EXPLANATION OF SIGNIFICANT DIFFERENCES
I5 3
%
Raymark Industries, Inc. Superfund Site
Operable Units 4 and 6
September 2023
I. INTRODUCTION
A. Site Name and Location
Site Name: Raymark Industries, Inc. Superfund Site
EPA ID: CTD00118661
Site Location: Stratford, Connecticut
B. Lead and Support Agencies
Lead Agency: U.S. Environmental Protection Agency (EPA)
Support Agency: Connecticut Department of Energy and Environmental Protection (CTDEEP)
C. Legal Authority for the Explanation of Significant Differences
Under Section 117(c) of the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA),1 Section 300.435(c) of the National Contingency Plan (NCP),2 and
U.S. Environmental Protection Agency (EPA) guidance,3 if EPA determines that differences in
a remedial action significantly change but do not fundamentally alter the remedy selected in a
Record of Decision (ROD) for a site with regard to scope, performance, or cost, EPA shall
publish an explanation of the significant differences between the remedial action being
undertaken and the remedial action set forth in the ROD as well as the reasons such changes are
being made. Minor changes do not require formal documentation.
This document sets forth the basis for this Explanation of Significant Differences
(ESD) for the Raymark Industries, Inc. Superfund Site ("Site"), located in Stratford,
Connecticut. This ESD describes three significant changes to the remedy for Operable Units
(OUs) 4 and 6 as prescribed in two separate RODs issued in July 2011 and September 2016.
Significant Changes:
(1) Coastal Flood Storage,
(2) Stormwater Management, and
(3) Change in Excavation Depth at an OU6 property.
A discussion of each significant change is provided in Section III.
1 42 U.S.C. Section 9617(c).
2 40 C.F.R. Section 300.435(c).
3 Office of Solid Waste and Emergency Response (OSWER) Directive 9200.1-23P.
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D. Summary of this Explanation of Significant Differences
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E. Public Coninicnt Period
The community was notified about the proposed ESD and comment period though the
attached flyer distributed electronically and through the mail, and press release posted in the
classified section of the CT Post newspaper on August 9, 2023. This information was also
posted on EPA's web page for the Site at the link included in the table below and linked to the
Town of Stratford's web page for the Raymark Site. An informational public meeting on the
proposed ESD was held at EPA's Stratford office and through an on-line link on August 15,
2023. While not required, EPA did solicit public comment from CTDEEP, Town of Stratford
officials and the public though a formal public comment period which was held August 16 to
30, 2023. No formal comments were received, and, therefore, no responsiveness summary was
prepared.
F. Public Record
This final ESD and its supporting documentation are part of the Administrative Record for this
ESD. The supporting documentation for this ESD and the complete Administrative Record, as
set forth in the NCP 300.825(a)(2), are available to the public online at the link in the table
below and resources are also available at the Stratford Public Library. The Administrative
Record is also located at EPA New England Records Center, which is open by appointment as
described below.
Location
Days & Hours
US Environmental Protection Agency
Region I Records Center
John W. McCortnack Building
Five Post Office Square Boston,
MA 02109
(617)918-1440
The Reading Room is open to the public by
appointment only, Monday through Friday from
9:00am to 5:00 pm. The phone number to schedule
an appointment is (617) 918-1440.
Stratford Public Library
2203 Main Street
Stratford, Connecticut
(203) 385-4161
Open Tuesday, Wednesday, Thursday from 10:00am
to 8:00pm; Friday, Saturday from 10:00am to
5:00pm. Closed Sundays and Mondays.
The Administrative Record is on-line at: www.eDa.sov/suDerfund/ravmark
Click on "Site Documents & Data " on the left-side of the screen.
II. SUMMARY OF SITE SETTING, HISTORY, CONTAMINATION, RISK, AND
THE SELECTED REMEDY
A. Site Setting
The Raymark Industries Site consists of over 500 non-contiguous acres in the Town of Stratford,
Fairfield County, Connecticut, contaminated as a result of manufacturing processes from the
former Raymark Industries, Inc. facility at 75 East Main Street in Stratford. Figure 1 shows the
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location of the Site divided into the following nine operable units (OUs):
OU1 is the former manufacturing facility property which has been capped and
redeveloped into a 34-acre shopping center.
OU2 is the area impacted by contaminated groundwater emanating from the former facility
and includes 125 vapor mitigation systems.
OU3 includes Upper Ferry Creek and associated wetlands.
OU4 is the former Raybestos Memorial Ball Field which was used as a disposal area for
Raymark wastes. The ball field was built over the waste area and was abandoned in the
1980s. OU4 is the consolidation area for Raymark Waste excavated from OU3 and OU6
properties.
OU5 is a former tidal wetland that was filled with Raymark Waste and includes the
Housatonic Boat Club and a portion of Shore Road.
OU6 consists of over 157 non-contiguous acres and is comprised of about 30 individual
properties, all of which contained buried Raymark waste. The cleanup of the OU6
properties is ongoing.
OU7 includes wetlands at Lower Ferry Creek, Selby Pond, and the Housatonic River.
OUS includes wetlands at Beacon Point and Elm Street.
OU9 is approximately 94 acres in size consisting of a municipal landfill and portions of an
abutting recreational area.
B. Summary of Site History
Raymark Industries, Inc. ("Raymark"), formerly known as the Raybestos-Manhattan Company
located at 75 East Main Street, manufactured friction materials primarily for the automotive
industry containing asbestos and non-asbestos components, metals, phenol-formaldehyde
resins, and various adhesives. Raymark and its predecessors operated at this location from
1919 until 1989.
Water and wastes from Raymark"s manufacturing operations were collected and diverted into
the facility's drainage system, mixed with lagoon wastewaters, then discharged to groundwater
and a nearby surface water body known as Ferry Creek, resulting in extensive volatile organic
compound (VOC) contamination. Dredged lagoon sludge and other manufacturing waste were
also disposed as free "fill." Raymark"s waste consisted of polychlorinated biphenyls (PCBs),
asbestos, lead, and copper, and about a dozen other constituents known to be toxic. The waste
was disposed not only at the facility, but also at residential, commercial, recreational, state and
municipal properties in the Town of Stratford, and was used to fill low areas and wetlands.
In the early 1990s, EPA tested over 500 properties and in 1993, began excavating
contaminated waste/soil from residential properties under its removal authority. Connecticut
Department of Energy and Environmental Protection (CTDEEP), then known as the
Connecticut Department of Environmental Protection, likewise excavated contaminated
materials on municipal land and at the Wooster Middle School. EPA listed the Site on EPA's
National Priorities List (NPL) of Superfund sites in April 1995, and a final remedy for the
former manufacturing facility referred to as OU 1, was documented in a July 1995 ROD. In
accordance with the 1995 ROD, approximately 100,000 cubic yards of contaminated material
was transported from 46 residential properties and Wooster Middle School to the former
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Raymark facility, where it was consolidated and capped.
Between 1995 and 1997, EPA completed the cleanup of the 34-acre Raymark property (OU1)
working with the CTDEEP and U.S. Army Corps of Engineers (USACE). The property
became the location of the Stratford Crossing Shopping Center, which opened for retail
business in 2002.
A remedial investigation report in 1999 concluded that fill material throughout Upper Ferry
Creek and associated wetlands (OU3) were contaminated with asbestos, lead, copper, semi-
volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and dioxins.
Similarly, a 1999 remedial investigation report for the former Raybestos Memorial Field
(OU4) concluded that fill material in the area were contaminated with asbestos, lead, barium,
zinc, arsenic, PCBs, and SVOCs.
In September 2011, as more fully described below, EPA issued a partial ROD for OU6.
In September 2016, as more fully described below, EPA issued a ROD for OUs 2, 3, 4, and 6
modifying and finalizing cleanup remedies.4 The Remedial Action for OU2 is complete, and
EPA is now implementing the remedy for OUs 3, 4 and 6.
For a full site history, refer to the Fifth Five-Year Review Report for the Raymark Industries,
Inc. Superfund Site, publicly available on the Internet at:
https:// sem spub. epa. gov/ src/docum en 'A.
C. Present Contamination and Risk
From EPA's sampling and work at the former Raymark Facility, and in conjunction with
CTDEEP, the Town of Stratford and the Raymark Citizens Action Group, it was determined that
lead, asbestos, PCBs, and copper were appropriate constituents to identify or "fingerprint"
Raymark Waste.5 Raymark Waste contains other toxic constituents as well. Through site
investigations, all OUs (except OU2, Groundwater) were evaluated for the presence of Raymark
Waste, and risk assessments were performed to assess whether the Raymark Waste present in
soil resulted in an unacceptable risk to site users and/or the environment. OU2 evaluated eight
VOCs (benzene, chlorobenzene, vinyl chloride, 1,1-DCE, toluene, TCE, chloroform, and 1,1,1-
TCA), known to have originated from the groundwater plume beneath the former Raymark
facility.
Human health and ecological risk evaluations in 2016 concluded the following for each of OUs
3, 4, and 6:6
4 Raymark Industries. Inc. Superfund Site 2016 Record of Decision, publicly available on the Internet at:
https://semspub.epa.gov/src/doaiment/01/592492.pdf
5 "Raymark Waste" in soil is defined as a single soil sample containing lead above 400 parts per million (ppm). and asbestos
(chrysotile only) greater than 1 percent, and either polychlorinated biphenyls (PCBs) (Aroclor 1268 only) above 1 ppm or
copper above 288 ppm. This definition has been used to distinguish fill originating from the former Raymark Facility from
non-Ray mark Waste sources.
6 For a full description of present risks, refer to the Fifth Five-Year Review Report for the Raymark Industries. Inc.
Superfund Site.
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0U3
The human health risk assessment (HHRA) quantitative evaluation of soil/sediment exposures
for OU3 identified unacceptable cancer risks for current and future recreational visitors.
Potential exposure to lead in shallow 0 to 2 feet soil at OU3 would result in Blood Lead Levels
(BLLs) above levels of concern as well. Asbestos was also present in surface soils, wetland
soils, and sediments at depths of 0 to 2 feet. Similarly, ecological risks to birds (heron),
mammals (racoon), sediment biota, and the benthic community also exist from contamination
in the 0 to 1 foot sediment depth interval.
OU4
Similar to OU3, the updated HHRA evaluation of soil exposures for OU4 identified
unacceptable cancer risks for current recreational visitors and future residents. Likewise, the
average lead concentrations in surface soils collected from depths of 0 to 2 feet indicated that
potential exposure to lead in soils would result in BLLs above levels of concern. Asbestos was
also present at levels of concern. Unlike OU3, however, no significant ecological concerns were
found at OU4.
OU6
The updated HHRA quantitative evaluation of soil exposures at OU6 likewise identified
unacceptable cancer risks for current and future recreational visitors, residents, and commercial
workers with PAHs, PCBs, dioxin/furans, pesticide (dieldrin), arsenic, and chromium being the
primary contributors. The average lead concentrations in the 0 to 15 feet soil interval indicated
that potential exposure to lead in soils would result in BLLs above levels of concern, and
asbestos was also found to be present at levels of concern. Due to the existing characteristics of
the OU6 properties (all of the OU6 properties are either developed or have already been
disturbed by surrounding development), no ecological concerns were found to be present.
D. Summary of the Selected Remedy (2011 ROD and 2016 ROD)
2011 Record of Decision
In the 2011 ROD, EPA selected final source control remedies at 576/600 East Broadway (also
known as the "Morgan Francis" property). Beacon Point AOC2, and Third Avenue areas that
address the unacceptable human health risks identified. The selected remedies included the
following major components:
576/600 East Broadway (Morgan Francis) - Final Source Control Action
Excavate Raymark Waste from within the 100-year floodplain to a depth of 4 feet
and place a low-permeability Resource Conservation and Recovery Act-compliant
cap ("RCRA cap") on all Raymark Waste located outside the 100-year floodplain
(upland portion).
Excavate Raymark Waste from within the 100-year floodplain and consolidate on
the upland portion of the two properties to be capped and, if capacity allows,
consolidate Raymark Waste excavated from Third Avenue onto the properties.
Implement institutional controls that restrict future excavation and prohibit the use
of groundwater.
Perform monitoring of groundwater and cap maintenance as required, in addition to
annual reporting and five-year reviews.
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Beacon Point AOC2 - Final Source Control Action
Place institutional controls that restrict excavation and groundwater use.
Perform groundwater monitoring, annual reporting, and five-year reviews.
Third Avenue - Final Source Control Action (To be performed only if consolidation
capacity exists at 576/600 East Broadway)
Excavate all Raymark Waste and backfill the property with clean fill, returning
property to existing conditions.
If capacity allows, consolidate remaining Raymark Waste on 576/600 East
Broadway.
Interim Actions - Restrictions with Monitoring
Place restrictions on any remaining locations throughout Stratford that contain
Raymark Waste where direct contact exposures are a concern and perform quarterly
inspections.
2016 Record of Decision
In the 2016 ROD, EPA selected a combination of engineered control actions (vapor mitigation)
for OU2 and source control actions for OU3, OU4 and OU6. The selected remedy includes the
following general components:
OU2 - Groundwater and Engineering Controls
Install active vapor mitigation ventilation systems at approximately 20 additional
mostly residential properties, assessing potential vapor intrusion risks and installing
additional ventilation systems as needed.
Long-term groundwater monitoring and maintenance of the existing and newly
installed ventilation systems.
Institutional controls to limit future use of groundwater and to address potential
vapor intrusion risks.
Discontinue use of the existing passive dense non-aqueous phase liquid (DNAPL)
extraction system at the former Raymark facility (OU 1).
OU3 - Ferry Creek Soil, Wetland Soil and Sediment Source Control
Excavate and remove the top 2 feet (estimated 4,650 cubic yards) of sediment from
the channel of Upper Ferry Creek from Interstate 95 to the Broad Street bridge.
Excavate and remove to a depth of 4 feet (estimated 22,600 cubic yards) of
Raymark Waste-contaminated soil from the banks of Upper Ferry Creek.
Excavate and remove to a depth of 4 feet (estimated 7,600 cubic yards) of Raymark
Waste-contaminated wetland soil from abutting wetland areas.
Replace excavated sediment and Raymark Waste with clean material and line the
bottom of each excavation with a warning layer.
Sediment and Raymark Waste containing more heavily contaminated material that
exceeds certain regulatory limits, referred to as principal hazardous constituents
(PHCs), will be shipped to a licensed out-of-town disposal facility.
Consolidation of excavated sediment and Raymark Waste at the Raybestos
Memorial Ball field (OU4).
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Ship sediment and Raymark Waste that exceeds the capacity of OU4 to a licensed
out-of-town disposal facility.
Implement institutional controls to limit future excavation, groundwater use, and
other activities that could pose a risk, where necessary.
Perform long-term monitoring and operation and maintenance.
OIJ4 - Raybestos Memorial Ballfield Consolidation and Capping
Consolidate excavated sediment and Raymark Waste from OU3 and OU6 with the
existing 111,000 cubic yards of Raymark Waste on OU4.
Construct a permanent, low-permeability cap (not exceed a maximum elevation of
46 feet above mean sea level) over the consolidation area to isolate contamination.
Construct storm water management features including an underground vault or
alternative system.
Restore the property with vegetation and pavement as appropriate to support
anticipated future use.
Develop institutional controls to protect the cap, limit groundwater use, and other
activities that could pose a risk.
Perform long-term monitoring and operation and maintenance.
OIJ6 - Additional Properties
Excavate and remove to a depth of 4 feet (approximately 71,000 cubic yards) soil
that meets the definition of Raymark Waste from an estimated 22 properties.
Replace excavated Raymark Waste with clean material and lining of the bottom of
each excavation with a warning layer.
Restore excavated areas to the pre-excavation condition, with pavement or
vegetation, as appropriate.
Consolidate excavated Raymark Waste at the former Raybestos Memorial Ballfield
(OU4).
Ship Raymark Waste that exceeds Principal Hazardous Waste Criteria (PHC) to a
licensed out-of-town disposal facility.
Ship Raymark Waste that exceeds the capacity of OU4 to a licensed out-of-town
disposal facility.
Develop institutional controls to limit future excavation, groundwater use, and other
activities that could pose a risk, where necessary.
Perform long-term monitoring and operation and maintenance.
Respond as appropriate to any additional properties or parcels where Raymark
Waste is discovered.
III. THE BASIS FOR CHANGES TO THE SELECTED REMEDY AND
A DESCRIPTION OF THE SIGNIFICANT DIFFERENCES
This ESD documents three (3) significant changes to the remedies as set forth in the 201 1 and
2016 RODs. These changes do not alter the protection of human health or the environment or
any Applicable or Relevant and Appropriate Requirements (ARARs) of the remedy from what
was proposed in the ROD. While "significant," there are no "fundamental" changes to either
ROD. A list of the significant changes, the nature and specific bases for these changes, and an
explanation of the specific modifications to the ROD, are described below.
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Summary of Change
OU
2011
ROD
2016
ROD
Synopsis
1. Coastal Flood Storage
4,6
X
X
CTDEEP clarified its policy on filling
within the coastal floodplain allowing for
vertical and lateral expansion of the cap
at Morgan Francis; consolidation of
Raymark Waste from Uppermost Ferry
Creek at Morgan Francis; and raising the
restored elevations at the Beacon Point
and Lockwood Avenue properties to
incorporate coastal resiliency.
2. Stormwater
Management at OU4
Ball field
4
X
The 2016 ROD stated that a large
underground vault would be constructed
to manage stormwater but that
alternatives would be evaluated. This
ESD documents EPA's final decision to
not construct the vault on OU4, but to
use and improve existing stormwater
infrastructure.
3. Change in Excavation
Depth at CTDOT
Property
6
X
CTDOT raised concerns with a 4-foot
excavation due to the proximity of
Interstate 95. Instead, a 2-foot clean
buffer will be established above the
Raymark Waste in this area.
A. Coastal Flood Storage
Three OU6 properties (Morgan Francis, Beacon Point AOC1, and Lockwood Avenue) are
located partially or entirely within a Federal Emergency Management Agency (FEMA) Special
Flood Hazard Area, including both Zone AE and VE areas, which are regulatory flood zones.
State of Connecticut Regulations Section 25-68h-2(c) permits filling in a tidal floodplain above
the existing topography, without the need to provide compensatory storage, as long as such
filling is not located within a flood way. Such filling complies with the federal floodplain related
ARARs, without the need to provide compensatory storage, if a demonstration can be made
regarding the following:
Filling will have negligible impact on flood storage;
Filling will have negligible impact on flood velocity and no adverse impact on abutters;
The shoreline and any caps or cover over contaminated materials will not be
significantly damaged by a 100- or 500-year flood event; and,
There is no habitat or wetlands impacted by the filling.
Further information is contained in a floodplain memorandum included as Appendix A.
Morgan Francis (576/600 East Broadway) is a 5.6-acre area, situated entirely within the 100-
year flood zone. Construction of the cap and consolidation of Raymark Waste from the Morgan
Francis property itself and abutting OU3 (Ferry Creek) will require filling within the flood zone.
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The 201 1 ROD included floodplain-related ARARs which at the time were interpreted to mean
that no filling was allowed within the 100-year floodplain. At that time, about half of the
property was located within the 100-year floodplain. The remedy included the excavation of
Raymark Waste from the portion of the property located within the floodplain and construction
of the cap limited to the portion of the property outside the floodplain. On July 8, 2013, FEMA
issued an updated flood map that expanded the 100-year flood zone to include the entire Morgan
Francis property.7On February 4, 2014, EPA received a written statement from CTDEEP's
Bureau of Water Protection and Land Reuse clarifying that filling of a floodplain is allowed
within tidally-influenced areas under state regulations, without the need to provide
compensatory storage, provided that the area to be filled is not a flood way.
Modification to the ROD: EPA is revising the cap design to include the consolidation of
Raymark Waste and capping materials within the 100-year flood zone. The anticipated post-
construction elevation of these properties will be raised up to 6 feet in some areas. The State of
Connecticut has determined that the Morgan Francis property is not located in a flood way.
US ACE is performing an analysis of drainage pathways to confirm that there will only be
negligible impacts to the hydraulic characteristics of the floodplain. Based upon the current
design, negligible impacts are expected to flood velocity and storage, and no adverse effects are
anticipated to abutters. There are no significant habitat and wetland impacts anticipated by the
construction of the cap. Also, the cap on Morgan Francis is being designed to withstand
degredation during future 100- or 500-year flood events.
Lockwood Avenue is a 4.8-acre area situated entirely within the 100-year flood zone. More
than half of this area is also tidal wetlands. At EPA's request, both CTDEEP and the Stratford
Waterfront Commission agreed that EPA should evaluate coastal resiliency in the restoration
plan for this property to help offset sea level rise and related climate change impacts by
increasing the post-remediation elevation.
Modification to the ROD: US ACE is evaluating the drainage and flood paths to determine if the
entire remediation area can be raised approximately 1 foot without displacing or trapping flood
water. Negligible impacts are expected regarding flood velocity and storage, and no adverse
effects are anticipated to abutters.
A significant portion of the Lockwood property is tidal wetlands. The approximately 1.5-acre
upland area is vegetated and supports a limited habitat. These areas will be necessarily impacted
during the excavation of Raymark Waste. A heavily degraded coastal bulkhead system will be
restored around the upland area. Wetland areas are anticipated to be restored as such. Mitigative
measures will be implemented during remediation of the upland area to minimize harm to the
local habitat to the extent practical. The post-remediation elevation of much of the property is
anticipated be raised by approximately 1 foot at the time of remediation to incorporate coastal
resiliency and to ensure that the tidal wetlands area remains as a functioning wetland given
anticipated sea level rise. Any added material would be designed to withstand degredation
during future flood events.
Beacon Point is divided into three areas of concern that are all situated entirely within the 100-
year flood zone. Area of Concern 1 (AOC1) is approximately 2 acres including a grassy field.
7 FEMA Map Number 09001C0434G.
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drainage swale, and a public dock and related paved parking lot. At EPA's request, both
CTDEEP and the Stratford Waterfront Commission agreed that EPA should evaluate coastal
resiliency in the restoration plan for this property to help off-set sea-level rise and related
climate change impacts by increasing the post-remediation elevation.
Modification to the ROD: US ACE performed an evaluation of drainage and flood paths, and
there was some concern that flood water could become trapped and inundate an adjacent
condominium property if the elevation of the entire 2-acre remediation area was raised by 1
foot. However, it was determined that the elevation of the public dock and related parking area,
which are located closest to the shore front, could be raised 1 foot without displacing or trapping
flood water. US ACE concluded that raising the elevation of the public dock and related parking
area would result in negligible impacts to flood velocity and storage and have no adverse effects
to abutters. This property was remediated between November 2022 and June 2023 at which time
the post-remediation elevation of the town's recreational dock and associated parking lot were
raised 1 foot. The backfill material included a dense gravel mix with a robust layer of riprap
designed to withstand degredation during future 100- or 500-year flood events. Additional
armoring was also added along the non-wetland portions of shore front.
These modifications regarding coastal flood storage will achieve the same expected outcome as
the remedy selected in the 2011 and 2016 RODs.
B. Storniwater Management at OIJ4
The remedy selected in the 2016 ROD for OU4 included the consolidation of Raymark Waste
from OU3 and OU6 on top of existing Raymark Waste and other contamination on this 13.5-
acre property. A low-permeability hazardous waste cap is being constructed over the
consolidated area (about 7.5 acres) to inhibit future leaching of contamination. The ROD
included construction of a 485,000-cubic-foot underground vault (about 3.6 million gallons) to
manage stornnvater flow from the low-permeability cap. This vault would require a relatively
large footprint to install (approximately 250 feet long by 250 feet wide and 8 feet deep) as well
as an associated bio-retention area. The vault would necessarily displace and require the
excavation of approximately 58,800 cubic yards of Raymark Waste.8 This volume along with
the estimated 85,000 cubic yards to be consolidated from OU3 and OU6 would have exceeded
the capacity of OU4 by an estimated 20,000 cubic yards, which would have been disposed at an
off-site hazardous waste facility. The vault would have also required significant operation and
maintenance costs.
As a result of these concerns, the ROD included language stating that EP A would explore
alternatives to the stornnvater vault, including improvements to the existing regional stornnvater
infrastructure.
Modification to the ROD: EP A performed an evaluation of the Town's Piatt Street pump station
and related infrastructure. It was determined that the existing 18-inch stornnvater culvert and
related 12 cubic-foot-per-second (cfs) pump station were inadequate to manage existing
stornnvater within the Piatt Street drainage area, leaving no capacity for additional stornnvater
from OU4. Through this ESD, EP A is documenting the decision to make improvements to the
municipal stornnvater system rather than constructing the underground vault at the OU4
8 Raymark OU4 Feasibility Study, Appendix A, Table 1, June 2016.
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ballfield. These improvements include constructing a 3-by-6-foot box culvert to convey
storm water from OU4 to the existing open channel approximately 2,000 feet away, and
construction of a new 200 cfs pump station. This gravity fed box culvert will manage
storm water from OU4 and adjacent town-owned property and tie into existing storm water
culverts along East Main Street and property owned by Ashcroft, Inc. Improvements were also
made to the open channel including the removal of phragmites and dredging and lining the
channel with concrete blocks.
Further information regarding the original storm water vault and implemented storm water
improvements are included as Appendix B.
This modification to the remedial component will achieve the same expected outcome as the
remedy selected in the 2016 ROD.
C. Change in Excavation Depth a CTDOT property (OIJ6)
The 2016 ROD called for the excavation and removal to a depth of 4 feet of soil containing
Raymark Waste at an OU6 property referred to as the Connecticut Department of Transportation
(CTDOT) Lot abutting Interstate 95 North. This 2.4-acre property directly abuts Interstate 95 on
the northbound side. See Figure 2 attached.
Through this ESD, EPA is decreasing the excavation depth over a portion of the property to
less than 4 feet. A significant portion of this property is steeply sloped and difficult to access.
CTDOT is concerned that excavating steeply sloped portions to a depth of 4 feet could
compromise the structural integrity of the nearby highway (Interstate 95) and barrier system.
Further, this property is owned by CTDOT and is located within CTDOT"s "asbestos" zone.
CTDOT designated this zone due to the high incidence of Asbestos Containing Material
(ACM) buried near numerous state highways in the Town of Stratford. CTDOT developed a
policy titled "Asbestos Contaminated Soil within CTDOT Right-of-Way in the vicinity of 1-95,
Exit 33 in Stratford" to safely manage properties located within the CTDOT asbestos zone.
Raymark is just one of several sources of buried ACM in the Town of Stratford. See CTDOT
ACM policy in Appendix C.
Modification to the ROD: The Lot abutting Interstate 95 North is located entirely within the
CTDOT asbestos zone. EPA will not excavate and remove 4 feet of Raymark Waste from the
steeply sloped portions of this OU6 property. Alternatively, and consistent with CTDOT policy
on ACM, EPA will ensure a minimum 2-foot vegetative cover remains over Raymark Waste in
the steeply sloped area through the placement of additional clean material or excavation to a
depth of 2 feet if necessary. No changes are required to the remainder of the property. Given the
property-specific characteristics of this difficult to access location, the 2-foot vegetative cover in
the steeply sloped area will be protective of human health.
The above-described modification to this remedial component will achieve the same expected
outcome as the remedy selected in the 2016 ROD.
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IV. SUPPORT AGENCY COMMENTS
CTDEEP reviewed the proposed ESD and attended the public meeting on August 9, 2023. On
September 21, 2023, the CTDEEP project manager submitted an email documenting concurrence with
this ESD. See Attachment 1.
V. STATUTORY DETERMINATIONS
In accordance with Section 117(c) of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. ง 9617(c),
Section 300.435(c)(2)(i) of the National Contingency Plan (NCP), 40 CFR
ง300.435(c)(2)(i), and EPA guidance OSWER [Office of Solid Waste and Emergency
Response] Directive 9200.1-23P (A Guide to Preparing Superfund Proposed Plans,
Records of Decision, and Other Remedy Selection Decision Documents), if EPA
determines that differences in the remedial action significantly change, but do not
fundamentally alter the remedy selected in the Record of Decision with respect to scope, performance,
or cost, EPA shall publish an explanation of the significant differences
between the remedial action being undertaken and the remedial action set forth in the ROD
and the reasons such changes are being made.
EPA has determined that the adjustments to the September 2011 and 2016 Records of Decision, as
explained in this ESD, are significant, but do not fundamentally alter, the overall remedy for the Site
with respect to scope, performance, or cost. Therefore, EPA is properly issuing this ESD.
In accordance with Section 1 17(d) of CERCLA and Section 300.825(a) of the NCP, this
ESD is part of the Administrative Record for the Site and available for public review at the locations
referenced above and online.
VI. PUBLIC PARTICIPATION
On August 15, 2023, EPA hosted an in-person and on-line "hybrid" community meeting to
present information about the changes documented in this ESD. EPA answered questions
during that meeting and solicited additional comments or questions through a formal public comment
period held between August 16 and 30, 2023. No comments were received and
therefore there is no responsiveness summary, and no modifications were made to the substantive portions
of the proposed ESD.
VII. DECLARATION
For the foregoing reasons, by my signature below, I approve the issuance of this ESD for the Raymark
Industries, Inc. Superfund Site in Stratford, Connecticut and the changes stated
therein.
A D r\/r*> Digitally signed by Olson, Bryan
Vy IjUI 1/ D I y O I I Date: 2025.09.25 09:07:41 -04'00'
Bryan Olson, Director
Superfund and Emergency Management Division
U.S. EPA, Region 1 (New England)
12 | P a g c
-------
Raymark Industries. Inc. Supcrfund Site
Explanation of Significant Differences
FIGURES
Figure 1: Location of the Raymark Industries, Inc. Superfund Site, Stratford, CT. The
Site is divided into nine operable units (OUs).
Figure 2: Location of the Connecticut Department of Transportation (CTDOT) Lot
Abutting Interstate 95 North. This is an Operable Unit 6 (OU6) property.
ATTACHMENT
Attachment 1: CTDEEP Concurrence
Attachment 2: Community Flyer and Press Release
APPENDICES
Appendix A: Flood Zone Memorandum
Appendix B: Stormwater Memorandum
Appendix C: Connecticut Department ofTransportation (CTDOT) Policy on Asbestos Containing Material ACM)
-------
FIGURES
-------
QU2 Boundary
Worcester
iringftpld
Wntertiunr
Map Location
O MAP OVERVIEW
V ff ' . s' ' ' I- V
hWooster, Parl
-------
576 & 600 East Broadway
| Outside of the study area |
Historic Raymark Waste exceedance outside
I limits of study area J
576 & 600 East Broadway properties are not included in the PDI.
lAtthe direction of USACE, a portion of the Raymark Waste
iidentified on the 576 East Broadway property is included
ฆin volume calculations contained in this PDI Report.
Once the RD for these properties (prepared by others) is
finalized the limits of waste should be re-visited to verify
that they match the limits contained in the RD.
INOTE: Raymark Waste and PHC waste limits shown in the PDI Report will inform development
pfthe Remedial Design (RD). The RD Report will incorporate information from the PDI and other design consideratic
to develop an RD, including remediation limits, where appropriate. The limits of remediation shown in the RD
Jmay differ from delineations depicted in the PDI Report. In some cases the RD may incorporate additional sampling
[to further refine the limits of waste.
Legend: ฆ AECOM 2017/2018 PDI Raymark Waste Boring
~ AECOM 2017/2018 PDI Non Raymark Waste Boring
AECOM Raymark Waste Delineation
OU 3 Raymark Waste Delineation
Historic Raymark Waste Boring
Historic Non Raymark Waste Boring
EPA 2018 Non-Waste Sample
EPA 2018 Raymark Waste Sample
Surveyed Property Boundary
OU6 Additional Properties Study Area
Limits of OU3 Investigation
AECOM
PROJECT
PRE-DESIGN INVESTIGATION
REMEDIAL DESIGN
RAYMARK SUPERFUND SITE
Stratford, Connecticut
CLIENT
US Army Corps
of Engineers -
New England District
CONSULTANT
AECOM
500 Enterprise Drive Suite 1A
Rocky Hill, CT 06067-3913
860.263.500 tel 860.263.7777 fax
www.aecom.com
REGISTRATION
STAMP Dale:11g6/2019
REFERENCE
ISSUE/REVISION
1
GPK
12/27/2018
2
GPK
11/26/2019
PROJECT NUMBER
U
SHEET TITLE
OU6 VACANT LOT ABUTTING I-95
RAYMARK WASTE DELINEATION
FIGURE NUMBER
10F
-------
ATTACHMENT 1
-------
From: Ailevo. Anthony
To: DiLorenzo, James
Cc: Keefe. Daniel
Subject: ESD Concurrence
Date: Friday, September 22, 2023 9:18:42 AM
Importance: Low
Caution: This email originated from outside EPA, please exercise additional caution when deciding whether to open
attachments or click on provided links.
September 21, 2023
Jim DiLorenzo,
The Remediation Division of the Bureau of Water Protection and Land Reuse (DEEP) has reviewed the Explanation
of Significant Differences (ESD) for the Raymark Superfund Project, Operable Units 4 & 6, dated August 2023 and
presented at the August 15, 2023 public meeting.
The ESD describes changes to both July 2011 and September 2016 Records of Decision (ROD) and documents
three issues of difference: Costal Flood Storage of three OU6 properties, Morgan Francis, Beacon Pont and
Lockwood Ave., Stormwater Management of OU4, and Change in excavation depth of DOT owned OU6 property.
DEEP staff have reviewed the ESD and are in concurrence with the proposed and presented differences to the
RODs.
Nothing in this concurrence letter shall affect the Commissioner's authority to institute any proceeding, or take any
action to prevent or abate pollution, to recover costs and natural resource damages, and to impose penalties for
violations of law. If at any time the Commissioner determines that the approved actions have not fully characterized
the extent and degree of pollution or have not successfully abated or prevented pollution, the Commissioner may
institute any proceeding, or take any action to require further investigation or further action to prevent or abate
pollution. This approval relates only to pollution or contamination identified in the above referenced proposal.
In addition, nothing in this concurrence shall relieve any person of his or her obligations under applicable federal,
state and local law.
Anthony Ailevo
Environmental Analyst
DEEP
Bureau of Water Protection and Land Reuse Remediation Division, SC
-------
ATTACHMENT 2
-------
Raymark Superfund Site
ฃ|L \ Release of Explanation of Significant Differences (ESD)
Notice of Public Meeting
August 2023
OVERVIEW
The United States Environmental Protection Agency ("EPA") is announcing the public availability of
a draft decision document for the Raymark Industries Superfund Site ("Raymark") referred to as an
Explanation of Significant Differences ("ESD"), and the scheduling of an informational public meeting
to discuss the ESD. A 15-day public comment period will follow the public meeting. Following
response to public comment, EPA will determine whether to approve and issue a final ESD.
By issuing this draft ESD, EPA has determined that differences in portions of the Raymark remedial
action significantly change but do not fundamentally alter the remedies selected in both the 2011 and
2016 Records of Decision ("RODs") for the Raymark Site. The ESD explains the significant
differences between the remedial actions being undertaken and the remedial actions set forth in the
(1) Coastal Flood Storage
The 2011 ROD requires capping of Raymark Waste at the Morgan Francis property. The 2016 ROD
requires the excavation of Raymark Waste from additional properties some of which are located within
the tidal (or coastal) floodplain. Most properties will be restored to their original elevation. However,
the post-remediation elevation will be raised at three of the properties as follows:
Morgan Francis - Raymark Waste will be consolidated from abutting areas on top of existing
buried waste and covered with a hazardous waste capping system. This will raise the elevation
at the property by up to 6 feet.
Beacon Point - Raymark Waste has been excavated from this property. The majority of the
property was restored to existing grade except that the elevation of the Town's recreational dock
and associated parking lot were raised by 1 foot to provide resiliency against sea-level rise.
Lockwood Avenue - Raymark Waste will be excavated from this property. The majority of the
property is tidal wetlands and will be raised by 1 foot to provide resiliency against sea-level rise.
RODs.
SUMMARY OF SIGNIFICANT CHANGES
-------
(2) Storm water Management
EPA is actively consolidating excavated Ray mark Waste on top of existing buried waste located at the
site of a former ball field located on Frog Pond Lane. A hazardous waste cap will be constructed over
the 7.5-acre consolidation area to inhibit future leaching of contamination. The 2016 ROD included
construction of an underground vault (about 3.6 million gallons) to manage the increased storm water
flow that will be created by the low-permeability cap. This vault would have displaced about 58,800
cubic yards of existing Ray mark Waste and would have required significant long-term maintenance.
EPA evaluated alternatives and has instead constructed a 3-by-6-foot box culvert to convey storm water
by gravity from the consolidation area to a new 200 gallon per minute pump station and which will
discharge storm water to the Housatonic River.
(3) Change in Excavation Depth at an OU6 property
The 2016 ROD requires the excavation of Ray mark Waste from additional properties to a depth of 4
feet. One of the additional properties is owned by the Connecticut Department of Transportation
("DOT") and referred to by EPA as the DOT Lot Abutting Interstate 95 North. This 2.4-acre property
directly abuts Interstate 95 on the northbound side. A significant portion of this property is steeply
sloped and difficult to access. DOT has raised concerns that excavating the steeply sloped areas to a
depth of 4 feet could compromise the structural integrity of the nearby highway. Consistent with DOT
policy, EPA intends to alternatively provide a 2-foot clean cover over Ray mark Waste on the steeply
sloped area. Ray mark Waste located within the flat portions of this property will continue to be
excavated to a depth of 4 feet.
PUBLIC MEETING, COMMENT PERIOD AND CONTACT INFORMATION ]
Informational Public Meeting on August 15, 2023 at 6:30pm.
Thi s will be a "hybrid" meeting. In person attendance at EPA's Stratford office at 300 Ferry Boulevard OR
To attend the meeting virtually, please use link on EPAs Raymark webpage.
A 15-day public comment period will be held from August 15 to 30, 2023. Comments may be submitted via email
at .v ; : or mailed to EPA Remediation Headquarters, 300 Ferry Boulevard, Stratford, CT
06614.
For more information, please contact:
Jim DiLorenzo, EPA, 617-918-1247, di 1 orenzo.jim@epa.gov
Darriel Swatts, EPA, 617-918-1065, swatts.darriel@epa.gov
For general information, property locations, photos, virtual public meeting dates and ongoing updates regarding
the Raymark Superfund Site clean-up:
EPA's website: epa.gov/superfund/ravmark
EPA's Raymark Facebook page: facebook. com/EPA Raymark
-------
CONNECTICUT POST | CTPOST.COM
WEDNESDAY, AUGUST 9, 2023 B7
CONNECTICUT POST
SOUTHERN1
CTJ^BS
MARKETPLACE
203-333-4151 | classifieds@hearstmediact.com | Hours: 8:00 a.m.-3:30 p.m., M-F | Major Credit Cards Accepted
Public Meeting Notice: Raymark Industries, Inc. Site Update
Tuesday, August 15, 2023
6:30pm - 8:00pm
Raymark Cleanup Headquarters, 300 Ferry Blvd., Stratford, CT
06615
US EPA will hold a public meeting to announce a proposed Explanation of
Significant Differences (ESQ) for the Raymark Industries, Inc, Supetfund
Site (Raymark Site) iri Stratford, CT. Issuance of this ESD is necessary to
document significant changes to the temedies as set foith in the 2011 and
2016 RODs.
EPA is proposing through the ESD to add fill material within the tidal
floodplain at the Morgan Francis, Beacon Point and Lockwood Avenue
properties, to document the stormwater management plan for OU4 and to
reduce the excavation depth at one OU6 property. While significant, these
changes do not fundamentally alter the remedies. The draft ESD will be
presented at the public meeting on August 15, 2023, and will be opened to
the public for comment the following day.
Public Comment Period:
A formal public comment period on this diaft ESD will run from August 16,
2023 through August 30, 2023. Beginning August 16, 2023, EPA will accept
written and e-mailed comments on this ESD which will be included in the
administrative record. Submit your comments by mail, hand
deliveiy/courier, or email to:
James DiLorenzo, Remedial Project Manager
Raymaik Industries, Inc. Supetfund Site
EPA Region 1, Raymark Cleanup Headquarters
300 Ferry Blvd
Stratford. CT 06615
DiLorenzo.Jim@epa.gov
A copy of EPA's proposed ESD for the Raymark Site and its Administrative
Recoid File as well as the original Records of Decision, previous
Administrative Records for the Site, and other technical documents related
to the site are available for review on EPA's web page
www.epagov/supeifund/iaymarkorat the following locations:
The U.S. Environmental Protection Agency Records Center located at 5
Post Office Square, Suite 100, Boston, Massachusetts. The Records
Center is open Monday through Friday, 9:00 am until 5:00 pm; for an
appointment to view the records at EPA's office please call at 617-918-
1440.
Darriel Swatts, EPA Community Involvement Coordinator
Sv.uK D.imol'-op.iqov
Office: 617-918-1065
PUBLIC NOTICE OF
PENDING APPROVAL FOR A
CERTIFICATE OF WETLANDS CONFORMANCE
FAIRFIELD, CONNECTICUT
PURSUANT TO SECTION 6.4 OF THE INLAND WETLANDS AND
WATERCOURSES REGULATIONS OF THE TOWN OF FAIRFIELD,
CONNECTICUT, PUBLIC NOTICE IS HEREBY GIVEN THAT THE INLAND
WETLAND AND WATERCOURSES AGENCY'S DESIGNATED AGENT
INTENDS TO APPROVE THE FOLLOWING APPLICATION FOR A
CERTIFICATE OF WETLANDS CONFORMANCE:
Assessor's Map: 156 Parcel No: 19
Location of proposed activity (address): 3025 Burr Street
Type of activity: Replacement of septic tank and construction of an
in-ground pool and patio within a regulated area
ANY PERSON OBJECTING TO THE APPROVAL OF THIS CERTIFICATE
MAY SUBMIT A WRITTEN AND DATED PETITION TO THE INLAND
WETLAND AGENCY WITHIN FIFTEEN (15) CALENDAR DAYS OF THIS
NOTICE FOR THE PURPOSE OF REQUIRING REVIEW OF THE
CERTIFICATE BY THE INLAND WETLAND AGENCY.
FAIRFIELD CONSERVATION COMMISSION ACTING AS
THE INLAND WETLAND AND WATERCOURSES AGENCY
FAIRFIELD CONSERVATION COMMISSION
LUKAS THOMAS, CHAIRMAN
RICHARD BOUCHER, SECRETARY
JOANNE MOURA, CLERK
LEGAL NOTICE
Tracy's Garage Inc. 129 Water St.
Derby Ct. 06418 will sell the follow-
ing vehicle on 8-21-2023 at 10:00
A.M. at Tracy's Gatage Inc. 129
Water St Derby a. 06418 2014
Jeep Wrangler Spott VIN:
1C4AJWAGOEL239649.
PROBATE NOTICES
NOTICE TO CREDITORS
The Hon. Max L. Rosenberg,
Judge of the Court of Probate,
District of Stratfoid Probate Court,
by deciee dated July 14, 2023,
ordered that all claims must be
presented to the fiduciary at the
address below. Failure to promptly
present any such claim may result
in the loss of rights to recover on
such claim.
Deirdte Bassett, Chief Clerk
The fiduciary is:
Martin Jerome Goldschmidt,
Co-Executor
Stephen F. Goldschmidt,
Co-Executor
C/O Attorney Richard Giarniero
972 East Broadway
Stratfoid, CT 06615
FIND
YOUR
NEXT
BEST
FRIEND
HERE!
PROBATE NOTICES
NOTICE TO CREDITORS
ESTATE OF Eileen Ruth
Goldschmidt, AKA Eileen R.
Goldschmidt (23-0009(9
The Hon. Max L. Rosenberg,
Judge of the Court of Probate,
District of Stratford Probate Court,
by decree dated July 14,2023,
ordered that all claims must be
presented to the fiduciary at the
address below. Failure to promptly
present any such claim may result
in the loss of rights to recover on
such claim.
Deirdre L. Bassett, Chief Clerk
The fiduciary is:
Martin Jerome Goldschmidt,
Executor
c/o RICHARD PAUL GIARNIERO,
GIARNIERO & ASSOC:,
972 EAST BROADWAY, SUITE 203,
STRATFORD, CT 06615
NOTICE TO CREDITORS
Stephanie A. Miller, Assistan
The fiduciary is:
Lillian Slater
c/o DANIEL F SCHOPICK,
STEIBER&SCHOPICK,
572 WHITE PLAINS RD,
TRUMBULL, CT 06611
PROBATE NOTICES II WANTED TO BUY II DUMP RUNS II MASONRY / PAVING
The Hon. T. R. Rowe, Judge of the
Court of Probate, District of
Trumbull Probate Court, by decree
dated August 4, 2023, ordered that
all claims must be presented to the
fiduciary at the address below.
Failure to promptly present any
such claim may result in the loss of
rights to recover on such claim.
Stephanie A. Miller, Assistant Cletk
The f iduciaiy is:
Marie D. Colimitra
c/o DANIEL F SCHOPICK,
STEIBER&SCHOPICK
572 WHITE PLAINS RD,
TRUMBULL, CT 06611
NOTICE TO CREDITORS
The Hon. Kathleen N. Maxham,
Judge of the Court of Probate,
District of Fairfield Probate Court,
by decree dated July 31, 2023,
ordered that all claims must be
presented to the fiduciary at the
address below. Failure to promptly
present any such claim may result
dI rights to re
ฆ the to
such claim.
Chetyl Monk, Assistant Clerk
The f iduciaiy is:
Robert A. Maier
c/o THOMAS M ULLIGAN,
MCNAMARA AND KENNEY,,
1087 BROAD STREET, 3RD
FLOOR, BRIDGEPORT, CT 06f
NOTICE TO CREDITORS
ESTATE OF Wanda Z.
Grabarz, AKA Wanda
Grabarz, AKA Wanda
Crabaez
(23-00294)
The Hon. Max L. Rosenberg,
Judge of the Court of Probate,
District of Stratford Probate Court,
by decree dated August 3,2023,
ordered that all claims must be
presented to the fiduciaiy at the
address below. Failure to promptly
present any such claim may result
in the loss of rights to recover on
Jennie-Lynn Mainville, Clerk
The fiduciaiy is:
Barbara Z. Viglione, Executrix,
c/o KEVIN WILUAM FINCH, LO OF
KEVIN W. FINCH, 244
BRIDGEPORT AVE,
MILFORD.CT 06460
LIQUOR PERMIT
Notice of Application
This is to give notice that I,
WILLIAM SAM
813 RIVER RD
SHELTON.CT 06484-5432
Have filed an application
placarded 08/07/2023 with the
Department of Consumer
Protection
for a CAFE LIQUOR PERMIT for
alcoholic liquor on the premises at
813 RIVER RD
SHELTON CT 06484-5432
Objections must be filed by: 09-18-
2023
Visit:
https://poital.ct.gov/remonstrance
WILLIAM SAM
GENERAL HELP WANTED
MECHANIC - ExperiencedF/T
needed for large, landscape/site
development co. Full knowledge c
landscape equip/heavy mach i
truck fleet from pick up's to tri-axe
dumps. Call Lou 203-869-2583
Tire Seivice Person.
Passenger and TruckTires
Apply Professional Tiie,
20 Todd Rd, Shelton
BUSINESS OPPORTUNITIES
FLOWER SHOP
Well established business for sali
in Stiatford, Call for details
203-615-4141
LOST AND FOUND
Poodle Rescue Connecticut
203-206-3420
Found Dog on state st
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Call to describe.
MERCHANDISE FOR SALE
Potter-Cable g
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COLLECTOR BUYING Old Bottles
of Bourbon, Scotch, Cognac, Whis-
key, Rum, 25 years experience, ref-
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COSTUME JEWELRY
WANTED
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Also Buying Gold & Silver
$$ CASH PAID $$
(203) 589-1880
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CONCERT T-SHIRTS
203-589-1880
ROOMS FOR RENT
BRIDGEPORT- FURN'D ROOMS
Share kit+bath $700 and up
Utilities incl. Accept SSI. Call:
203-610-1705 or 203-218-2094
APARTMENTS FOR RENT
1 bd Condo, Stiatford, Stoneleigh
Sq, 1st Fl, on Bus line, Heat/HW inc.
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CONFIDENTIAL: non-profit social
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lease w/option in Stratford, Trumbull
or Fairfield a 7-10,000 SF church,
school, social club or L.I. bldg
on/near bus line. Contact Alan
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6789 or AFischer@FischeiCom.com
VEHICLES FOR SALE
1966 BUWICK Skylark Convertible,
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Original condition, no rust or rot.
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will return call
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203-856-7000
VEHICLES WANTED
CASH PAID FOR ANY
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Running or not, crashed ok, will
take other makes/models,
free pick up, call ai
DONATE YOUR CAR to Children
with Special Needs Tax Deductible
Free Towing 203-293-6474
JUNK CABS WANTED-
itle or no Title, CASH PAID ON
SPOT, 203-907-7766
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OR 203-895-0542
JUNK REMOVAL & MORE
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TOP SOIL/SAND
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GRAVEL
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PREMIUM SCREENED
TOPSOIL
8 cubic yards 12 cubic yards 18cubic yards
$395 $495 $645
{plus 6.35% CT Sales Tax)
Delivered To: Bpt., Easton, Ffld, Monroe, Mlfrd, Shelton, Stfd, &Trumbull
Crushed Stone, Process, Fill Material &Truck Service Available
Stratford Rock, LLC 203-386-1407
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REQUIREMENTS:
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Routes are delivered seven (7) days a week. Delivery window is
between the hours of: 1 a.m. - 6 a.m. Monday - Friday &
1 a.m. - 7:30 a.m. Saturday & Sunday.
* Routes can earn between $1,300-1,600 per month.
Westport $510/week Trumbull $400/week Norwalk $280/week
New Milford $900/week Danbury $375/week
Dan bury $360/week* Fairfield $400/week Westport $500/week
If interested, please call
860-646-0600 x362
Did you Know?
DA ccording to the National Sleep Foundation, certain foods
/*may help people fall asleep faster and sleep more soundly
while others may compromise a person's ability to enjoy a restful
night's sleep. In lieu of white bread, refined pastas and sugar-laden
baked goods, all of which can reduce serotonin levels, the NSF
recommends whole g*ains.The buildup of serotonin in the brain
^ during periods of wakefulness can contribute to the onset
of sleep later in the dty If serotonin levels in their brains are
disturbed, then people ma/ experience difficulty falling asleep.The
NSF also recommends almonds and walnuts, which contain melatonin, a hormone
that helps to regelate the sleep/wake cycles. In addition,foods that are higfi in lean
protein that contain the amino acid tryptophan also may increase the production of
serotonin, potentially contributing to a restful night's sleep.
-------
APPENDICES
-------
APPENDIX A
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1
^ ^ 5 Post Office Square, Suite 100
^PROl# Boston, MA 02109-3912
Memorandum
Date: August 9, 2023
Subject: Flood Plain Memorandum for Explanation of Significant Differences
Raymark Industries Inc. Superfund Site - Stratford, Connecticut
To: File
Thru: John Kilborn and Jaegun Lee, ORC
From: Jim DiLorenzo, RPM, SEMD
The purpose of this memorandum is to document the evaluation of three Operable Unit 6
(OU6) areas located within the tidal floodplain at the Raymark Industries, Inc. Superfund
Site ("Site"). This memorandum supports the significant change to the remedial decision
as documented in the associated Explanation of Significant Differences (ESD) that filling
within the tidal floodplain in these three OU6 areas complies with the substance of state
and federal applicable and relevant and appropriate regulations (ARARs). For this
memorandum and associated ESD the terms "tidal" and "coastal" are the same.
BACKGROUND
Three OU6 properties (Morgan Francis, Beacon Point AOC1, and Lockwood Avenue)
are located partially or entirely within a Federal Emergency Management Agency
(FEMA) Special Flood Hazard Area, including both Zone AE and VE areas, which are
regulatory flood zones. Figures are attached that show the 100-year floodplain for these
three properties.
On February 4, 2014, EPA received a written statement from CTDEEP's Bureau of
Water Protection and Land Reuse clarifying that filling of a floodplain is allowed within
tidally influenced areas, without the need to provide compensatory floodplain storage,
provided that the area to be filled is not a flood way. This statement is attached.
State of Connecticut Regulations Section 25-68h-2(c) permits filling in a tidal floodplain
above the existing topography, without the need to provide compensatory floodplain
storage, as long as such filling is not located within a flood way. Such filling can comply
with the federal floodplain related ARARs, without the need to provide compensatory
storage, if a demonstration can be made regarding the following:
1
-------
Filling will have negligible impact on flood storage.
Filling will have negligible impact on flood velocity and no adverse
impact on abutters.
The shoreline and any caps or covers over contaminated materials will
not be significantly damaged by a 100- or 500-year flood event.
There is no habitat or wetlands impacted by the filling.
Documentation of this floodplain evaluation for the three OU6 Properties
follows.
MORGAN FRANCIS
Morgan Francis (576/600 East Broadway) is a 5.6-acre area, situated entirely within
the 100-year flood zone. Construction of the cap and consolidation of Raymark Waste
from the Morgan Francis property itself and abutting OU3 and OU6 properties will
require filling within the flood zone.
The most recent floodplain maps for this area were released by FEMA in 2013. This
update expanded the floodplain across the entire 5.6-acre property. (Previously, the
floodplain encroached only onto the eastern portion of the property.) An updated
Remedial Design (RD) is currently underway that will require filling within the
floodplain from both the consolidation of waste material and the addition of material
necessary to construct the low-permeability cap. The updated RD will include an
evaluation of the floodplain and demonstration consistent with ARARs. The current
floodplain elevation is at 11 feet above sea levels (NAVD88). Portions of the cap may
extent to an evaluation of about 16 feet. An initial review indicates that the Morgan
Francis property is not within a floodway and that the property can be graded to allow
adequate drainage such that flood water will not be trapped, and adjacent properties will
not be flooded. The Morgan Frances property does not contain significant habitat and
does not contain wetlands.
A location figure and figures that show the pre-2013 floodplain, the current floodplain,
and RD draft grading plan for Morgan Francis are attached.
BEACON POINT AREA OF CONCERN 1 (AOC1)
Beacon Point is an OU6 property divided into three areas of concern that are all situated
entirely within the 100-year flood zone. A location figure is attached. Area of Concern 1
(AOC1) is approximately 2 acres including a grassy field, drainage swale, and a public
dock and related paved parking lot, and is the subject of this analysis. Raymark Waste
was excavated from this entire area to a depth of 4 feet. Prior to the start of remediation
and at EPA's request, both the CTDEEP and the Stratford Waterfront Commission
agreed that EPA should evaluate coastal resiliency in the restoration plan to mitigate the
effects of sea-level rise and related climate change impacts by increasing the post-
remediation elevation. U.S. Army Corps of Engineers (USACE) performed an evaluation
of drainage and flood paths. Portions of the area may act as a floodway, and there was
2
-------
some concern that flood water could become trapped and inundate an adjacent
condominium property if the elevation of the entire 2-acre remediation area was raised.
However, it was determined that the elevation of the public dock and related parking
area, which are located closest to the shore front, could be raised 1 foot without
displacing or trapping flood water. This is documented in the attached email from
US ACE dated December 7, 2022. CTDEEP concurred with this approach as documented
in a December 9, 2022 email also attached.
Area of Concern 2 (AOC2) is under the main public parking lot. Raymark Waste within
AOC2 is generally deeper than 8 feet and is completely under pavement. There is no
active cleanup for AOC2. An Environmental Land Use Restriction (ELUR) has been put
in place to prevent future contact.
Area of Concern 3 (AOC3) includes a difficult to access area of shoreline, adjacent tidal
wetlands, and a private commercial property. Raymark Waste from AOC3 was excavated
to a depth of 4 feet and backfilled to original grade. An ELUR will be placed on AOC3 to
prevent future contact.
There were no changes to the floodplain elevation for AOC1 and AOC3.
LOCKWOOD AVENUE
Lockwood Avenue is a 4.8-acre area situated entirely within the 100-year flood zone.
More than half of this area is also tidal wetlands. At EPA's request, both CTDEEP and
the Stratford Waterfront Commission agreed that EPA should evaluate coastal resiliency
in the restoration plan for this property to help offset sea level rise and related climate
change impacts by increasing the post-remediation elevation. This evaluation of drainage
and flood paths by US ACE is underway. The objective of the evaluation is to
demonstrate that the entire remediation area can be raised approximately 1 foot without
displacing or trapping flood water or harming abutters. If the evaluation demonstrates no
adverse effects, EP A intends to increase the post-excavation elevation of the entire tidal
wetland area by about 1 foot. Increasing the elevation of the tidal wetlands will allow the
area to remain a functioning wetland give anticipated sea level rise. EPA is also
evaluating the efficacy of increasing the elevation of non-tidal areas. CTDEEP concurred
with this approach as documented in the attached memorandum December 13, 2022. A
location and wetland delineation figure is also attached.
FIGURES
Current 100-year floodplain location maps
Morgan Francis location figure
Pre-2013 floodplain delineation for Morgan Francis
Morgan Francis grading plan
Beacon Point location figure
Lockwood Avenue location and wetland delineation figure
3
-------
ATTACHMENTS
Statement from CTDEEP's Bureau of Water Protection and Land Reuse
regarding filling in tidal wetlands, February 4, 2014.
Statement on Beacon Point from United States Army Corps of Engineers,
December 7, 2022.
Statement on Beacon Point from CTDEEP, December 9, 2022.
Statement on Lockwood Avenue from CTDEEP, December 13, 2022.
4
-------
Kilborn, John
From: Ifkovic, Diane [Diane.lfkovic@ct.gov]
Sent; ' Tuesday, February 04, 2014 12:43 PM
To: Kilborn, John; Curran, Ronald
Cc: ฆ . 'Frances, lvy!
Subject: 576/600 East Broadway, Stratford
Attachments: vol 4 of 6.pdf; 600EastBroadwayStratford.pdf
Importance: ฆ Low ฆ
Follow Up Flag: ฆ Follow up
Flag Status: Completed , , .
Mr. Kilborn, . ,
Ron Curran of the CTDEEP forwarded me your email below regarding the filling of the floodplaiti at 576/600 East
Broadway, Stratford, CT. Ron and I have had discussions about this project in relation to floodplain management issues
and placing clean fill at this contaminated site.
FEMA minimum standards do not prohibit adding fill to floodplain areas. Limitations are placed for adding fill in
designated flood ways. This site is not located in a floodway. State statute does require compensatory storage for fill
placed in non-tidally influenced area. This location, however, is located in a tidally influenced area and compensatory -
storage Would not be required. This is indicated in the attached Flood Insurance Study for Fairfield County, CT, dated
October 16, 2013,,Volume 4, flood profile 134P for Ferry Creek/Long Brook. Tidal effects from Long Island Sound
reach beyond U.S. Route 1 to where Ferry Creek crosses.Longbrook Avenue, well past the site location.
Both the FEMA minimum standards arid state regulations are incorporated into local zoning regulations or ordinances.
I ha ve also copied Ivy Frances, chief of the floodplain management and insurance branch, at the FEMA Region I office
in Boston in case you would like to confirm the requirements with the federal agency that administers the National
Flood Insurance Program (NFIP). ' . . - ' - .ฆฆฆ. - . ;
diane .'ฆฆฆฆ.... ' .
Diane S, Ifkovic - ' ,
State NFIP Coordinator/Environmental Analyst 111
Connecticut Department of Energy & Environmental Protection
Bureau of Water Protection & Land Reuse
Inland Water Resources Division
Flood Management Program -
79 Elm Street. 3rd floor
Hartford, CT 06106-5127 '
Phone: (860) 424-3537 '
Fax: (860) 424-4054 '
Email: diane.ifkovic@ct.gov - . . . . ฆ . ฆ. .
1
-------
From: Kilborn, John [mailto:]
Sent: Tuesday, February 04, 2014 8:41 AM
To: Curran, Ronald
Cc: Jennings, Ronald
Subject: Morgan-Francis'Property
Ron:
As we discussed yesterday, thanks for talking to the OLISP program. As for the state floodplain standards, I
am primarily'concerned with the fldodplain management, standards in. the Regulations. I would like to know if
it is QLlSP's opinion that a four foot cap at Morgan-Francis, placed on top of existing grade, can meet the
floodplain management standards, specifically Section 25-68h-2(c) regarding -filling. I've pasted the
regulations below.
Thanks for your help!
John
: Sec." 25-6.8hr2. Floodplain management standards--- , ' .
. - 1 1 . ฆ . .
(a) All state activities shall conform to the Federal Emergency Management Agency National
, ' . - ฆ . . ฆ . .
Flood Insurance Program requirements, specifically Part 60 - Criteria For Land Management
and Use, Subpart A Sections 60.3, 60.4 and 60.5.
(b) The following restrictions shall pertain to all new and substantially improved structures
located within the floodplain.
(1) Structures shall not be designed for human habitation unless elevated with the lowest
-------
floor one foot above the level of the base flood.
(2) Structures and all stored materials which may result in damage to other structures,
restriction of bridge, openings or other narrow sections of the, stream or river shall be
anchored or restrained to prevent them from floating away.
(3) Service facilities such as electrical and heating equipment shall be constructed at or
ฆabove/the- elevation of the base flood or floodproofed with a passive. system,
(4) Structures located within a "coastal high hazard area" as defined in 44 CFR Part 59
shall be elevated on adequately anchored pilings or columns and securely anchored
to such piles or columns such that the lowest portion of the structural members of the
lowest floor (excluding the pilings or columns) is elevated to one foot above the base
flood and certified by a registered professional engineer or architect that the structure
is securely anchored, to piling or columns in order to withstand velocity waters and
hurricane wave wash.
(5) No new structures shall be permitted on undeveloped coastal barrier beaches as
designated by the Federal Emergency Management Agency (FEMA).
(6) All water supply equipment shall be designed to prevent flood waters from entering
; . and contaminating the system.
j (7) All sanitary sewer collection systems located in the floodplain must have watertight
manhole covers and if equipped with vents, shall extend above the elevation of the
base flood.
(c) The following restrictions shall pertain to all filling, dumping, construction, excavating, and
.other activities which change the topography within the floodplain.
(1) No filling, dumping or construction or other activity shall be allowed which would
increase the elevation of the base flood by more than one foot or adversely affect the
-------
hydraulic characteristics of the floodplain unless the proposed filling is fully ' '
compensated for by excavation in or contiguous to the filled area.
(2) No filling, dumping, construction or excavation will be allowed if these changes will
result in a concentration of the natural flow of water such as to cause or increase
drainage, erosion or sediment problems.
(3) Any fill placed in the floodplain shall not be greater than that which is necessary to
achieve the intended purpose as demonstrated by a plan showing the uses to which
the filled land will be put and the final dimensions of the proposed fill or other
. . materials.
(4) Such fill or other material shall be protected against erosion as discussed in the :
Connecticut' Guidelines for Soil Erosion and Sediment Control (1985), as may be
ฆ amended. " . - ' ฆ.
(5) Any activity within a floodway designated by FEMA which would result in an
increase of the elevation of the base flood or ten year flood profile is prohibited.
' ฆฆฆฆฆ " \ ,
. \ (6) The placement of fill in areas of high velocity flow or at the outside edge of a
migrating river bend is discouraged.
(d) The following restrictions shall pertain to the storage of materials and equipment within the
flood ^ ฆ ฆฆฆฆ'. ฆฆฆ:<-.
4
-------
John W. Kilbom
Senior Enforcement Counsel ' , : '
U.S. Environmental Protection Agency
Five Post Office Square, Suite 100 (Mail Code: OES04-3)
Boston, MA 02109-3912
Tel; 617-918-1893 '
Fax: 617-918-0893 -
. E-Mail: kilbom,iohn@epa.gov
********** ********* * * * * attachment not delivered ***************** * *
This Email message contained an attachment named . - - ฆ - :
imageOOl. jpg.. , . ' j . . - 1ฆ
which may be a computer" program. This attached computer program could
contain a computer virus which couldcause harm.to EPA's computers,
network, and data. - Theฆฆ attachment-has been-deleted. ,
This "was.done to limit the distribution of computer viruses introduced
.. into the EPA network. EPA is. deleting all computer program attachments
.sent from..the Internet into the agency via. Email, ' -
If the message sender is known 'and the attachment was legitimate, you
should contact the^ sender and request that they rename the file name'
extension and resend the Email with the renamed attachment. After
receiving the.revised Email, containing the renamed attachment, you can
re'name.-the file -extension to its 'correct, name... .
For-:ฃurther information., .please-'contact' the .EPA Call Center at .
(-8 66)' 411-4EPA {4372). The TDD number is (866) 489-4900. ;
*$ ******.************ **.* ATTACHMENT NOT' DELIVERED ***************-*.**''* **ฆฆ**
-------
From:
To:
Subject:
Loonev. Michael S CIV USARMY CENAE fUSA)
Pi Lorenzo, James
FW: Draft "Coastal Resiliency" Language
Hi Jim,
As discussed, our design team agrees with your proposed statement regarding raising of the Beacon
Point fishing pier parking area by V.
Thanks,
Mike
Mike Looney, PE
Project Manager
Programs/Project Management Division
USAGE New England District
696 Virginia Rd
Concord, MA 01742
Michaels. I oonev(S)usace. armv. mil
P: 978-318-8380
From: Thibodeau, Lee P CIV USARMY CENAE (USA)
Sent: Wednesday, December 7, 2022 9:03 AM
To: Looney, Michael S CIV USARMY CENAE (USA)
Cc: Mueller, Katelyn E CIV USARMY CENAE (USA)
Subject: RE: Draft "Coastal Resiliency" Language
Mike,
(1) We don't need to worry about flood storage in a coastal tidal environment. Only applies to
inland water systems. At least it does in MA and would assume this is pretty uniform across multiple
states.
(2) Agree with statement.
Lee
From: Looney, Michael S CIV USARMY CENAE (USA)
Sent: Wednesday, December 7, 2022 8:49 AM
To: Thibodeau, Lee P CIV USARMY CENAE (USA) <1 ee. P.'Thibodeau (a) usace. armv. mil>
Cc: Mueller, Katelyn E CIV USARMY CENAE (USA)
Subject: FW: Draft "Coastal Resiliency" Language
Hi Lee,
-------
Please see note from Jim below regarding potential for flooding from raising of final grade, specific
to Beacon point.
I agree with Jim's proposed statements:
(1) Filling will have "negligible" impact on flood storage, and
(2) Filling will have "negligible" impact on flood velocity and "no adverse" impact on abutters.
I just want to run this by you and see if you're in agreement. I'm glad we stayed away from pushing
the raised elevation to the west (as you and Kate recommended) as to not create any drainage
issues.
Thanks,
Mike
Mike Looney, PE
Project Manager
Programs/Project Management Division
USAGE New England District
696 Virginia Rd
Concord, MA 01742
Michaels. I oonev(S)usace. armv. mil
P: 978-318-8380
From: DiLorenzo, James
Sent: Tuesday, December 6, 2022 1:17 PM
To: Looney, Michael S CIV USARMY CENAE (USA)
Cc: Allevo, Anthony
Subject: [Non-DoD Source] Draft "Coastal Resiliency" Language
Hi Mike,
As we discussed, attached is language drafted by EPA's legal office regarding coastal resiliency. This
was drafted for the pending 0U5 ROD but will apply to the pending 0U6 ESD for Beacon Point and
Lockwood.
My concern is specific to the first two redline bullets:
Filling will only have a de minimis impact on flood storage.
Filling will only have a de minimis impact on flood velocity and ancillary
-------
impacts on abutters.
Use of the words "de minimis" and "ancillary" in these statements indicates
that there will be impacts to abutters. If there are any impacts to abutters
predicted., we should not raise the elevation at all. Based on USACE's analysis.,
I'm hoping we can instead state the following or something similar:
1. Filling will have "negligible" impact on flood storage, and
2. Filling will have "negligible" impact on flood velocity and "no adverse"
impact on abutters.
Thanks,
Jim
James M. DiLorenzo
Superfund Project Manager
EPA Region 1 - New England
5 Post Office Square (OSRR07-4)
Boston, MA 02109 - 3912
dilorenzo.iim(a)eDa.aov
(617)918-1247
-------
From:
To:
Subject:
Date:
Attachments:
Ailevo. Anthony
DiLorenzo, James
Fw: Raymark, Remediation Activities proposed for Beacon Point
Tuesday, December 13, 2022 5:49:32 AM
imaqeOOl.pnq
RMK-BP DRAFT-04NQV ml comment.pdf
Jim,
Below is the Beacon Point concurrence e-mail from Sue Jacobson.
Tony Allevo
DEEP
From: Jacobson, Susan
Sent: Friday, December 9, 2022 11:07 AM
To: Allevo, Anthony
Subject: Raymark, Remediation Activities proposed for Beacon Point
Hello Tony, Staff with the Land and Water Resources Division (LWRD) have reviewed
the attached plans, "Remedial Excavation Plan, Beacon Point", sheet C-101 and
"Grading and Restoration Plan, Beacon Point", sheet C-102 for proposed shoreline
modifications related to remediation of the site. Based on the information provided,
LWRD concurs with the determination that the proposed activities are consistent to
the maximum extent practicable with Connecticut's approved Coastal Zone
Management Program. For reference, the photograph below shows the pre-
remediation condition of the existing riprap shoreline. Please let me know if we can
be of further assistance. Thank you, Sue
-------
Susari Jacobson, Supervising Environmental Analyst
Land and Water Resources, Regulatory - West
Connecticut Department of Energy and Environmental Protection
79 Elm Street, Hartford, CT 06106-5127
P: 860-424-3693 (Tuesday and Wednesdays are best days to reach me in the office)
-------
Connecticut Department of
ENERGY &
ENVIRONMENTAL
PROTECTION
79 Elm Street Hartford, CT 06106-5127 www.ct.gov/deep Affirmative Action/Equal Opportunity Employer
Memo
To: Tony Allevo, Environmental Analyst, Remediation Division, SC
From: Sue Jacobson, Supervising Environmental Analyst, Land and Water Resources
Division
CC:
Date: 12/13/2022
Re: Raymark Remediation of Tidal Wetlands, Area 6
Hi Tony, The following mitigation guidance is offered in response to remediation proposed
within regulated tidal wetlands.
Existing Tidal Wetlands
In attached Figure 6, tidal wetlands are those areas identified as estuarine and growing tidal
wetland vegetation as defined pursuant to CGS Sec. 22a-29(2) - the plant list is provided in
the attached Reference for Regulatory Jurisdiction in Tidal Waters and Wetlands. For
historical documentation related to the placement of fill at this site, the shaded area below
1
-------
The upland limit of tidal wetlands is one foot above local extreme high water, Connecticut
General Statutes (CGS) Section 22a-29(2). Local extreme high water is defined in Section
22a-30-2(h) of the Tidal Wetlands Regulations as the elevation of the one-year frequency tidal
flood at a particular location as shown on the most recently adopted U.S. Army Corps of
Engineers tidal flood profile. The one-year frequency tidal flood elevation at this site is
approximately 5.8' NGVD.
In attached Figure 6, the existing elevations at plots 1, 5-7 and 13 support healthy tidal
wetland vegetation. Plots 1 and 13 appear to be between elevation 2' - 3', but the datum is
not noted on the plan.
Post Remediation Goal
The areas currently defined as tidal wetlands should remain tidal wetlands. Therefore, the
final elevation of the substrate should be no higher than 6.8" NGVD (one foot above local
extreme high water).
Suggestion - if a low-elevation bulkhead was installed around the marsh, there could be a
band of low marsh adjacent to the bulkhead before the elevation increases to a maximum of
6.8" NGVD toward the center of the tidal wetland. The height of the bulkhead should be
sufficient to maintain sediment at the current elevation of Plots 1 and 13 (where tidal wetland
vegetation is currently growing). In this manner, no area that is currently tidal wetland would
be lost to filling - we would have regulatory authority over any future activity proposed below
6.8" NGVD.
Page 2
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Connecticut Department of
Energy & Environmental Protection
Bureau of Water Protection & Land Reuse
Land & Water Resources Division
Reference for Regulatory Jurisdiction in Tidal Waters and Wetlands
In the tidal, coastal or navigable waters of the state waterward of the coastal jurisdiction line, the Department of
Energy and Environmental Protection regulates: dredging; the erection of structures; the placement of fill; and, work
incidental thereto pursuant to Connecticut General Statutes (CGS) Section 22a-359. Activities within tidal wetlands
are regulated pursuant to CGS Section 22a-32. Your activity may be regulated by both CGS Sections 221-359 and
22a-32.
One of the following regulatory limits will apply to your activity:
Coastal Jurisdiction Line (CJL) - For activities not within tidal wetlands, the CJL is the upland limit of state
regulatory jurisdiction CGS Section 22a-359(c).
Mean High Water (MHW) - For projects located upstream of a tide gate, dam or weir, use MHW. The use of MHW
would not apply to areas where a culvert, pipe, or narrow channel is causing a restriction as the purpose and function of
such devices are not to modify the flow of tidal water (their purpose is to convey water).
Tidal Wetland Boundary - Use the tidal wetland boundary if tidal wetland vegetation is located landward of CJL
or MHW. The upland limit of tidal wetlands is one foot above local extreme high water, Connecticut General
Statutes (CGS) Section 22a-29(2). Local extreme high water is defined in Section 22a-30-2(h) of the Tidal
Wetlands Regulations as the elevation of the one year frequency tidal flood at a particular location as shown on the
most recently adopted U.S. Army Corps of Engineers tidal flood profile.
In accordance with CGS Sec. 22a-29(2) "Wetland" means those areas which border on or lie beneath tidal waters,
such as, but not limited to banks, bogs, salt marsh, swamps, meadows, flats, or other low lands subject to tidal
action, including those areas now or formerly connected to tidal waters, and whose surface is at or below an
elevation of one foot above local extreme high water; and upon which may grow or be capable of growing some, but
not necessarily all, of the following:
Plant list from CGS Sec. 22a-29(2), taxonomy not updated.
Acer ru brunt
red maple
A cor us calamus
sweet flag
Agrostis palustris
bent grass
Alisma triviale
water-plantain
A In us rugosa
speckled alder
Alnus serrulata
common alder
Call a palustris
water-arum
Caltha palustris
marsh marigold
Clethra alnifolia
sweet pepper-bush
Cornus amomum
red willow
Cornus obliqua
silky dogwood
Cornus stolonifera
red osier
Distich lis spicata
spike grass
Dryopteris thelypteris
marsh fern
Eleocharis rostellata
spike rush
Eupatorium purpureum
joe pye weed
Eupatorium maculatum
Page 1 of 3
Rev. 04/01/20
-------
Eupatorium perfoliatum
thoroughwort
Heteranthera dubia
water stargrass
Hibiscus palustris
marshmallow
Hierochloe odorata
sweet grass
Impatiens capensis
jewelweed
Iris prismatica pursh
slender blue flag
Iris pseudacorus
yellow iris
Iris versicolor
blue flag
Ivafrutescens var. oraria
high-tide bush
Juncus effusus
soft rush
Juncus gerardi
black grass
Limonium carolinianum
sea lavender
Limonium nashi
Lythrum alatum,
loosestrife
lythrum salicaria
Mikania scandens
climbing hemp-weed
Nuphar variegatum nuphar advena
spatter-dock
Onoclea sensibilis
sensitive fern
Osmunda cinnamomea
cinnamon fern
Osmunda claytoniana
interrupted fern
Osmunda regalis
royal fern
Panicum virgatum
switch grass
Peltandra virginica
tuckahoe
Polygonum arifolium
halberd-leaved tearthumb
Polygonum sagittatum
arrow-leaved tearthumb
Pontederia cordata
pickcrchvced
Rhododendron viscosum
swamp honeysuckle
Rhus radicans
poison ivy
Rhus vernix
poison sumac
Rosa palustris
swamp rose
Sagittaria subulata,
arrowhead
Sagittaria graminea,
Sagittaria eatoni,
Sagittaria engelmanniania
Salicornia Europaea, and
saltworts
Salicornia bigelovii
Saururus cernuus
lizard's tail
Scirpus americana
chairmaker's rush
Scirpus robustus and
saltmarsh bulrushe s
Scirpus paludosus var. atlanticus
Sparganium eurycarpum,
bur-reed family
Sparganium androcladum,
Sparganium americanum,
Sparganium chlorocarpum,
Sparganium angustifolium,
Sparganium fluctuans, and
Sparganium minimum
Spartina alterniflora
saltmarsh grass
Spartina patens
salt meadow grass
Spartina pectinata
tall cordgrass
Spergularia marina
sand spurrey
Symplocarpusfoetidus
skunk cabbage
Typha angustifolia, and
cattails
Page 2 of 3
Rev. 04/01/20
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Typha latifolia
Veratrum viride
false hellebore
Vaccinium corymbosum
high-bush blueberry
Vaccinium macrocarpon
cranberry
Zannichellia palustris
horned pondweed
Zizania aquatica
wild rice
Section 22a-30-2(g) of the Tidal Wetlands Regulations defines "Areas formerly connected to tidal waters" as those
areas which have retained tidal wetland soil characteristics, which can support some but not necessarily all of the
vegetation specified in section 22a-29 of the General Statutes upon rccstablishment of a tidal connection, and to
which a tidal connection can be reestablished. Areas formerly connected to tidal waters shall not include:
(1) Areas which have been filled to an elevation greater than one foot above local extreme high water where such
filling occurred prior to 1972 or to the adoption of a tidal wetland map for such area pursuant to CGS 22a-30,
whichever is later;
(2) Areas to which a tidal connection has been permanently blocked or severed and where re-establishment of a
tidal connection would endanger existing structures for which alternative means of protection such as floodproofing
and elevation arc not feasible; or
(3) Areas which arc no longer wetland but which are another coastal resource as defined by CGS 22a-93 and
which function as a healthy, stable habitat.
Page 3 of 3
Rev. 04/01/20
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wmm
Legend
~ Plot Locations
A Wetland Flags
Contours
Contour 1 ft
Contour 5 ft
Ordinary High Water
OU6 Boundary
Wetland Boundary
Habitat Cover Types
Adjacent Upland Areas
Bl Building
Paved
Lawn/Landscaped
V, V Early Succession/Scrub Shrub
' / Upland Forest
Coward in Wetland Classification
, Intertidal, unconsolidated bottom
, Intertid al, emergent - Panne
, Intertidal, emergent - Low Marsh
, Intertidal, emergent - Low Marsh/Phrag
, Intertidal, emergent - High Marsh
, Intertidal, emergent - High Marsh/Phrag
, Intertidal, scrub-shrub
Palustrine emergent wetland - Phragmites
Palustrine emergent/scrub-shrub wetland
Palustrine scrub-shrub wetland
Map Location
40
80
160
\Feet
I N
A
Map Projection: State Plane, NAD 83, feet.
Image Source: USGS Topographic Quadrangle Bridgeport and Milford, CT.
Operable Unit #6
Area 6 - Lockwood Avenue
Wetland Delineation Report
Field Delineated Wetland Boundaries
Raymark Superfund Site
Stratford, Connecticut
AZCOM
Figure 6
12/19/2019
Project#: 60548556.3.3
-------
Plot data used in quantitative assessement o
'vegetation communities in OU-6.
Plot
Species
Midpoint
LAYER
Plot type
Habitat
16
Acer platanoides
38
T
5x5
Forested Upland
W2-U
W2-U
W2-U
W2-U
W2-U
W2-U
Toxicodendron radicans
63
V
ACOE
Forested Upland
Area 6
1
Spartina alterniflora
85.5
H
5x5
Estuarine
2
Bacchus halimifolia
63
S
5x5
Estuarine
2
Iva frutescens
3
S
5x5
Estuarine
2
Phragmites australis
10.5
H
5x5
Estuarine
-------
Plot
2
3
3
4
4
4
4
5
5
5
6
6
6
6
6
7
7
7
7
8
8
8
9
9
10
10
11
11
12
12
13
13
13
13
14
14
14
35
36
36
37
37
37
38
38
3lot data used in quantitative assessement o
vegetation communities in QU-6.
Species
Midpoint
LAYER
Plot type
Habitat
Toxicodendron radicans
20.5
V
5x5
Estuarine
Phragmites australis
85.5
5x5
Wetlands W1A PEM/SS
Toxicodendron radicans
V
5x5
Wetlands W1A PEM/SS
Carex scoparia
85.5
5x5
Wetlands W1A PEM/SS
Lysimachia terrestris
5x5
Wetlands W1A PEM/SS
Phragmites australis
0.5
5x5
Wetlands W1A PEM/SS
Solidago rugosa
5x5
Wetlands W1A PEM/SS
Distichlis spicata
63
5x5
Estuarine
Phragmites australis
20.5
5x5
Estuarine
Spartina patens
10.5
5x5
Estuarine
Distichlis spicata
63
5x5
Estuarine
Limonium carolinianum
38
5x5
Estuarine
Phragmites australis
10.5
5x5
Estuarine
Spartina alterniflora
5x5
Estuarine
Spartina patens
20.5
5x5
Estuarine
Distichlis spicata
85.5
5x5
Estuarine
Phragmites australis
10.5
5x5
Estuarine
Salicornia sp.
5x5
Estuarine
Spartina patens
10.5
5x5
Estuarine
Bacchus halimifolia
20.5
5x5
Estuarine
Iva frutescens
10.5
5x5
Estuarine
Phragmites australis
85.5
5x5
Estuarine
Bacchus halimifolia
63
5x5
Estuarine
Phragmites australis
38
5x5
Estuarine
Iva frutescens
20.5
5x5
Estuarine
Phragmites australis
63
5x5
Estuarine
Schoenoplectus robustus
20.5
5x5
Estuarine
Spartina alterniflora
63
5x5
Estuarine
Phragmites australis
85.5
5x5
Palustrine
Solidago sempervirens
5x5
Palustrine
Bacchus halimifolia
10.5
5x5
Estuarine
Iva frutescens
5x5
Estuarine
Spartina alterniflora
20.5
5x5
Estuarine
Spartina patens
85.5
5x5
Estuarine
Iva frutescens
38
5x5
Palustrine
Phragmites australis
63
5x5
Palustrine
Solidago sempervirens
10.5
5x5
Palustrine
Phragmites australis
98
5X5
Estuarine
Phragmites australis
85.5
5X5
Estuarine
Schoenoplectus robustus
10.5
5X5
Estuarine
Asterspp
5X5
Estuarine
Phragmites australis
20.5
5X5
Estuarine
Schoenoplectus robustus
63
5X5
Estuarine
Betula papyrifera
10.5
5X5
Forested Upland
Lonicera japonica
10.5
V
5X5
Forested Upland
-------
Plot data used in quantitative assessement o
'vegetation communities in OU-6.
Plot
Species
Midpoint
LAYER
Plot type
Habitat
38
Paulownia tomentosa
63
T
5X5
Forested Upland
38
Prun us serotina
10.5
S
5X5
Forested Upland
38
Quercus rubra
3
S
5X5
Forested Upland
38
Rosa multiflora
85.5
s
5X5
Forested Upland
38
Toxicodendron radicans
20.5
V
5X5
Forested Upland
W1A-U
Acer platanoides
10.5
s
ACOE
Forested Upland
W1A-U
Celastrus orbiculatus
20.5
V
ACOE
Forested Upland
W1A-U
Parthenocissus quinquefolia
10.5
V
ACOE
Forested Upland
W1A-U
Paulownia tomentosa
38
T
ACOE
Forested Upland
W1A-U
Rhus typhina
10.5
s
ACOE
Forested Upland
W1A-U
Robinia pseudoacacia
10.5
s
ACOE
Forested Upland
W1A-U
Rosa multiflora
38
s
ACOE
Forested Upland
W1A-U
Solidaqo ruqosa
3
H
ACOE
Forested Upland
W1A-W
Acer rubrum
20.5
S
ACOE
Wetlands W1A PEM/SS
W1A-W
Phraqmites australis
85.5
H
ACOE
Wetlands W1A PEM/SS
W1A-W
Toxicodendron radicans
10.5
V
ACOE
Wetlands W1A PEM/SS
Area 7
39
Braccharis halimfolia
20.5
S
5X5
Estuarine
39
Iva frutescens
38
S
5X5
Estuarine
39
Phraqmites australis
10.5
H
5X5
Estuarine
39
Solidaqo
3
H
5X5
Estuarine
40
Alliaria petiolata
10.5
H
5X5
Early succession/scrub-shrub
40
Allium sp.
20.5
H
5X5
Early succession/scrub-shrub
40
Celtis occidentalis
20.5
S
5X5
Early succession/scrub-shrub
40
Galium concinnum
10.5
H
5X5
Early succession/scrub-shrub
40
Malus sp.
10.5
S
5X5
Early succession/scrub-shrub
40
Paulownia tomentosa
20.5
T
5X5
Early succession/scrub-shrub
40
Phraqmites australis
3
H
5X5
Early succession/scrub-shrub
40
Prun us serotina
3
S
5X5
Early succession/scrub-shrub
BEW1-U
Dactylis glomerata
10.5
H
ACOE
Upland field
BEW1-U
Linaria vulgaris
3
H
ACOE
Upland field
BEW1-U
Plantago lanceolata
63
H
ACOE
Upland field
BEW1-U
Trifolium pratense
10.5
H
ACOE
Upland field
BEW1-U
Vicia lutea
3
H
ACOE
Upland field
BEW1-W
Distichlis spicata
63
H
ACOE
Estuarine
BEW1-W
Iva frutescens
10.5
S
ACOE
Estuarine
BEW1-W
Limonium carolinianum
20.5
H
ACOE
Estuarine
BEW1-W
Phragmites australis
10.5
H
ACOE
Estuarine
BEW1-W
Plantago maritima
10.5
H
ACOE
Estuarine
BEW2-U
Acer platanoides
3
S
ACOE
Early succession/scrub-shrub
BEW2-U
Artemesia sp.
38
H
ACOE
Early succession/scrub-shrub
BEW2-U
Celastrus orbiculatus
10.5
V
ACOE
Early succession/scrub-shrub
BEW2-U
Eleagnus angustifolia
3
S
ACOE
Early succession/scrub-shrub
BEW2-U
Lonicera tatarica
10.5
S
ACOE
Early succession/scrub-shrub
BEW2-U
Malus sp.
0.5
S
ACOE
Early succession/scrub-shrub
-------
APPENDIX B
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 1
^ ^ 5 Post Office Square, Suite 100
^PROl# Boston, MA 02109-3912
Memorandum
Date: August 7, 2023
Subject: Raymark Superfund Site
Appendix B: Storm water Memorandum for Explanation of Significant
Differences - Raymark Industries Superfund Site - Stratford, Connecticut
To: File
From: Jim DiLorenzo, RPM
The purpose of this memorandum is to compile and document the management of
storm water as necessary for the construction of a low-permeability capping system at
Operable Unit 4 (OU4) for the Raymark Industries Superfund Site (Site). This memorandum
supports the significant change as documented in the associated Explanation of Significant
Differences (ESD) to make necessary improvements to the municipal storm water
management system in the T own of Stratford rather than manage storm water within the OU4
property through the construction of an underground vault system.
BACKGROUND
The remedy selected in the September 2016 Record of Decision (ROD) for OU4
included the consolidation and capping of Raymark Waste from the OU3 and OU6
properties. The 7.5-acre low-permeability hazardous waste capping system to be
constructed over the consolidated area to inhibit future leaching of contamination
will shed a significant volume of storm water. Modeling estimates a peak flow from a
10 or 25-year storm of 80 cubic feet per second.1 The ROD included construction of
a 485,000-cubic-foot underground vault (about 3.6 million gallons) to manage
storm water flow from the cap. This vault would have required a relatively large
footprint to install (approximately 250 feet long by 250 feet wide and 8 feet deep) as
well as an associated bio-retention area. The vault would have displaced an estimated
58,800 cubic yards of Raymark Waste.2 At the time of the ROD, it was estimated
that the relocation of this Raymark Waste along with the Raymark Waste to be
consolidated from OU3 and OU6 would have exceeded the capacity of OU4 by an
estimated 20,000 cubic yards, which would have been disposed at an off-site
hazardous waste facility at a significant cost. The vault would have also required
significant operation and maintenance costs. The capping and storm water vault
1 Piatt Street Stornnvatcr Drainage System (AECOM), Figure 3-5, March 25, 2020.
2 Raymark OU4 Feasibility Study. Appendix A, Table 1, June 2016.
1
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concept is included as Figure 1. A cross-section view is shown as Figure 2.
In consideration of these facts, the ROD included language stating that EP A would
explore alternatives to the storm water vault, including improvements to the existing
regional storm water infrastructure.
As part of the Remedial Design (RD), the United States Army Corps of Engineers
through their consultant, AECOM, performed an evaluation of the existing municipal
storm water system. OU4 is located within the 130-acre Piatt Street Drainage area.
This area is shown as Figure 3. The evaluation documented in a January 17, 2018
memorandum concluded that the existing 18" storm water culvert located on Frog
Pond Lane and the 12 cubic feet per second Piatt Street pump station were
inadequate to manage the storm water flow anticipated from OU4. The culvert system
discharged into an open channel prior to reaching the pump station. The open
channel was constricted by sediment and choked with vegetation. The evaluation
concluded that a new storm water conveyance line and pump station would be
required. The open channel would also need to be enlarged and lined with concrete
blocks to inhibit vegetative growth. In a February 1, 2018 email (attached), the
United States Army Corps of Engineers (USACE) recommended that the
construction of a new storm water conveyance line and pump station remain the
preferred option to manage storm water from OU4.
An analysis was performed to determine possible routes for the new approximately
2,000-foot-long storm water conveyance line. Three alternatives were evaluated and a
preferred route. Alternative 2, selected based on memorandums prepared by US ACE
on November 15 and December 1 1, 2018 (attached). A portion of this route required
installing the conveyance line on Avery Street which is a short residential road, but is
also the primary entrance for Ash croft Corporation. Installation of the conveyance
line on Avery Street would have been disruptive to homeowners and require
significant rerouting of existing utilities as well as constructing an alternative access
route for Ash croft Corporation. In an email dated June 2021, EPA identified an
alternate route through a private property located at 390 East Main Street to avoid
Avery Street. Easements were obtained with Ash croft Corporation and the private
property owner, and construction began in May 2022. Construction of the
storm water conveyance line including improvements to the open channel were
complete in July 2023. Construction of the storm water pump station is ongoing and
expected to be complete by December 2024. The final layout of the storm water
conveyance line and pump station is shown as Figure 4.
FIGURES
1. Capping and storm water vault concept drawing
2. Capping and storm water vault cross-section
3. Piatt Street Drainage Area
4. Stormwater conveyance line and pump station
2
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ATTACHMENTS
Memorandum from AECOM to US ACE evaluating existing municipal storm water
system, January 17, 2018.
Email from US ACE to EPA recommending construction of a new storm water
conveyance line and pump station rather than the vault, February 1, 2018.
Memorandum from US ACE evaluating storm water routes, November 15, 2018.
Memorandum from US ACE recommending Alternative 2 as the preferred
storm water route, December 11, 2018.
Email from EPA to US ACE recommending an alternative to the preferred
storm water conveyance line route to avoid Avery Street, June 3, 2021.
3
-------
A=COM
AECOM
250 Apollo Drive
Chelmsford, MA
978.905.2100 tel
DRAFT Memorandum
To
David Heislein, Engineering Technical Lead Page 1
United States Army Corps of Engineers (USACE)
CC
Michael Tuttle, USACE
Subject
Raymark OUs 3, 4, 6
DRAFT Preliminary Storm Water Analysis and Piatt Street Pump Station Evaluation
From
Yan Zhang, Richard Berlandy, Michael Doherty (AECOM)
Date
January 16, 2018
This preliminary memo outlines the evaluation of the existing Piatt Street Pump Station, Town of
Stratford storm water collection and conveyance system existing conditions and limitations of as-
built survey information, and proposes tasks required to be completed in support of the remedial
design for Raymark Superfund Site Operable Unit OU4. The Piatt Street Pump Station is currently
significantly undersized and this condition will only be exacerbated as a result of the design and
construction of the planned OU4 landfill cap and future redevelopment, as well as conveyance of
storm water from the former Contract Plating facility. In addition, the Town of Stratford storm water
collection and conveyance infrastructure in the vicinity of OU4 and watershed discharging into the
open channel conveyance system and Piatt Street Pump Station appears to be undersized. This
includes the storm water collection systems within East Main Street, Avery Street, Allyndale Drive,
East Parkway Drive and portions of Phillips Street and Beacon Street. The approximate limits of the
Piatt Street Pump Station are shown on Figure 1.
Existing Conditions
General Storm Water Management
Storm water runoff from OU4 drains eastward and crosses the East Main Street and the Ashcroft
Inc. facility (an OU6 property) before discharging into a drainage swale which flows approximately
northeastward to the Piatt Street Pump Station. During flood events, the pump station pumps the
flooding water to the Housatonic River which, at the project location, is under tidal influence from
Long Island Sound. In addition, the Town of Stratford is planning on redevelopment of the
neighboring Contract Plating Facility (an OU1 property) post remediation. The storm water runoff
from the Contract Plating Facility will drain through OU4 before discharging into the town's drainage
system. Currently, OU4 does not have an active storm water system and there is no existing
drainage system along Frog Pond Lane based on a preliminary field evaluation and Town of
Stratford municipal records (Figure 1).
The existing Town of Stratford as-builts and survey records associated with existing storm water
collection and conveyance infrastructure are not comprehensive and must be supplemented to
support the development and evaluation of storm water management evaluations and design of the
project.
-------
AECOM
2
Piatt Street Pump Station
The Town of Stratford owns and maintains a storm water pump station that was constructed in the
1970s, reportedly to provide flood protection for the As hero ft property and the East Main Street
railroad underpass. A condition assessment was performed by Diversified Technology Consultants
(DTC) in 2012 and modifications to the station were undertaken in 2013. The 2013 modifications
addressed the identified structural, mechanical, and electrical deficiencies, but did not increase
pump station capacity. Please note the DTC evaluation did not identify the pump station design
storm event or present a detailed quantitative analysis of estimated flows associated with discrete
storm events.
The Piatt Street storm water pump station is located approximately 150 feet east-southeasterly of
the eastern end of Piatt Street (Figure 1). The pump station is not accessible with a vehicle from
Piatt Street and must be accessed by driving to the eastern end of Avery Street, crossing the
Ashcroft, Inc. parking lot, and then traversing a 500 foot long gravel driveway to reach the pump
station. The pump station site is forested and unimproved except for a small perimeter around the
pump station. The pump station is approximately 115 feet from the closest residence at 77 Piatt
Street.
Attachment A contains photographs of the existing Piatt Street Pump Station and associated
drainage channels.
Storm water flows reach the pump station via a manmade open stream channel that extends
approximately 640 feet northeasterly from a storm drainage pipe outfall located just north of the
Ashcroft Inc. northern parking lot (Figure 1). Storm water flows from the pump station discharge to a
650 foot long drainage channel discharging into the Housatonic River.
The pump station is a concrete structure with a precast concrete roof that replaced a deteriorated
steel roof. Inside dimensions are 14'-10" wide by 7'-6" long. The station has a reported interior
height of approximately 16 feet in the pump chamber area and 13 feet in the through channel area
(Attachment A).
Storm water flows to the station are conveyed by a short 48-inch diameter reinforced concrete pipe
with a flared end section and a trash rack. The 48-inch pipe passes low flows through the pump
station to a 48-inch by 48-inch flap gate which is equipped with a side outlet overflow weir to the
pump chamber that contains two submersible non-clog pumps. Each pump is equipped with a 10-
inch diameter discharge pipe that terminates outside the station with a duck-bill style elastomeric
check valve. Each pump has a design capacity of 2,916 gallons per minute (gpm) [6.5 cubic feet per
second (cfs)] at 14 feet total dynamic head. Each pump is equipped with a 19.7 horsepower, 850
rpm, 208 volt, 3 phase, 60 hertz, submersible electric motor. The pumps are installed in a slide rail
configuration that allows for pump removal though the provided roof hatches for maintenance and
service without the need to enter the pump chamber.
As each pump is equipped with its own discharge pipe and not a common discharge header, the
pump station each pump has a firm pump capacity of 2,916 gpm or 6.5 cfs and a total pump station
capacity of 5,832 gpm or 13 cfs.
The Piatt Street station is supplied with electrical power by United Illuminating Company from three
120/208Y, 25 kVa pole mounted transformers located at the eastern end of Piatt Street. The pump
station meter, service entrance main circuit breaker, and power distribution panel are located
adjacent to the utility pole on a ground level unistrut frame. Electrical power and telephone service
-------
AECOM
3
to the station control panel, which is located on the pump station roof slab, are conveyed by an
underground duct bank system. No provisions have been made for pump station operation during
periods of electric utility power interruption.
The pump station control panel is located on the pump station roof within a NEMA 4X stainless steel
floor mounted enclosure and includes the pump disconnects, reduced voltage soft starters, pump
controls, and a telephone based alarm notification dialer. The pump station controls are arranged in
a lead / lag configuration which provides for operation of both pumps based upon float switches
located in the pump chamber.
The roof of the pump station is provided with a chain link fence and gate for security.
Estimated Storm Water Flows
Preliminary hydrologic analysis indicates that the contributing drainage area to the Piatt Street
Pump Station will be approximately 126.5 acres at a CN number of 67. Preliminary flowrates were
modeled using the United States Department of Agriculture, Natural Resources Conservation
Service, Technical Release 55 (TR55) Urban Hydrology for Small Watersheds software package.
Attachment B includes the TR55 model input and output summary report. Table 1 below provides
preliminary flow estimates based upon the following assumptions:
One lumped basin including the Contract Plating Site and potential adjacent property;
In order to be conservative, future development scenario is assumed for Contract Plating
without detention. A conceptual site design is included as Figure 2. Please note that Figure 2
includes detention, but this detention was not included in the storm water flow estimates;
Based on Northeast Regional Climate Center (NRCC) information; and,
No calibration was performed. A comparison to nearby drainage basins within the Town of
Stratford was performed and the results appear to be consistent with the results of the project
drainage basin analysis.
Table 1 - Piatt Street Pump Station - Estimated Contributing Drainage Area Flows
Storm Return Interval
Estimated Peak Flow Rate
CFS
GPM
10 - Year
99.04
44,452
25 - Year
149.42
67.064
50 - Year
215.11
96,548
100-Year
282.15
126.638
500 - Year
556 26
249,667
-------
AECOM
4
In comparing the total capacity of the existing Piatt Street storm water pump station (13 cfs) to the
estimated flows under all return periods, it is clearly evident that replacement of the existing pump
station is required.
Schedule
AECOM is currently preparing reports and design documents in support of the remediation and
restoration of OU3 (Ferry Creek) and OLJ6 properties in addition to the Raymark Waste
consolidation and capping design at OU4. The project schedule estimates completion of the
remedial design (OLJs 3, 4 and 6) in late December 2018 with remediation to begin in the spring of
2019. Consolidation of Raymark Waste at OU4 and the construction of the cap will require
improvements to the Town of Stratford storm water collection and conveyance system in this area
as well as replacement of the Piatt Street Pump Station in advance of the construction at OU4.
Please note we have assumed that the Seed Projects can proceed prior to the storm water
improvements. The pump station and storm water collection and conveyance infrastructure will be
required to accommodate the estimated flowrates presented in Table 1. For preliminary planning
purposes, it is anticipated that the storm water piping and structures will be required to be sized to
accommodate a 25 year return period consistent with the Connecticut Department of Transportation
(ConnDOT) guidance and the pump station will be sized to accommodate a 50 year return period.
Collection of the required survey information associated with the Town of Stratford storm water
collection and conveyance infrastructure in the project area, design of piping improvements and
required design of a new Piatt Street Pump Station are necessary elements to maintain the overall
project schedule. Remediation and restoration of OU3, OLJ6 properties and the consolidation of
Raymark Waste at OU4 and the construction of the cap which will allow future redevelopment of the
former ballfield and Contract Plating site will not be possible until accommodation of the resultant
storm water flows are addressed.
Recommendations
In order to maintain the project schedule the following steps are recommended to be initiated as
soon as possible:
Collect required survey information, including topography and property boundaries,
associated with the Town of Stratford storm water collection and conveyance system
(please see Attachment C for suggested scope) - proposed start date of January 29, 2018;
Review potential storm water piping configurations/routes at discharge from OU4 (please
see Figure 2 of Attachment C for potential alternatives) - proposed review meeting(s)
March 2018;
Evaluate and design new (if necessary) storm water collection and conveyance
infrastructure from OU4 to the Piatt Street Pump Station; and,
Begin new Piatt Street Pump Station design - proposed start date of March 15, 2018 and
completion November 1, 2018.
The design of a new pump station will likely require survey, wetland delineation, and habitat
assessment of the stream channel leading to the existing pump station as well as the discharge
channel to the Housatonic River.
-------
Figures
-------
Piatt Street
Pump Station
Long
Brook Park
Housatonic Ri
Facility-
Ashcroft
Town of Stratford
DP# /
The Dock
Shopping
Center
Vi/almar!1
vhopRite f Horn?1
Depot
Contract
Plating
N.iluies
^ 0 300 600 1,200
i\ Figure 1. Piatt Street Pump Station Drainage Area in I
1 inch = 600 feet
Legend
Catch Basins
ฆ
Manholes
Outfalls
Drainage Network
C3 Piatt St Drainage Basin
Contract-Plating
Parcel
Housatonic River 100-Year Floodplain
Wuschl1fp001\data\Projects\Govt\Projects\USACE New England HTRW 2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\Platt_Design_Alts_Fig1.mxd
-------
-------
Attachment A
Photo Log
-------
Client Name:
USACE
Site Location:
Stratford, CT
Project No.
60548556
AECOM
PHOTOGRAPHIC LOG
Photo No.
1
Date:
10/6/17
Direction Photo Taken:
Southwest
Description:
Piatt Street Pump Station
discharge
Photo No.
Date:
2
10/6/17
Direction Photo Taken:
Southeast
v ฆrt. ,\|W ; u^_ ^2II
bJEvS^jwni -91' ?ii. * vป i6nl3mF^*^eVt^Sฎ3w
1
I Description:
Piatt Street Pump Station
Electric Service Entrance
and Distribution Panels
/v ' :ฆ
'^kIIHbSI - Mi - MtW "
1
' }"'jr l '\. j; f '.* 'C^LMV' ' ปi .:
*:,;f' '7,
I
Attachment A - Storrriwater Tech Memo Photo Log.docx
1
-------
Client Name:
USACE
Site Location:
Stratford, CT
Project No.
60548556
AECOM
PHOTOGRAPHIC LOG
Photo No.
3
Date:
10/6/17
Direction Photo Taken:
East
Description:
Piatt Street Pump Station
control panel
Attachment A - Storrriwater Tech Memo Photo Log.docx
2
-------
Client Name:
USACE
Site Location:
Stratford, CT
Project No.
60548556
AECOM
PHOTOGRAPHIC LOG
Photo No.
5
Date:
10/6/17
Direction Photo Taken:
East
Description:
Piatt Street Pump Station
wet well
Photo No.
Date:
6
10/6/17
Direction Photo Taken:
North
Description:
Piatt Street Pump Station
discharge channel
"Br
mm . ; ' 9 ฆ
?ฆ-*. -m
Attachment A - Storrriwater Tech Memo Photo Log.docx
3
-------
AECOM
PHOTOGRAPHIC LOG
Client Name:
USACE
Site Location:
Stratford, CT
Project No.
60548556
Photo No.
7
Date:
10/6/17
Direction Photo Taken:
East
Description:
Piatt Street Pump Station
top and fencing
Photo No.
8
Date:
10/6/17
Direction Photo Taken:
East
Description:
Piatt Street Pump Station
entrance gate
Attachment A - Storrriwater Tech Memo Photo Log.docx
4
-------
Client Name:
USAGE
Site Location:
Stratford CT
Project No.
60548556
AECOM
PHOTOGRAPHIC LOG
Photo No.
9
Date:
10/6/17
Direction Photo Taken:
West
Description:
Ashcroft property parking
lot near Piatt Street Pump
Station entrance gate
Phot8 No.
10
Date:
10/6/17
Direction Photo Taken:
Northeast
Description:
Storm water discharge
headwall from Piatt Street
Attachment A - Storrriwater Tech Memo Photo Log.docx
5
-------
AECOM
PHOTOGRAPHIC LOG
Client Name:
USACE
Site Location:
Stratford, CT
Project No.
60548556
Photo No.
11
Date:
10/6/17
Direction Photo Taken:
South
Description
Stormwater Pump Station
Approach Channel
Photo No
12
Date:
10/6/17
Direction Photo Taken:
South
Description:
Storm drainage channel
discharge to pump station
approach channel
Attachment A - Stormwater Tech Memo Photo Log.docx
6
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Attachment B
Preliminary Stormwater Analysis and Piatt Street Pump
Station Evaluation
-------
Preliminary Stormwater Analysis and Piatt Street Pump
Station Evaluation
Raymark Operating Units 4 and 6
United States Army Corps of Engineers
November 21, 2017
Methodology Based on the USDA & NRCS Technical Release 55: Urban Hydrology for Small Watersheds
-------
Piatt Street Pump Station Drainage Area Stormwater Evaluation Calculations Performed on 11/21/17
Peak Runoff Calculation, in
CN =
67
Curve Number
S =
4.93
in
Slope
la =
0.99
in
Initial Abstractions
Drainage Area =
126.46
acres
Drainage Area =
0.20
sqm
Table 1. Peak Runoff Calculation of Piatt Street Pump Station Drainage Area
P Interval
24 hr P, in
Q Interval
Q, in
la/P
Complies
Fig 4-1
Tc
qu, csm/in
qp, cfs
P1
2.78
Q1
0.48
0.4
Yes
1.4
175
16.58
P2
3.39
Q2
0.79
0.3
Yes
1.3
230
35.86
P5
4.23
Q5
1.29
0.2
Yes
1.2
255
64.94
P10
5.00
Q10
1.80
0.2
Yes
1.1
278
99.04
P25
6.25
Q25
2.72
0.2
Yes
1.1
278
149.42
P50
7.40
Q50
3.63
0.1
Yes
1.0
300
215.11
P100
8.76
Q100
4.76
0.1
Yes
1.0
300
282.15
P200
10.39
Q200
6.17
0.1
Yes
0.9
330
402.48
P500
13.01
Q500
8.53
0.1
Yes
0.9
330
556.26
Note: Connecticut falls within the SCS Type III Curve. (Source: Exhibit 4-III in TR-55)
Table 2. Sub Areas of Ferry Creek
Location
Area, acres
CN
Tc, min
Tc, hr
FC Area 34
30
74
21.2
0.35
FC Area 16
80
81
22.4
0.37
Piatt St.
126.46
67
60.0
1.0
FC Area 2
177
80
90.0
1.5
Note: Comparison Between Results and EarthTech Report
Table 3. Peak Flows and Input Locations
Location
Flow, cfs
qpio
qp25
qp50
qp100
qp500
FC Area 34
52
65
78
93
119
FC Area 16
174
209
245
287
356
Piatt St.
99.04
149.42
215.11
282.15
556.26
FC Area 2
190
230
272
320
396
-------
Piatt Street Pump Station Drainage Area Stormwater Evaluation
Time of Concentration Calculation for overall Subbasin of Piatt St. Pump Station
Calculations Performed on 11/21/17
Table 1. Tc Calculation
P Interval
24 hr P, in
Tt, hr
Tc, hr
P1
2 78
0.63
1.38
0.36
P2
3 39
0.57
1.29
0.33
P5
4 23
0.51
1.20
0.29
P10
5.00
0.47
1.13
0.27
P25
6.25
0.42
1.05
0.24
P50
7.40
0.39
1.00
0.22
P100
8.76
0.35
0.95
0.20
P200
10.39
0.33
0.91
0.19
P500
13.01
0.29
0.85
0.17
Note: Precipitation Data Source is the Northeast Regional Climate Center
Table 2. Tt Segments Calculation
Segment
Length
Category
n
s
V
Tt (hr)
1
217.8
Sheet
0.4
0.02754821
*
2A
82.2
Sheet
0.15
0.00219051
*
2B
450.4
Shallow Concentrated
0.15
0.00219051
1.6
0.078
3
156.7
Shallow Concentrated
0.011
0.00319081
1.6
0.027
4
304.6
Shallow Concentrated
0.011
0.01149048
2.4
0.035
5
258.0
Shallow Concentrated
0.011
0.01
2.03
0.035
6
316.4
Shallow Concentrated
0.011
0.01
2.03
0.043
7
107.0
Shallow Concentrated
0.011
0.01
2.03
0.015
8
159.8
Shallow Concentrated
0.011
0.01
2.03
0.022
9
278.0
Shallow Concentrated
0.011
0.01
2.03
0.038
10
253.6
Shallow Concentrated
0.011
0.01
2.03
0.035
11
687.0
Open Channel
0.045
0.003
2.99
0.064
Table 3. Open Channel Velocity Calculation
k =
1.49
A =
46.5
sf
P =
21.5
sf
r =
2.16
ft
v =
2.99
ffc/s
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Attachment C
Town of Stratford Stormwater Infrastructure Survey
Suggested Scope
-------
Town of Stratford Stormwater Infrastructure Survey Suggested Scope
The current scope of work assumed that existing Town of Stratford electronic records with regard to
stormwater infrastructure would be sufficient to support the stormwater management system evaluation
tasks. AECOM has conducted data research with various sources and performed field reconnaissance
and determined that the existing Town data is inadequate, A survey of the municipal stormwater drainage
system in the area is required. To support the remedial design, the Town stormwater collection system
and the Piatt Street Pump Station base plan topography will need to be surveyed including the relevant
utilities. Figure 1 depicts the approximate limits of the required survey scope. The area shaded in green
on Figure 2 depicts the approximate limits of required topographic survey. Some limited access onto
private properties may be necessary.
The survey of the drainage system will be performed using GPS RTKwith a vertical tolerance of no more
than 1.5". Information on structure dimension, invert, material type, and pipe connections will be collected.
Information on the existing Piatt Street Pump Station will be collected.
The topographic and bathymetric (if necessary) survey will be conducted and post processed to produce
1' contours in AutoCAD Civil 3D. Within the topographic/bathymetric survey areas, field topographic
survey will locate pavement, curbs, utilities, trees, parking, fences, walks, curb cuts, culverts, wetland
flags, top and bottom bank of river and other pertinent site features, spot grades and elevation contours.
Field survey will determine utility structure rim and invert elevations, pipe size and material. Field survey
will include research of property boundaries.
Field level run will establish elevations based on the North American Vertical Datum of 1988. Horizontal
datum will be North American Datum of 1983.
Televised video inspection and/or dye testing of specific stormwater collection system piping may be
necessary following completion of the field survey activities.
-------
Figure 1 - Raymark - Town of Stratford Stormwater Collection System Survey
Approximate Limits
-------
Legend *?
Catch Basiri#
Manholes
Outfalls ^
5$r 6
Alternative f" ฃ
Alternative 2
Existing Drainage jy^ies
Q3 OU4&OU6
Contract-Plating
Parcel
Proposed Aerial Survey
Ashcroftlnc. Facility
Town^f ^Stratfordi 1>
u jh~DPm^-p nil
Note: Surrey area around the
Piatt Street Pump Station is
approximate and w|j likely be
reduced following discus^bns^
with CTDEEP Dam Safety.
.N> \
J JfBarnurr, Ave
Contract
Plating
N
A Figure 2. Piatt Street Drainage Improvement f^^sc^^oo Ujoo^
Design Alternatives
1 inch = 500 feet
\\uschl1fp001\data\Projects\Govt\Projects\USACE New England HTRW 2015\Task OrdersXTO 0005 Raymark\400_Technical\404_GIS\MXD\Platt_Design_Alts_Fig2.mxd
-------
From:
To:
Cc:
Subject:
Date:
Heislein, David E CIV USARMY CENAE fUS)
DiLorenzo. James
Tuttle. Michael R CIV USARMY CENAE fUS)
RE: Raymark Phase IB OU4 & Pump Station Alternative (UNCLASSIFIED)
Thursday, February 1, 2018 9:06:10 AM
Jim,
Talked with Mike Tuttle, Mike D and Greg yesterday afternoon. AECOM does not feel that all of the
surface water generated on the OU4 property could be infiltrated on site. Particularly if we include
the CP Site that is to pass through the OU4 site. We could go back to the vault, but the construction
cost of the vault and off-site disposal of the RW would be excessive, as we already discussed, and
was the reason for the change to the Piatt Street discharge. It would also require some additional
design work to go back to the vault approach and require a revised OU4 capping design.
One option Mike Tuttle has started to look at is a smaller pump station located on OU4 to only
handle the OU4 and CP water. This could be directly discharged into either Upper Ferry Creek or
down Avery Street (Town ROW) to the open channel or beyond the existing pump station. Concern
with the discharge to Upper Ferry Creek is that Salce is not designing their site to take this additional
water and there would be some concern with potential scouring of soil cover within the creek. We
would have to modify the ongoing modelling of the Ferry Creek system being done by AECOM. We
would also have to work around Long Brook Ave/Barnum Ave, jack under the rail road, work our way
through the shopping centers and then jack under 1-95 to reach Upper Ferry Creek. Not an easy feat
and potentially high design and construction costs. Also see significant schedule issues.
Option to discharge the water to the open channel at the end of Avery Street above the existing
pump station is not desirable as we would further overwhelm the undersized pump station.
Therefore we would need to discharge on the downgradient side of the Piatt Street Pump Station.
We would need to revise some of the design on OU4 to fit this pump station on site and may reduce
the volume of RW that can be placed on OU4, though nothing like the vault. Will incur long term
maintenance of the system as it would be located on OU4 (new Piatt St system to be maintained by
the Town).
In the end there are no great solutions to this problem. Taking out the concerns with schedule and
funding, the most desirable solution is the one currently proposed - 1 or 2 new storm water lines to
the open channel and a new Piatt Street Pump Station. Solves all the flooding currently occurring in
the area of OU4 and E. Main St by upgrading to a 25 year storm event, gets all the water off the CP
and OU4 sites, upgrades the pump station and leaves the pump station on Town land and Town
maintenance. Right now we think we can get this all designed and construction started in time to
support the work at OU4 and the CP site. Getting a revised schedule from AECOM by tomorrow and
will forward to you to see how this will fit in. This alternative does not resolve the funding limits for
this FY.
Note, AECOM does have some recommendations to reduce the cap design that will save some
construction funds, but that won't help with the design of the storm water conveyance system.
-------
Feel free to call me or Mike Tuttle regarding the options and we can discuss further.
David Heislein
Engineering Technical Lead
Engineering Division
U.S. Army Corps of Engineers
New England District
696 Virginia Road
Concord, MA 01742
David.F.Heislein@usace.armv.mil
Direct: 978-318-8177
From: DiLorenzo, James [mailto:dilorenzo.jim@epa.gov]
Sent: Wednesday, January 31, 2018 10:04 AM
To: Heislein, David E CIV USARMY CENAE (US)
Cc: Tuttle, Michael R CIV USARMY CENAE (US)
Subject: [Non-DoD Source] RE: Raymark Phase IB OU4 & Pump Station Alternative (UNCLASSIFIED)
Sounds good. Thank you for jumping on this.
Jim
From: Heislein, David E CIV USARMY CENAE (US) [mailto:David.E.Heislein@iJsace.armv.mill
Sent: Wednesday, January 31, 2018 9:44 AM
To: DiLorenzo, James
Cc: Tuttle, Michael R CIV USARMY CENAE (US)
Subject: Raymark Phase IB OU4 & Pump Station Alternative (UNCLASSIFIED)
CLASSIFICATION: UNCLASSIFIED
Jim, Per our discussion late yesterday I had a call with Mike Doherty, AECOM, early this morning. He
will be meeting with Yan at 9:00 today and will see if there might be some other lower cost
alternatives to consider before going ahead with the Piatt Street Pump Station survey and design. I
should be able to get back to you later today with AECOM's response.
David Heislein
Engineering Technical Lead
Engineering Division
U.S. Army Corps of Engineers
New England District
696 Virginia Road
Concord, MA 01742
David.E.Heislein@usace.armv.mil
-------
Direct: 978-318-8177
CLASSIFICATION: UNCLASSIFIED
-------
AECOM
AECOM
250 Apollo Drive
Chelmsford, MA
978 905 2100
tel
DRAFT Memorandum
To
David Heislein, Engineering Technical Lead
United States Army Corps of Engineers (USACE)
New England District
CC
Michael Looney, USACE
Subject
DRAFT Raymark Preliminary Storm Water Corridor Analysis and Recommendation
From
AECOM
Date
November 15, 2018
AECOM conducted an evaluation of potential corridors for the conveyance of storm water
generated from the Contract Plating and OU4 sites, associated with the Raymark Superfund Site
- Operational Units 3, 4 and 6. This memorandum provides an overview of the potential
conveyance corridors identified, a recommended conveyance corridor and the applicable design
criteria. As presented in this memorandum, we recommend selection of Alternative 2, which is
along the corridor of the existing conveyance system, across Frog Pond Lane through the Town of
Stratford Department of Public Works (DPW) property to Avery Street and into the open channel,
discharging through the Piatt Street Pump Station.
Stormwater Conveyance Corridor Alternatives
AECOM, USACE and EPA identified three potential stormwater conveyance corridor alternatives.
1. Across Frog Pond Lane to East Main Street and through the Ashcroft Industries
property to the open channel and Piatt Street Pump Station.
2. Across Frog Pond Lane through the Town of Stratford DPW property, down Avery
Street and into the open channel and Piatt Street Pump Station.
3. Across Frog Pond Lane and East Main Street, and along southern Ashcroft Inc. facility
(directly adjacent to the railroad) directly into the Housatonic River.
Figure 1 shows a depiction of the three conveyance alternatives.
Applicable OU4 Stormwater Conveyance Design Criteria
AECOM reviewed applicable regulations, technical guidance and reference documents to develop
the proposed engineering design criteria for the stormwater management infrastructure. The
proposed criteria are summarized below:
OU4 and Contract Plating properties stormwater - Attenuate 10-year, 24-hour stormwater
flow;
Affected local (Frog Pond Lane, Avery Street), and minor arterial (East Main Street) roads
- 25-year, 24-hour storm;
Open channel from Ashcroft outfall to Piatt Street Pump Station - 25-year, 24-hour storm;
Piatt Street Pump station - 25-year, 24-hour storm.
-------
AECOM
2
Preliminary Hvdroloaic Evaluation
Preliminary hydrologic evaluation of storm water runoff for Contract Plating, OU4, and nearby
contributing drainage areas was performed, based on the pre- and post-re mediation condition for
various design storms. The post-re mediation development layout on Contract Plating is based on
maximum 80% development level. Stormwater runoff associated with Contract Plating currently
discharges outside the Piatt Street drainage area. The proposed redevelopment of Contract
Plating and OU4 will redirect those flows through OU4 and into the existing conveyance system,
and will therefore increase the flow through that existing drainage system significantly.
Alternatives Analysis and Recommendation
A detailed concept evaluation of Alternatives 1 and 2 was conducted. Alternative 3 was eliminated
from consideration due to the complexity of its routing, the presence of existing utilities, the
potential need for a lift station, and existing environmental impacts to soil and groundwater along
the corridor.
Table 1 summarizes the major comparison between Alternative 1 and Alternative 2. AECOM
recommends the selection of Alternative 2 - DPW Lot through Avery Street for the following
reasons:
Limit required work to East Main Street and reduced traffic impacts;
Simplified design and construction of a gravity system anticipated to correspond to lower
construction and maintenance costs;
Reduce potential conflicts with existing utilities;
Greater elevation drop to support the gravity design flows; and
Simplified property easements to be obtained.
Figure 2 provides a profile of the recommended Alternative 2 alignment.
-------
AECOM
3
Table 1. Comparison of Storm water Conveyance Alignments
Evaluation Considerations
Alternative 1
Alternative 2
Elevation drop (ft)
9 6
11
Approximate New
Connecting Pipe
Corridor Length (ft)
(does not include
upgrading existing
pipes)
375
172
Estimated Existing
pipe length (ft)
1,345
1,634
Alignments
Potential Structures
1
1
Existing Structures
8
16
Grade cover range
(ft)
1.6-9.1
1.8-9.3
Ease to connect to
OU4
According to
proposed outfall
location an additional
375 feet of pipe are
needed to connect
172 feet of pipe to connect to
proposed outfall, heading
slightly upgradient
Street Crossing/traffic
Roads Affected: East
Main Street: major
road and intersection
at the railroad bridge,
266 feet, affects 4
structures.
Roads Affected: Frog Pond
Lane, East Main Street
(major road) at shortest
distance (90 feet), affects 3
structures, Avery Street
Additional property
involved
Ash croft Property
DPW Property and small
section of Ashcroft Property
Property/easement
Easement
Frog Pond Lane,
East Main Street and
Ash croft property
from East Main
Street to the Pump
Station.
Frog Pond Lane, East Main
Street, Avery Street, and
expansion of the existing
easement from the drainage
outfall to the Pump Station
Opportunity to alleviate localized flooding
Potential to address
flood complaints of
low lying area at
railroad/l-95
underpass
Potential to address flooding
problems within the existing
watershed and Ashcroft
parking lot; existing
alignment, to be verified by
modeling
-------
AECOM
5
Figures
-------
Piatt Street
Pump Station
Ash croft iTide Gate
AshcrofMnc. Facility C
XownroTSt ratf o rd ->
h \tDPW-jk; 1
Legend
Alternative 1
Alternative 2
Alternative 3
Potential Alt. 1 Pipe
Potential Alt. 2 Pipe
Potential Alt. 1 Structure
Proposed Discharge
PointifraS0U4
Surveyed Structures
Surveyed Pipes
OU4/OU6 Boundary
^ Figure 1 0 250 500 1,000
j\ Drainage Infrastructure Upstream of n peet
DRAFT /A the Piatt Street Pump Station
- > Date: 11/2/2018 Design Alternatives for OU4 Stormwater Runoff
P:\Govt\Projects\USACE New England HTRW 2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\DesignAlts_Figure_2018oct16.mxd
-------
* Piatt Stream
Pump Station
S^^Ashcroft Inc. Facility^
itownfof Stratford
^J^nalive 2
Potential Alt. 2 Pipe
Surveyed Structures
Surveyed Pipes
Propose dpisclrarg e
Point from 0U4
i
OU4/OU6 Boundary
N
A
Figure 2
0 250 500
1,000
iFfifit
DRAFT
A
Drainage Infrastructure Upstream of
A
Date: 11/2/2018
the Piatt Street Pump Station
Design Alternative 2
P:\Govt\Projects\USACE New England HTRW 2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\DesignAlts_Figure_Nov_Profile1 .mxd
-------
f
kPiatt Street
Pump Station
>\shcnoft IncTFacility
iTownrof Stratford
'emative 1
Potential Alt. 1 Pipe
Surveyed Structures
Surveyed Pipes
Proposed Discharge
ฆRp i ntff ro mlฉ U4
OU4/OU6 Boundary
ALTER HA:
east
STREET THROUGH ASHCR9FT PPORILE
SMSSt, [FT
N
A
Figure 3
0 250 500
1,000
DRAFT
A
Drainage Infrastructure Upstream of
iFhhI
A
the Piatt Street Pump Station
Date: 11/2/2018
Design Alternative 1
P:\Govt\Projects\USACE New England HTRW2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\DesignAlts_Figure_Nov_Profile1 .mxd
-------
Raymark Storm Water Management Corridor Analysis
Overview and Talking Points
December 2018
An evaluation of potential corridors for the conveyance of storm water generated from the Contract
Plating and OU4 sites, associated with the Raymark Superfund Site - Operational Units 3, 4 and 6 has
been conducted. Three potential storm water conveyance corridor alternatives were identified and
evaluated. The alternatives are identified below and depicted on Figure 1.
1. Across Frog Pond Lane to East Main Street and through the Ash croft Industries property to
the open channel and Piatt Street Pump Station.
2. Across Frog Pond Lane through the Town of Stratford DPW property, down Avery Street and
into the open channel and Piatt Street Pump Station.
3. Across Frog Pond Lane and East Main Street, and along southern Ash croft Inc. facility
(directly adjacent to the railroad) directly into the Housatonic River.
Alternative 2 is the selected option based on the following:
Limits disruption to the Ash croft facility.
Limits required work to East Main Street and reduced traffic impacts;
Simplifies design and construction of a gravity system anticipated to correspond to lower
construction and maintenance costs;
Reduces potential conflicts with existing utilities;
Greater elevation drop to support the gravity design flows; and
Simplifies property easements to be obtained.
Figure 2 includes a depiction of the estimated work area (or potential disturbance area) on the Ash croft
property along the north boundary. The selected alternative includes the following impacts and benefits
to the Ash croft facility:
Permanent (or temporary) easement associated with the likely dredging and widening of the open
channel may be required.
Limited and temporary impact to Avery Street entrance during installation of storm water piping
and structures.
Selected alternative likely to result in reduction of storm water volume in Ashcroft north parking lot
and along western storm water piping network adjacent to East Main Street.
Improvements to the open channel could be leveraged to include Ashcroft funded improvements
to the north parking lot storm water piping and structures network.
-------
Figure 1
Storm Water Corridor Alternatives
-------
Piatt Street
Pump Station
Ash croft-.Tide Gate
Ashcrpft'lnc. Facility C
-Xowntof Stratford-\ sS
Legend
Alternative 1
Alternative 2
Alternative 3
Potential Alt. 1 Pipe
Potential Alt. 2 Pipe
Potential Alt. 1 Structure
Proposed Discharge
Point from OU4
Surveyed Structures
Surveyed Pipes
OU4/OU6 Boundary
V Figure 1 0 250 500 1,000
A Drainage Infrastructure Upstream of peet
DRAFT m\ the Piatt Street Pump Station
' Date: 12/11/2018 Design Alternatives for OU4 Stormwater Runoff
P:\Govt\Projects\USACE New England HTRW 2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\DesignAlts_Figure_2018oct16.mxd
-------
Figure 2
Ashcroft Property - Estimated Work Area
-------
Piatt Street
Pump Station
Estimated Work Area
Ash croft-.Tide Gate
Ashcrpft'lnc. Facility C
-lovvnfof Stratford-\ sS
Legend
Surveyed Structures
Potential Alt. 1 Structure
Alternative 3
Alternative 1
Proposed Discharge
Point from OU4
Alternative 2
Surveyed Pipes
Potential Alt. 2 Pipe
Potential Alt. 1 Pipe
OU4/OU6 Boundary
V Figure 2 0 250 500 1,000
A Estimated Work Area peet
DRAFT m\ Ashcroft Property
' Date: 12/11/2018 Design Alternatives for OU4 Stormwater Runoff
P:\Govt\Projects\USACE New England HTRW 2015\Task Orders\TO 0005 Raymark\400_Technical\404_GIS\MXD\DesignAlts_Figure2_2018DEC11.mxd
-------
From:
To:
Cc:
Subject:
Date:
Attachments:
DiLorenzo. James
Loonev, Michael S CIV USARMY CENAE fUS) fMichaei.S.Loonev(a>usace.armv.mil)
Heislein. David E CIV USARMY CENAE CUS) fDavid.E.HeisleinOusace.armv.miD
Potential Stormwater Option - 390 E. Main Street
Monday, April 27, 2020 4:41:00 PM
DRAFT Proposed 390 EMAIN Conveyance Svstem.pdf
Hi Mike,
I have a concept for a potential optional route to avoid Avery Street all together. If viable, this option
would likely cost $50k or more for an easement, but it would likely still provide a net savings for the
government when you considerthe costs associated with digging up/repaving Avery, moving
utilities, providing alternate access for Ash croft and potential impacts to homeowners. If technically
viable, it would certainly appear to be an easier route.
I was first looking at this as a traffic alternate route for Ashcroft. Perhaps that could be an option as
well if the conveyance approach doesn't fly?
If AECOM and your construction group believe it could be technically viable, we could approach the
owner of 390 E. Main Street. Their driveway provides straight access from E. Main Street to
Ash crofts parking lot. I did some research, and this property is owned by a Mosque. Interesting that
they are trying to raise money to purchase the next door property for expansion and a new temple.
They may welcome our funds? (See attached figure with proposed location in yellow highlighter).
First question is this a technically viable option?
Thanks,
Jim
James M. DiLorenzo
Superfund Project Manager
EPA Region 1 - New England
5 Post Office Square (OSRR07-4)
Boston, MA 02109 - 3912
diiorenzo.iim&eDa.aov
(617)918-1247
-------
APPENDIX C
-------
Subject: Asbestos Contaminated Soil within CTDOT Right-of-Way in the
vicinity of 1-95, Exit 33 in Stratford
The Connecticut Department of Transportation (CTDOT) has found Asbestos Contaminated Soil
(ACS) within its Right-of-Way (ROW) in Stratford. The ACS was found during routine soil borings
conducted as part of preliminary design work in the vicinity Exit 33 on 1-95.
Note: ACS is not an asbestos-containing material (ACM) in accordance with Department of Public
Health (DPH) Regulations. Should soil commingled with ACM (i.e. building debris) be discovered,
State and Federal asbestos abatement regulations will apply.
The CTDOT is currently implementing additional protocols for all activities in the areas included on
the attached map entitled "Areas of Restricted Disturbance." This map indicates the areas where the
CTDOT has identified locations positive for the presence of ACS. All employers must take appropriate
precautions to protect their employees, subcontractors, and the general public during intrusive
activities within CTDOT's ROW. These precautions may include soil sampling and management,
employee training, and health and safety provisions.
Employee Health and Safety: CTDOT is providing this information so that your company can
comply with regulations concerning asbestos, including but not limited to the Federal
Occupational Health & Safety Administration regulations (29 CFR 1926.1101 (k)) and the
Regulations of Connecticut State Agencies Section 22a-174-18, which should not be
construed as a list of all pertinent regulations.
Public Safety - Dust Control and Perimeter Monitoring: Due to the health hazards
associated with asbestos, the Permittee shall take precautions to ensure that the public is not
exposed to asbestos fibers in the soil. As a part of this, the Permittee shall take actions to
ensure soil is maintained adequately wet to prevent the release of asbestos fibers. Water shall
be available for this purpose at all times during soil disruption activities within the DOT ROW.
Any time water is not available for this purpose, all work shall cease until it is again available.
The Permittee shall institute perimeter air monitoring to verify its work practices have been
adequate to ensure the protection of the public. Such perimeter monitoring shall be performed
between the regulated work area and any area which is open to public access (vehicular
traffic, sidewalks, buildings, etc.). Perimeter samples shall be located at points north, south,
east and west of the work area with an additional sample away from the immediate work area
to function as a background sample. These samples shall be run for the duration of the work
shift or 4 hours (whichever is greater) while the soil disturbance activities are being conducted
with a target sample volume of 1000L.
All air samples shall be collected following the collection techniques described in NIOSH
Method 7400, Issue 2, dated August 15, 1994. Battery powered low-volume (1-5 Ipm)
sampling pumps shall be utilized for the site perimeter sampling. Flow rates shall be both pre
and post sampling calibrated using a secondary standard rotameter, calibrated to a primary
standard within the previous 12 months. During the sampling time period the licensed CTDPH
Asbestos Project Monitor conducting the sampling shall periodically inspect the sample
cassette filters to ensure the filters do not become overloaded with dirt/particulate and shall
change sampling cassettes as necessary.
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All samples shall be delivered at the end of each work day via proper chain of custody
procedures to a CTDPH/AIHA accredited laboratory for analysis via Phase Contrast
Microscopy (PCM) following NIOSH Method 7400. Should PCM analysis of the site
background/perimeter samples be above the applicable EPA clearance/CTDPH reoccupancy
standard (0.01 f/cc), those samples shall be transferred via proper chain of custody procedures
to a CTDPH/AIHA accredited laboratory for analysis via Transmission Electron Microscopy
(TEM) following NIOSH Method 7402 for delineation of asbestos fibers. As soon as possible,
but within 24 hours, perimeter monitoring samples analytical results (PCM, and TEM as
necessary) shall be compared to the background sample(s) and the EPA clearance/CTDPH
reoccupancy standard of 0.01 f/cc to determine if there has been an impact outside the
immediate work area. The permittee shall immediately notify CTDOT of such exceedance and
corrective actions being implemented.
On-site Soil Management: All disturbed areas must be restored in a manner acceptable to
CTDOT. Any existing demarcation layer disturbed as a part of the work must be fully restored
by the Permittee. All soils placed above the demarcation layer must not contain asbestos.
Cross sections views of the three acceptable restoration methods are attached.
1. Cover the ACS with at least 15 centimeters (6 inches) of compacted nonasbestos-
containing material, and grow and maintain a cover of vegetation on the area adequate
to prevent exposure of the ACS material.
2. In erodible and other areas where vegetation would be difficult to maintain, cover the
ACS with at least 15 centimeters (6 inches) of compacted nonasbestos-containing
material topped with at least 8 additional centimeters (3 inches) of well-graded,
nonasbestos crushed rock instead of vegetation; or
3. Cover the ACS with at least 60 centimeters (2 feet) of compacted nonasbestos-
containing material, and maintain it to prevent exposure of the ACS.
Management and Disposal of Excess Soils: All excess soils generated from CTDOT's
property shall not be commingled with other soils until such soils undergo environmental
sampling by a qualified firm knowledgeable in asbestos contamination. Documented ACS will
be considered property of the Permittee and shall be disposed of at a landfill permitted to
accept such soil at the Permittee's cost.
As an alternative to these protective measures, the Permittee can undertake environmental sampling
for asbestos in the soil within the designated excavation limits prior to starting the work. All sampling
must be completed by a properly qualified firm knowledgeable in sample collection and preservation
methods. Laboratory data generated by such soil sampling must be submitted to CTDOT with a map
showing the location and depth where the sample was collected prior to starting work. Any detected
asbestos will cause full implementation of the above listed provisions.
For utility work, the Permittee may opt to line the entire excavated area with demarcation material and
replace all material surrounding the installation with nonasbestos-containing material. In this manner,
future maintenance of that utility installation will not involve these requirements. Documentation of
this shall be supplied to CTDOT and maintained in the utility company's files. Future encroachment
permit applications for work related to that installation shall also include this documentation.
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All Permittees must supply these requirements to its subcontractor(s) performing work within this
area but remains responsible for ensuring that requirements are met. All records for
perimeter air monitoring and soil disposal must be supplied to CTDOT at the completion of the
work. The permit bond will not be released prior to the submittal of all documentation.
Failure to fully implement requirements may result in forfeit of the bond, refusal by CTDOT to
issue future encroachment permits, or other penalties.
If you require additional information or would like a copy of the actual sampling results from
the CTDOT's investigation, please contact:
Mr. Adam G. Fox, P.E.
Transportation Principal Engineer
Environmental Compliance
Department of Transportation
2800 Berlin Turnpike, P.O. Box 317546
Newington, CT 06131-7546
adam.fox@ct.gov
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