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).  It is believed that 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 17 May 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
(6) CT RSR Residential DEC standard for PCBs is 1 ppm.  This standard applies to PCBs under CT RSR Regulation 22a-133k-2(b)(2)(B)

* 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 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.