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.
A settlement agreement under Section 104(e)(6) and 122(h)(1) of the Comprehensive Environmental Response, 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, the 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.
On 8 July 2013, EPA and contractors mobilized to the Site to commence the removal action.
2.1.2 Response Actions to Date
Since the issuance of the last POLREP, EPA OSC, EPA ERT, START and ERRS have performed the following activities:
15-19 July 2013
ERRS continued to set up the support zone, clear brush, and construct a decontamination pad at the southern end of the exclusion zone. ERRS began decontamination of the antique cars within the exclusion zone. A total of 24 vehicles were decontaminated and relocated to the staging area this week. START collected groundwater samples from monitoring wells ERT-01 through ERT-12 and submitted samples to NERL for VOC and SVOC analyses.
22-26 July 2013
ERRS continued the decontamination of the antique cars within the exclusion zone. A total of seven (7) vehicles were decontaminated and relocated to the staging area this week. ERRS decontaminated all scrap metal within the exclusion zone and relocated them to the staging area by the orange temporary fence. ERRS also consolidated all wood debris on-site and relocated asphalt milling (Pile #23) outside the exclusion zone. In addition, START conducted perimeter air monitoring and also collected bulk samples from concrete and clay piping onsite and submitted the samples to an outside laboratory for asbestos analysis using polarized light microscopy (PLM). START and ERRS posted “No Trespassing” signs along the drainage ditch.
Lead OSC Tsang conducted a conference call with personnel from START, EPA, and CTDEEP Solid Waste to discuss roles and responsibilities of the current property owner, the City of Middletown, and any potential future property owners with regard to any applicable post removal requirements for municipal solid waste landfill closure and long-term monitoring under CTDEEP regulations.
29 July – 2 August 2013
ERRS continued the decontamination of the personal property owned by the Site property owner including 15 jersey barriers, 39 concrete blocks, and four (4) pieces of brownstone, and moved these to the staging area. START conducted perimeter air monitoring. Amy Vaillancourt and Jill Libby of Tighe and Bond, a consultant for the City of Middletown, stopped by the Site and met with Alternate OSC Jarrell for an update.
5-9 August 2013
ERRS regraded a small area located at the northeastern portion of the exclusion zone by the orange temporary fence using crushed brick in order to accommodate truck access for load-out. ERRS decontaminated brownstone pieces (Pile #10) and relocated them to the construction and demolition (C&D) debris pile. ERRS began preparing the C&D debris piles for load out. START collected soil samples from one of the former wood debris pile (Pile #18) and submitted them to an ERRS-subcontracted laboratory for disposal profile analyses. START conducted perimeter air monitoring.
OSC Tsang conducted a conference call with personnel from START, ERRS, ERT/SERAS and ERRS subcontractor Hager-Richter GeoScience, Inc. (H-R) to discuss the upcoming geophysical survey at the Site, including different methods and techniques, data interpretation and site preparation.
OSC Tsang conducted a conference call with personnel from ERRS, START, ERT/SERAS, H-R and J.R. Marino, RP representative and Les Adams, American Contractors LLC representative, to discuss access coordination and relocation logistics for RP's and RP's tenants' personal property located along the Site building footprints in order for EPA and contractors to conduct utility locating and buried drum surveys.
OSC Tsang, EPA Community Involvement Coordinator (CIC) Emily Zimmerman, and START member Sharp attended a public meeting of the City of Middletown Riverfront Redevelopment Committee. OSC Tsang gave a presentation which provided a brief review of the site history, and the current and future planned removal activities at the Site.
12-16 August 2013
ERRS continued preparing C&D debris for load out. SERAS members collected pore water, surface water, and passive diffusion samples from drainage ditch and installed transducers in ERT-04, ERT-08, and ERT-09. START delivered samples to NERL for VOC and SVOC analyses. A total of 761 tons of C&D debris was shipped to Valley Sand and Gravel in North Haven, CT for recycle.
START conducted an inventory of all vehicles and other items located along the footprint of the building that may require temporary relocation during the upcoming geophysical survey. START delivered the inventory to American Contractors representative Les Adams for their review and confirmation. START conducted perimeter air monitoring.
19-23 August 2013
ERRS continued the load out of C&D debris. A total of 336 tons of C&D debris was shipped to Valley Sand and Gravel in North Haven, CT for recycling. ERRS began the load out of miscellaneous stockpiles of non-hazardous soil. A total of 306 tons of non-hazardous soil was shipped to Bondi Island Landfill located in Agawam, MA for reuse as landfill cover. EPA Health and Safety Officer Tony Honnellio arrived at the Site and conducted a Health and Safety audit.
Amy Vaillancourt stopped by the Site to meet with OSC Jarrell for an update.
26-30 August 2013
ERRS continued the load out of non-hazardous soil. A total of 928 tons of soil was shipped for disposal at Bondi Island Landfill located in Agawam, MA. Amy Vaillancourt stopped by the Site to meet with OSC Tsang for an update. ERRS T&D Coordinator collected wipe samples from the pontoon boat (owned by RP's tenant) and the loader tire (owner unknown) staged in the exclusion zone. Samples were analyzed for PCBs and SVOCs by York Analytical Labs. The sampling results showed that no PCBs or SVOCs were detected.
2-6 September 2013
ERRS continued the load out of C&D debris. A total of 321 tons of C&D debris was shipped to Valley Sand and Gravel in North Haven, CT for recycle. ERRS began preparing concrete and rebar debris for load out next week. ERRS decontaminated and staged the pontoon boat and miscellaneous items (blast mats, loader tires, broken metal cabinet etc.) outside the exclusion zone.
OSC Tsang conducted a meeting with ERRS RM Overend, START member Sharp, and J.R. Marino and Les Adams to discuss access coordination and relocation logistics for RP's and RP's tenants' personal property locating along the outside of the Site buildings in order for EPA and contractors to conduct utility locating and buried drum surveys.
9-13 September 2013
A total of four (4) roll-offs (estimated 100 tons) containing concrete and rebar was shipped to CWPM in New Britain, CT for recycling. Orange temporary fence with "No Trespassing" signs was erected and secured. A total of four (4) drums containing investigative derived wastes (IDW) remain in the exclusion zone awaiting disposal arrangement. As of 12 September, all ERRS personnel and all equipment except an office trailer were temporarily demobilized.
2.1.3. Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)
The Settlement Agreement between EPA, the 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