1.1.1 Incident Category

Time Critical Removal Action.

1.1.2 Site Description

The Omo Manufacturing Site (the Site) is 10.2-acre property which consists of two buildings (Buildings Nos. 1 and 2) on the eastern/southeastern sides of the property, an open yard to the west of the buildings, and a parking area/vacant lot east of Walnut Street.  Building No. 1 is located on the northeastern portion of the Site and is approximately 35,600 square feet.  Building No. 2 is located on the southeastern portion of the Site and is approximately 18,600 square feet. The property owner currently leases to several small businesses and private individuals that utilize the space for various type of activities including woodworking; autobody repair; construction contracting; landscaping company, antique collections; storage; and/or office space. 

Both on-site buildings have been modified and expanded in stages, creating numerous partitioned spaces that are linked through a maze of hallways and entrances.   The open yard, once known to be used as a landfill, is approximately 4-acres in size.  It is currently used for staging various pieces of heavy equipment, vehicles in various states of disrepair, disabled trailers, a “diner” trailer, and miscellaneous construction debris and materials such as fill, concrete blocks, and scrap steel.

A discontinuous fence surrounds the Site, with openings in the northwest corner and along the western edge of the Site.  An asphalt/dirt access road located immediately west of the buildings runs from the River Road entrance, south, following the edge of the two buildings and exiting on Walnut Street through a pair of locked swing gates.  Several above-ground storage tanks (ASTs) with approximately 5,000 gallons or greater are adjacent to the buildings.  The nearest residence is located east of Building No. 2.  A parking area is located east of the Building No. 1, east of Walnut Street.

1.1.2.1 Location

The Site is located at 50 Walnut Street, in Middletown, Middlesex County, Connecticut (CT).  The geographical coordinates of the site, as measured from its approximate center, are 41º 33′ 23.1″ north latitude and 72º 38′ 25.6″ west longitude. The property is identified by the City of Middletown (the City) Tax Assessor’s Map Number (No.) 34, as Block No. 24-7, Lot No. 9.  The Site is bordered to the north by River Road, railroad tracks, and the Connecticut River; to the east by Walnut Street and residential properties; to the south by Route 9 and state-owned land; and to the west by Sumner Brook, a small drainage ditch, Route 9, and state-owned land.

1.1.2.2 Description of Threat

The Site was originally the location of Omo Manufacturing Company, a rubber and artificial leather factory that was built in the late 1800s.  Prior to the 1930s, a 2- to 4-acre wetland area was located in the western portion.  From the early 1930s to approximately 1955, the wetlands were used by the City of Middletown (the City) as a municipal landfill (the City Landfill).  According to Mr. JR Marino, the City Landfill accepted industrial waste from various facilities. Waste oils, paints, and refuse from the on-site rubber manufacturing process were also allegedly disposed of west of Building No. 1.  In 1955, during the construction of Route 9, the State of Connecticut altered the topography, including modifying the course of Sumner Brook and constructing a drainage ditch, located west of and adjacent to the Site. 

On May 17, 1983, Connecticut Department of Environmental Protection (CT DEP) Waste Engineering & Enforcement Division (WEED) received a general environmental complaint alleging that a pit had been excavated near the western portion of the Site and that approximately 200 to 300 55-gallon drums of chemicals had been buried in the pit.  The complaint also cited several companies for disposing of waste on the Site, including Omo Manufacturing, Middletown Rubber, Middletown Industries, and Hildebrand Industries.  Chemicals allegedly disposed of include acetone, methyl ethyl ketone (MEK), naphthalene, and xylene.
 

1.1.3 Preliminary Removal Assessment/Removal Site Inspection Results

At the request of CTDEP the EPA Removal Program conducted a Preliminary Assessment/Site Investigation (PA/SI) from April to December 2009.  This included collecting surface and subsurface soil, groundwater, and buried container samples.  The sampling results shown in the table below confirmed the presence of hazardous materials including VOCs, SVOCs, PCBs, and metals.

Notes:

(1) CT RSR PMC = Connecticut Remediation Standards Regulation Pollutant Mobility Criteria (in part-per-million, ppm)

(2) CT RSR I/C DEC = Connecticut Remediation Standards Regulation Industrial/Commercial Direct Exposure Criteria (ppm)

(3) NA = Not available

(4) PMC for heavy metals and PCBs by Toxicity Characteristic Leachate Procedure (TCLP) or Synthetic Precipitation Leachate Procedure (SPLP) in milligram per liter

(5) ND = Not detected

* Total Xylene = M/P Xylene +Ortho Xylene lab result values

** Results of both field screening and fixed laboratory analysis for PCBs

*** Results of both field XRF screening and fixed laboratory analysis for metals

2.1.1 Narrative

On February 9, 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 March 18, 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.

2.1.2 Response Actions to Date

Since the referral of the Site by CTDEP in April 2009, EPA has conducted groundwater sampling of the on-site monitoring wells, geophysical survey utilizing EM-31 and magnetometer at the northwestern portion of the Site [herein described as Area of Investigation 1 (Area 1)], excavation of six (6) test pits in Area 1, sediment sampling at the drainage ditch and Sumner Brook, and surface soil sampling.

2.1.3. Enforcement Activities, Identity of Potentially Responsible Parties (PRPs)

The Site is owned by RLO Properties Inc., ℅ Mr. J.R. Marino.  Mrs. Tamba Marino is the president of American Contractors, LLC, which operates on the Site.  On March 15, 2010, EPA sent access request letters to the 14 business tenants. 

2.1.4 Progress Metrics

No off-site disposal of wastes was conducted during this reporting period.