and priorities. Today,
cleanup remains on track for completion in 2018. In the
meantime, property reuse is already underway. Community
vvEPA
U.S. Environmental Protection Agency
Office of Site Remediation Enforcement

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Local Economic Benefits of Cleanup
The cleanup has prioritized the use of local sources
of labor and materials. Over 30 percent of the
project's labor, services, and materials come from
within 25 miles of the facility - and over 40 percent
of labor, services, and materials come from within
Connecticut.
organizations and school and church groups can schedule
visits to the property's growing ecological preserve to enjoy
the green space and interpretive trail network. Full public
access is anticipated when the ecological preserve is well-
established. Commercial and light industrial development
will start after the final facility remedy is in place.
Enforcement Makes a Difference
EPA's enforcement program has helped make a difference
in thousands of communities impacted by hazardous waste
contamination. At faciIitiessuch asthe Pharmacia & Upjohn
Company LLC facility, the enforcement program, working in
conjunction with EPA Corrective Action program technical
staff, has played a centra! role in facilitating cleanup and
reuse by negotiating innovative settlement agreements and
emphasizing the importance of community engagement.
EPA's enforcement tools and greener cleanup resources
protected public health and provided for environmental
restoration, reuse, and greener cleanup at the facility.
Additionally, early and continued community involvement
and transparency ensured efficiency in developing a cleanup
plan. From there, EPA enforcement staff's decision to
integrate a master plan into the order provided the flexibility
necessary to set and meet ambitious deadlines, keep
the cleanup on track, and provide long-term community
benefits. Looking forward, EPA will continue to work with
community members, CAP, local governments, CT DEEP,
and Pfizer to keep the public informed and ensure the
cleanup's long-term protectiveness.
Additional Resources
ASTM's Standard Guide for Greener Cleanups (AS IM
E2893):
ASTM's Standard Guide for Integrating Sustainable
Objectives into Cleanup (ASTM 2876-13):
For More Information, Contact:
Katie Hatt
hatt.catherine@epa.gov I (202) 564-6331
Community members touring the site's ecological restoration
area in 2016.
The beneficial reuse of materials during remedy construction
has kept 2,465 tons of material out of local landfills.

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