2.1.1 Narrative
On 9 February 2010. the Director of the Office of Site Remediation and Restoration signed an Action Memorandum authorizing a time-critical removal action with an extramural removal project ceiling of $1,750,000.
On 18 March 2010, OSC Tsang, the Emergency Rapid Response Service (ERRS) Response Manager (RM) and members of the Superfund Technical Assistance and Response Team (START) conducted a site walk to verify site conditions and begin planning removal activities. The mobilization of personnel and equipment and the commencement of the removal action are currently on hold pending the receipt of the signed access agreements from the property owner and tenants.
A settlement agreement under Section 104(e)(6) and 122(h)(1) of the Comprehensive Environmental Compensation, and Liability Act of 1980, as amended ("CERCLA"), 42 U.S.C. §§ 9604(e)(6) and 9622(h)(1), for recovery of site-related costs and for access was signed by EPA, City of Middletown and Site owner RLO Properties in May 2012, and became effective on 20 August 2012. Clean up of the Site will proceed as an EPA Fund lead action.
2.1.2 Response Actions to Date
28 August 2009 - EPA and START collected 27 surface (0 to 6 inches below ground surface "bgs") soil samples from 24 locations in the northwestern portion of the Site (Area of Investigation No. 1). The objective of the sampling was to identify and document the surface soil conditions, and the sampling data would be used for public health evaluation by the CT Department of Public Health. The 27 surface soil samples (SS-01 through SS-27) were submitted to the EPA New England Regional Laboratory (NERL) for PCB and metals screening analysis. Samples were screened for PCBs and metals. Confirmation analyses were performed on selected surface soil screening samples.
The results of these surface soil samples detected the following:
-PCBs (Aroclor-1260) at 10 locations with a range of 0.31 ppm to 7.5 ppm, and six locations were above CT DEEP RSR Residential Direct Exposure Criteria (DEC) at 1 ppm.
-Arsenic was detected at two locations above CT RSR I/C standards at 11 ppm and 13 ppm.
-Lead was detected at all locations, but only one location exceeded CT RSR I/C standards at 1,600 ppm.
Based on the above-referenced sampling results, in October 2009, CTDPH issued a public health fact sheet to inform the residents and on-site tenants regarding the contamination found at the Site.
30 November and 4 December 2009 - EPA and START collected 226 surface soil samples from locations throughout the entire Site. All surface soil samples were submitted to the on-site EPA Mobile Laboratory for PCB and metal (XRF) screening analyses. Laboratory confirmatory analyses were performed on selected surface soil screening samples by NERL.
The results of the December 2009 sampling showed the following:
-SVOCs (benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, and bis(2-ethylhexyl)phthalate) at concentrations exceeding CT RSR I/C standards at a total of 79 locations throughout the Site.
-PCBs (Aroclor-1260) were detected at low levels at the majority of locations, and 130 locations were above CT RSR Residential standards at a range from 1 ppm to 270 ppm. Most of these locations were in the southern portion of the current exclusion zone, and in the orange-fenced area of the former investigation derived waste (IDW) drum storage area adjacent to the entrance of American Contractors' garage.
-Arsenic was detected at 14 locations above CT RSR I/C standards at a range of 10 ppm to 62 ppm. Most of these locations were in the central and northern portions of the Site.
In addition to the above surface soil sampling, three samples were sent to NERL for Toxicity Characteristic Leaching Procedure (TCLP) analysis. A second material storage inventory at Area 1 was conducted.
18 March 2010 - OSC Janis Tsang and START members conduct a site visit to photo-document site conditions and inventory the vehicles, debris piles, and other materials on site.
7 July 2010 - START members conduct a site visit to photo-document site conditions and inventory the vehicles, debris piles, and other materials on site.
3 May 2011 - Scott Wing of CTDEEP conducted a site visit and photo-documented the site conditons.
1 June to 29 August 2011 - The owner of the diner hired TANTARA Corporation of Worcester, MA to submit a plan to EPA, CTDPH and CTDEEP to remove the diner from the exclusion zone. The removal of the diner was conducted and completed on 29 August 2011 by TANTARA personnel who were OSHA 40-hour HazWoper trained.
23 February 2012 - Scott Wing of CTDEEP conducted a site visit and photodocumented the Site conditions.
17 and 20 September 2012 - EPA and START collected 205 surface soil samples from locations throughout the entire Site. The objective of the sampling was to identify the general area of the surface soil contamination so that EPA can set up the exclusion zone, contaminated reduction zone, clean and support zone accordingly. All surface soil samples were submitted to the on-site EPA Mobile Laboratory for PCB and metal (XRF) screening analyses. Confirmatory analyses were performed on selected surface soil screening samples by NERL.
The sampling results of the September 2012 sampling indicated the following:
-PCBs (Aroclor-1260) were detected at 66 locations in concentrations above CT RSR Residential standards at a range from 1 ppm to 35 ppm. Most of these locations were in the southern portion of the current exclusion zone, and in the fence-in drum storage area adjacent to the entrance of American Contractors' garage.
-Arsenic was detected at 13 locations above CT RSR I/C standards at a range of 13 ppm to 136 ppm. Most of these locations were in the central and northern portions of the site.
-Lead was detected at all locations, but only two locations exceeded CT RSR I/C standards at a range of 1,000 ppm to 2,300 ppm. Both of these locations are in the southern portion of the exclusion zone.
In addition, EPA/START photodocumented the site conditions, and conducted an inventory of debris piles, junk cars, and other miscellaneous materials currently staged within Area 1.
17 and 18 September 2012 – The EPA Emergency Rapid Response Service Contractor (ERRS) mobilized to the Site to conduct brush clearing activities near the River Road Site entrance to allow the establishment of Site entry/access, and to clear areas where miscellaneous junk automobiles are located to facilitate a better visual inventory and assessment of the vehicles.
3 and 4 October 2012 – ERRS mobilized to the Site to collect samples from debris piles and IDW drums for disposal analyses.
20 November 2012 – START member Sharp, OSC Allen Jarrell, and ERRS RM Joe Overend meet to inspect the Site, review the September 2012 sampling results, and discuss the next steps for the Removal Action.
26 November 2012 - OSC Allen Jarrell and ERRS mobilized to the Site for the load-out of the thirteen IDW drums to United Oil Recovery Inc. of Meriden, CT for disposal.
2.1.3. Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Settlement Agreement between EPA, City of Middletown and RLO Properties, Inc. became effective on 20 August 2012. On 23 August 2012, the City of Middletown submitted a $2.8 million settlement payment to EPA under the terms of the Agreement.
2.1.4 Progress Metrics
Thirteen IDW drums were shipped to United Oil Recovery for off-site disposal during this reporting period.
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