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COMMUNITY RELATIONS PLAN

FOR THE

SOLVENTS RECOVERY SERVICE OF

NEW ENGLAND, INC. SUPERFUND SITE

SOUTHINGTON, CONNECTICUT

NUS Corporation

EPA Work Assignment No. 01-1 LOS

Contract No. 68-W8-0117

Project No. 0217

June 1991

NUS

CORPORATION

^ J A Halliburton Company

COMMUNITY RELATIONS PLAN

FOR THE

SQLV£!1IS RECOVERY SERVICE OF MEN ENGLAND, IMC. SUFESFUMD SITE


PBZPARED S I

NUS CORPORATION

> v^>

EPA Work Assignment No. 01-1L08

Contract No. 68-W8-0117

Project No. 0217

June 1991

Prepared byt Approved by:

Betsy Home Q^orge

> L ^ ^

TABLE OF CONTENTS

COMMnSITT RELATIONS PLAN

BOOsVEMXB SECaVERY SSCVICS OF SOSM EMUSLUSD, ZKC.


9KXMV PAGE

I. Overview of the Community Relations Plan 1

II. Site Background 3

III. Community Background 7

IV. Key Community Concerns 9

V. Objectives of the Community Relations Plan 12

VI. Future Community Relations Activities 12

APPENDIX A

APPENDIX B Key Contacts List 17

20

23

27

APPENDIX C Media Contacts

APPENDIX D Fact Sheet Comparing RCRA and Superfund

APPENDIX E Superfund Cleanup Process

NUMBER

Figure l SRSNE Site Map 2

Locations of Information Repositories

and for Public Meetings 16

Schedule of Community Relations Activities at SRSNE

29

FIGURES

PAGE

PRINTED ON RECYCLED PAPER

I. OVERVIEW OF THE COMMUNITY RELATIONS PLAN

This Community Relations Plan identifies current issues of

community concern regarding the Solvents Recovery Service of New

England, Inc. (SRSNE) Superfund hazardous waste site in

Southington, Connecticut and proposes activities to address these

concerns. These activities will be conducted by the United

States Environmental Protection Agency during remedial activities

conducted at the Superfund site.

This Community Relations Plan has been prepared to assist EPA in

developing a comprehensive community relations program for the

affected citizens of Southington. It addresses problems and key

issues identified in interviews with citizens and local and state

officials conducted in January 1991, at a public meeting in July

1990, through a review of the files, and in articles in local

newspapers. The activities proposed are designed to inform

interested citizens and officials about the progress of remedial

activities and to provide opportunities for the public to be

involved in planning those activities at the SRSNE site.

The remaining portions of the Plan include a discussion of the

site background, concerns about the site and how EPA proposes to

address those concerns, future community relations activities,

and appendices. A map of the SRSNE site can be found on page 2.

This Community Relations Plan is divided into the following

sections:

Site Background

Community Background

Key Community Concerns

Objectives of the Community Relations Program

Future Community Relations Activities

In addition, five appendices contain information to provide a

more detailed understanding of EPA's community relations efforts

for the SRSNE site.

EPA's Region I Office in Boston, Massachusetts, has overall

responsibility for managing the site. Susan Frank is the EPA

Superfund Community Relations Coordinator (CRC) from the Region I

Office of Public Affairs who will oversee all community relations

activities at the site as outlined in this Plan (see page 17 for

the CRC's address and telephone number).

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®

MICKEY'S AUTO BODY GARAGE

SOLVENTS RECOVERY SERVICE

OF NEW ENGLAND, INC.

STREE"̂ ANDERS

LEGEND SRSNE PROPERTY UNE

RAILROAD UNE

RIVER

NOTE: ALL LOCATIONS AREA PPROXIMATE

400 800

APPROXIMATE SCALE IN FEET

FIGURE 1

SRSNE SITE MAP

FIGURE 1

SRSNE SITE MAP

-2

II. SITE BACKGROUND

The SRSNE Superfund site is located off Route 10 (Queen Street)

in central Southington, Connecticut, just south of Lazy Lane and

west of the Quinnipiac River. In 1988, with the acquisition of

the former Cianci Construction property immediately to its east,

the SRSNE site expanded from 3.3 acres to approximately 13.6

acres. The current structures at the site include an office, a

drum storage area, a process area, a tank car and trailer parking

area, and two fuel blending tanks.

Since 1955, SRSNE operated a solvents recovery facility at the

Lazy Lane site. The major form of operation at the site was

processing used solvents, by distilling and recovering them, for

reuse by the original generator or for sale to other customers.

The distillation process generated a sludge by-product. More

recently the company's operations focused on fuel blending and

waste transfer. The Southington facility is no longer active,

having ceased operations on March 29, 1991. (See sections State

of Connecticut and Government Coordination on pages 4 and 5 for

additional detail.)

From 1955 to 1967, at least two unlined lagoons were used to

store or dispose of various solvent sludges and wastes. In 1967,

the lagoons were drained and covered with fill. In the 1960s and

early 1970s, an open pit incinerator was used to dispose of the

sludges. After the State of Connecticut ordered the incinerator

closed, the wastes were disposed of off-site.

In the late 1970s, Southington Town Production Wells No. 4 and 6,

both located less than a half mile from the SRSNE facility (see

the map on page 2), were shut down because of solvent

contamination. Environmental officials contended that SRSNE

caused the contamination in Well No. 6 and contributed to the

pollution in Well No. 4. Because of this threat to public health

and the environment, EPA placed the SRSNE site on the National

Priorities List, making it eligible for federal assistance for

study and cleanup.

Government Enforcement Actions Against SRSNE

Environmental Protection Agency

In 1979, EPA filed suit against SRSNE under the Resource

Conservation and Recovery Act (RCRA) for contaminating Production

Wells No. 4 and 6, and under the Clean Water Act for the

unpermitted discharge of pollutants into the Quinnipiac River.

The Southington Board of Water Commissioners and the Connecticut

Fund for the Environment later joined EPA in that action. The

1979 suit was amended in 1982 to include claims under the 1980

Superfund law. Before the case came to trial, an agreement,

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resulting in a consent decree, was reached in 1983. The consent

decree required SRSNE to make improvements to its solvents

handling procedures, to install an on-site groundwater recovery

and treatment system, and to construct an off-site interception

system to prevent contaminated groundwater from moving beyond the

facility boundaries. In November of 1983, SRSNE paid EPA a

$10,000 penalty for delay in submitting plans for the off-site

system.

Other efforts were made to force SRSNE to comply with federal

requirements. In May 1983, EPA ordered SRSNE to pay a $2500

penalty for its failure to submit a complete RCRA permit

application. In the spring of 1986, to meet the provisions of

the Hazardous and Solid Waste Amendments (HSWA) of 1984 (which

amended RCRA), EPA issued SRSNE an HSWA permit, which required

the company to submit a plan to clean up contaminated soils at

and around its facility. Despite several submissions of such a

plan, none were approvable by EPA due to a variety of

deficiencies.

State of Connecticut

In 1981, the Connecticut Department of Environmental Protection

(DEP) issued a Notice of Violation to SRSNE for accepting

hazardous wastes without manifests or shipping papers. In July

of 1983, the DEP issued an order requiring SRSNE to conduct an

investigation of soil contamination caused by the company's

operations and to undertake cleanup activities. A 1984 amendment

to the 1983 order required SRSNE to hire a consultant to

undertake the study. It also required SRSNE to remove sludge and

contaminated soil from the area where it was to construct new

buildings and a tank farm, under the terms of the then-pending

RCRA permit.

DEP issued the RCRA permit in January 1986. Among its many

provisions were requirements that SRSNE make major improvements

to its waste handling facilities, establish procedures for

dealing with emergency releases, and establish financial

responsibility requirements. In May 1987, the DEP referred SRSNE

to the State Attorney General for the company's failure to comply

with many of the provisions of its RCRA permit. Soon thereafter,

Connecticut filed suit against SRSNE for those violations. (See

the following section, Government Coordination, for recent

activity concerning this suit.)

Government Coordination

Throughout the decade since the federal and state governments

have attempted to compel SRSNE to clean up its facility and

operations, the company has alleged that the government

requirements have often been unclear or conflicting. Further

complicating the situation was the fact that the authority to

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administer the RCRA program in Connecticut reverted to EPA soon

after the DEP issued SRSNE its RCRA permit in 1986. When it

became clear that no unilateral effort would be successful, EPA

and the DEP planned a coordinated and comprehensive approach to

address further actions against SRSNE.

In the spring of 1988, EPA and the DEP met with SRSNE officials

to present them with a schedule for short-term operations and

safety improvements as well as longer-term activities that would

be incorporated into a modification of the 1983 consent decree.

These long-term actions were to include the performance by the

company of a Remedial Investigation/Feasibility Study (RI/FS) at

the facility. The RI determines the nature and extent of

contamination at the site; the FS analyzes cleanup alternatives

for the site. In August of 1988, negotiations were terminated

due to SRSNE's inadequate progress in implementing the short-term

improvements. EPA then obligated Superfund money to perform the

RI/FS, which is currently under way. (See Appendix E on page 27

for an overview of the Superfund process.)

Despite EPA and DEP efforts, SRSNE failed to come into compliance

with its existing agreements. As a result, on July 24, 1990, EPA

and the Department of Justice announced the filing of a suit

charging the company with violations of its RCRA and HSWA permits

and violations of RCRA's land disposal restriction regulations.

The suit also charged the company with liability for past costs

of $777,000 and future costs the United States would incur to

study and clean up the site. The suit requested that the Court

permanently close the SRSNE facility; impose penalties of $25,000

a day for each of SRSNE's violations of its permits and the RCRA

regulations; and require SRSNE to reimburse EPA for the cost of

investigating, designing, and implementing site cleanup. A

separate action requested the Court to compel SRSNE to comply

with the provisions of the 1983 consent decree. Currently the

suit before the federal District Court is in the discovery

process, which involves each of the parties seeking relevant

information from the other.

Pending the outcome of the federal government's suit for final

closure under RCRA, in January of 1991, Connecticut's Attorney

General filed a request for an injunction to temporarily close

SRSNE for its failure to meet the terms of its RCRA permit. In

February 1991, the State entered into a partial judgement,

requiring SRSNE to cease receipt of hazardous waste and its

treatment, storage and disposal by February 27, 1991. Further,

the company would be compelled to complete certain closure

activities including shipping all hazardous waste off site and

cleaning up certain areas of its facility by March 29, 1991.

Under this judgement, final closure would be triggered if any of

the following events occurs:

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1. SRSNE is not in complete compliance with its RCRA

permit by the time a decision is returned in favor of

the United States in the federal government's suit;

2. SRSNE does not have in effect adequate liability

insurance for sudden accidental occurrences, as

required by the RCRA permit, by May 28, 1991; or

3. SRSNE does not come into complete compliance with its

RCRA permit, by February 27, 1992, or if the company

does not obtain all Town planning and zoning approvals

necessary to comply with the terms of the RCRA permit,

by August 27, 1991.

As of May 29, 1991, SRSNE confirmed to the Attorney General of

the State of Connecticut that it had not been able to obtain the

insurance discussed in condition 2, above. SRSNE, therefore, is

legally obligated to close permanently its Southington facility.

Related Activities

Both EPA and the State of Connecticut are involved in other

activities that address potential contamination in the affected

area. These activities are outlined below.

Residential Well Testing

In the spring of 1990, the DEP initiated a round of well testing

for residents living near the SRSNE facility. Only one well,

belonging to Mickey's Auto Body, immediately north of and

adjacent to SRSNE (see the map on page 2) showed high levels of

trichloroethene (TCE). TCE is a volatile organic compound

commonly used in dry cleaning and metal degreasing.

As a result of concerns expressed during EPA's July 1990 public

informational meeting in Southington, more than 60 residential

wells were tested by EPA in October 1990. The results show that

seven residential wells had elevated levels of sodium; of these,

DEP is providing bottled water to one that has an occupant on a

sodium-restricted diet. Another had high solvent levels. DEP is

providing that residence with bottled water. An adjacent home

was also supplied with bottled water following an additional

sampling effort by the State two months later. The remaining

wells showed only trace levels or no contamination. All residents

whose wells were tested have been contacted by DEP or EPA.

Department of Health Services Survey

The Connecticut Department of Health Services initiated an

investigation in June of 1990 which included mapping incidences

of cancer in the Southington area. This effort resulted from the

-6

observations of a local resident who believed that there was a

higher than usual occurrence of cancer in the area. Further

information concerning this study can be obtained by contacting

Diane Aye at the Connecticut Department of Health Services. Her

address and telephone number are listed on page 17.

DEP RCRA Permitting

Since SRSNE's permit was due to expire in January 1991, it needed

to reapply to the permitting authority (in this case, EPA) at

least six months before the expiration date. (EPA administered

the RCRA permit program in Connecticut from January 1986 to

December 1990.) That application was received just prior to the

July 1990 public meeting where it was the subject of significant

discussion. EPA staff outlined the review process, including the

basic criteria against which all RCRA permit applications are

measured. The RCRA permitting procedure requires that a public

hearing be held once the regulatory agency has issued a proposed

finding.

SRSNE's permit reapplication was forwarded to the DEP following

Connecticut's regaining RCRA program authority last December.

Since the facility has since closed, the entire application is

not currently undergoing DEP review. However, a portion of the

application, the closure plan, is being actively studied.

Information concerning the status of the permit application can

be obtained by contacting Ross Bunnell of the DEP. His address

and telephone number are listed on page 17.

III. COMMUNITY BACKGROUND

Community Profile

The Town of Southington is located in Hartford County,

approximately ten miles southwest of Hartford. It is bordered on

the west by the Town of Wolcott, on the north by the Towns of

Bristol and Plainville, on the east by the Towns of New Britain,

Berlin, and Meriden, and on the south by the Town of Cheshire.

Southington is mainly residential, commercial/industrial with

some agricultural activity.

Southington has an area of 36.8 square miles. The 1990

population was 37,737. Southington's topography consists of

gently rolling hills with numerous level areas in the central

section. The Quinnipiac River and its tributaries are the Town's

principal drainage pathways.

The Town is governed by a council-manager form of government. A

nine member Town Council is elected at-large and appoints a full-

time administrator as Town Manager.

x.»,

>.̂

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Southington currently has two sites listed on EPA's National

Priorities List, SRSNE and the Old Southington Landfill. The

Landfill is located off Old Turnpike Road in the Plantsville

section of town. The Town of Southington and SRSNE have been

identified as parties responsible for the contamination at the

Landfill. Together with Pratt and Whitney, they are underwriting

the cost of studying how best to clean it up.

History of Community Involvement

When the Town's Production Wells No. 4 and 6 were closed in the

late 1970s, many Southington residents became concerned about the

SRSNE operation. A group called Southington Citizens Action

Group (SCAG) was established in 1979. Its focus was the effect

of the contamination on residential wells. Others who lived in

the vicinity of the site had been trying to curtail SRSNE's

operations since it began using the open pit incinerator in the

late 1960s. A community group calling itself Southington

Opposing Solvents was established in early 1990; it was renamed

Southington Association For the Environment (SAFE) in July 1990.

On July 26, 1990, two days after the federal government filed

suit against SRSNE, EPA held a public informational meeting at

the Southington High School to describe the cleanup process and

to discuss other issues regarding the SRSNE site. More than

three hundred residents attended the meeting.

Formal community relations activities conducted by EPA to date

are listed below.

May 21, 1984 EPA press release announcing the completion of the groundwater cleanup system well construction.

November 21, 1984 EPA press release announcing the start up of the groundwater cleanup system.

July 1990 EPA fact sheet announcing the start of the Remedial Investigation.

July 13, 1990 EPA press release announcing the July 26, 1990 public meeting.

July 24, 1990 EPA/Department of Justice press release and press conference announcing the filing of the federal suit against SRSNE.

July 26, 1990 EPA public meeting to describe the RI and to discuss related issues of interest to the community.

-8

August 23, 1990 EPA public notice regarding SAFE'S intent to

file a Technical Assistance Grant

application.

January 7-9, 1991 EPA conducted Community Relations Plan

interviews.

June 1991 Community Relations Plan issued.

A chart showing the scheduling of community relations activities

during the cleanup process is included in Appendix E on page 29.

Technical Assistance Grant Program

The Superfund Technical Assistance Grant (TAG) program was

established under the Superfund Amendments and Reauthorization

Act of 1986. These grants of up to $50,000 for each Superfund

site are designed to enable community groups to hire a technical

advisor or consultant to assist them in interpreting and

commenting on site findings and proposed cleanup actions.

During the July 1990 public meeting, SAFE presented EPA with a

Letter of Intent to apply for a Technical Assistance Grant. A

formal application was made in January 1991. EPA is currently

reviewing the application, and expects to award the grant by the

end of June 1991.

IV. KEY COMMUNITY CONCERNS

This section summarizes concerns expressed by residents, Town

officials, and representatives of community groups in interviews

conducted in Southington in January 1991, at the public

informational meeting in July 1990, as well as through a review

of EPA files and newspaper clippings.

About half of those interviewed in January 1991 had lived in the

area for only a few years. The other half had resided in their

present homes from 13 to 45 years. Some suggested that property

values have not been depressed in the general area beyond the

effect of the regional economic downturn. Although a number of

homes in the vicinity of the site have been sold recently, other

commenters expressed concern about property values. There was

general agreement that concern about the SRSNE facility is not

Town-wide, but is centered within the neighborhood around Lazy

Lane.

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Concerns About the Timeliness and Types of Information

From EPA

Several commenters requested more frequent information about the

status of cleanup activities. One requested information on a

weekly basis, while others mentioned from every two to six

months. Most requested periodic public meetings, interspersed

with fact sheets, on the status of EPA activities. Several

interviewees requested that this Community Relations Plan include

a chronology of past activities performed toward site

remediation.

Other suggestions for fact sheets and information updates:

include a schedule for projected site activity and report

milestones; describe more simply the cleanup process; make

clearer connections between past and present legal and technical

events; discuss the effect of the site on the Quinnipiac River;

and the use of expanded glossaries. One interviewee asked that

EPA be "more candid" about cleanup activities.

Concerns About Government Credibility

Several comments centered around the lack of coordination between

state, federal, and local officials in dealing with SRSNE. They

assert that differing mandates and agendas have provided the

company with maneuvering room to delay effective remedial action.

One commenter suggested this situation has been magnified by the

lack of deadlines for EPA to respond to SRSNE submissions. The

resulting lack of progress has soured many commenters on EPA's

commitment to deal with past and perceived on-going contamination.

One interviewee stated that there is no way EPA can win with the

concerned Southington public short of having closed down the

SRSNE facility years ago. Another wants to hear the truth. A

commenter strongly requested that there should be public

discussion about all potential remedial alternatives, not just

those EPA normally presents for public review in the Feasibility

Study, for example.

Several commenters expressed dismay at alleged past and present

conflicts of interest by Town officials in dealings with the

facility.

Concerns About Public Health

Some residents feel the public water supply is contaminated and

two commenters expressed the feeling that they would prefer to

drink from their own wells than chance ill effects from Town

water. Others, with their own wells, are drinking bottled water.

-10

A number of residents are concerned that the removal of solvent

contamination from the groundwater by the air stripping process

used by the on-site treatment system is creating high levels of

air pollution. They question the wisdom of trading one form of

contamination for another, particularly since the DEP has not

required the company to install a pollution control device on the

stripper.

Residents are concerned about the number of people who may die

from the effects of contamination from the site before the

facility is closed down. Several commenters were concerned about

the alleged elevated incidence of cancer in Southington. Many

have neighbors or relatives who have had cancer.

Concerns About SRSNE'a Continued Operation

Most supported the immediate shutdown of the SRSNE facility.

Another suggested that if it was closed it might declare

bankruptcy and thereby escape financial responsibility for the

site clean up. All were concerned about the possibility of the

company avoiding paying cleanup costs.

Many lamented that the company is allowed to monitor its own

environmental systems; they believe that SRSNE is forewarned

about inspections. They requested that EPA and the DEP undertake

responsibility for monitoring to assure its integrity. They also

requested that EPA have an overseer at the site continuously.

Some asked whether the company had an evacuation plan in place in

case of an emergency. Many people want to know how long it will

take the Court to rule on the federal government's July 1990

suit.

The RCRA Reapplication Process

Many residents attending the July 1990 public meeting demanded

that EPA immediately deny SRSNE's application for a revised RCRA

permit. They also felt that the decision should be expedited

since SRSNE is the only facility in the region that is both a

RCRA facility and on the National Priorities List.* One

commenter strongly encouraged EPA to testify at the DEP hearing

on the RCRA permit when he learned that Connecticut had been

reauthorized to administer the RCRA program in Connecticut,

effective December of 1990. Others wanted a better understanding

of the relationship between RCRA and Superfund activities at the

site. (See Appendix D on page 23 for an explanation of the

relationship between RCRA and Superfund.)

*As a matter of clarification, there is at least one federal

facility in New England that is regulated both by RCRA and

Superfund.

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The Superfund Cleanup Process

Some residents did not feel that they had the Superfund cleanup

process explained clearly enough (see Appendix E on page 27 for

an explanation of the Superfund process). Others, upon hearing

that a groundwater treatment system can take 30 years or more to

accomplish its goal, requested that this potential treatment

scheme be discussed with the public in more detail.

Other Potential Sources of conteunination

One commenter asked if there was any credence to the notion that

SRSNE was going to start a low level radioactive waste disposal

facility on the Cianci property. An interviewee suggested EPA

look into waste SRSNE allegedly dumped in a pond off West Street.

Several commenters suggested that EPA investigate whether

contamination from the former Beaton & Corbin Manufacturing

building at 318 N. Main Street may have contributed to pollution

in the area. Several residents expressed concern about finding a

"black sludge pit" on the site last summer. Others suggested that

EPA sample for potential contamination at an abandoned filling

station just south of the site and at a parcel of land behind the

Moose Lodge on Curtiss Street.

V. OBJECTIVES OF THE COMMUNITY RELATIONS PROGRAM

Based on the comments of Southington residents, and reviews of

EPA's files, including news clips, the three major objectives of

the Community Relations Program to be implemented for the SRSNE

site are:

1. To keep the affected community better informed about site study and cleanup activities and provide an effective forum for their participation in these events.

2. To encourage coordination between the EPA, DEP and other agencies on the related/overlapping programs and jurisdictions.

3. To promote a clearer understanding of how the various programs and activities concerning the site are interrelated.

VI. FUTURE COMMUNITY RELATIONS ACTIVITIES UNDER THE SUPERFUND PROGRAM

This section lists specific community relations activities that

EPA will carry out to meet the objectives of this Community

Relations Plan for the SRSNE Superfund site. A chart in Appendix

E on page 29 provides a schedule of community relations

activities.

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1. Provide Two EPA Contacts for Community Members

To meet the information needs of local officials and community

members, EPA has designated two individuals as information

contacts for the site: the Remedial Project Manager (RPM),

Margaret Velie, and the Community Relations Coordinator (CRC),

Susan Frank. Their addresses and telephone numbers (listed in

Appendix B, on page 17) will be included in all informational

materials distributed to the public, including any facts sheets

and press releases.

2. Conduct Periodic Public Informational Meetings/Public

Gnimiiftni-- Periods

EPA policy is to hold a public informational meeting at the start

of the Remedial Investigation. Future meetings will be scheduled

prior to the start of the Feasibility Study comment period to

explain the remedial alternatives evaluated and the alternative

proposed as the preferred cleanup remedy, and during the Remedial

Design phase.

3. Conduct/Participate in Formal Public Hearings

During the comment period on the Feasibility Study Report, EPA

will hold a formal public hearing. Written and oral testimony

will be taken from anyone wishing to comment. EPA comment

periods are at least 3 0 days.

A written transcript will be made of comments offered at the

hearing. A copy of the transcript, as well as a Responsiveness

Summary, consisting of an abstract of oral and written comments

and EPA and state responses to them, will be placed in the

information repositories. (See Appendix A on page 16 for the

locations of the information repositories.)

4. Prepare Fact Sheets, Information Updates, and Press

Releases

Fact sheets and information updates summarize, in non-technical

terms, major findings or the status of site remedial activities.

EPA usually prepares fact sheets when technical milestones have

been reached. Press releases are sent out at irregular intervals

when other events occur, such as the filing of a law suit. Press

releases are sent to everyone on EPA's site mailing list. The

media outlets currently on EPA's mailing list to which press

releases are sent can be found in Appendix C on page 20.

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5. Maintain Regular Contact with Community Members

To provide an easily accessible update for Southington residents

about site activity, a "hot line" will be established. The

dedicated telephone line will allow Southington residents to hear

a recording of the status of activities, updated approximately

every two weeks or as needed, as well as to leave a message with

comments or questions, without incurring toll charges for a call

to Boston. Responses to residents questions and comments will be

made in a timely fashion by appropriate government

personnel. This line is expected to be established by the summer

of 1991. Local media contacts have agreed to regularly publicize

the telephone number.

6. Maintain Information Repositories

The Southington Public Library and the EPA Records Center in

Boston are the designated information repositories for the SRSNE

site. EPA will send the repositories such documents as fact

sheets, information updates, and all other public information

materials. When the Administrative Record (all the information

upon which EPA will base the selection of the final cleanup

remedy) is complete, EPA will ensure that the repositories

contain this material.

EPA's review of the information repository at the Southington

Public Library in January 1991 revealed that documents previously

available for public inspection there were missing. EPA will

replace them. Please contact the CRC (see Appendix B on page 17

for the CRC's address and telephone number) if the files at the

library again appear incomplete.

The addresses, hours of operation, and contacts for the

information repositories for the SRSNE site are listed in

Appendix A on page 16.

7. Maintain the Site Mailing List

EPA will maintain a mailing list of those individuals, as well as

media and official contacts, who have indicated a desire to

receive information concerning the SRSNE site. It will be

updated and amended regularly. The list will be used to

distribute notices, fact sheets, information updates, press

releases, and other information about actions at the SRSNE site.

-14

8. Review the Community Relations Plan Following the Record of

Decision

EPA will review this Community Relations Plan following the

Record of Decision and revise it, if necessary, to insure that it

provides a program of community relations activities appropriate

to the design and implementation of the remedial action chosen

for the SRSNE site. A revised plan will assess the Community

Relations Plan conducted to date, identify new concerns that have

arisen since the beginning of the RI/FS, and develop a program of

community relations activities to keep the public informed of,

and involved in, ongoing EPA activities at the site.

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APPENDIX A

LOCATIONS OF INFORMATION REPOSITORIES AND FOR PUBLIC MEETINGS

INFORMATION REPOSITORIES

Southington Public Library

225 Main Street

Southington, CT 06489

(203) 628-0947

Hrs. M-Th 9:30 am - 9:00 pm

F-Sat 9:30 am - 5:00 pm

Contact: Audrey Brown

EPA Records Center

90 Canal Street, 1st Floor

Boston, Massachusetts 02114

(617) 573-5729

Hrs. M-F 8:30 am - 1:00 pm

2:00 pm - 5:00 pm

Contact: Evo Cunha

PUBLIC MEETING LOCATIONS

Town Council Chambers High School Auditorium Town Hall 720 Pleasant St. Southington, CT Southington, CT 06489 Southington, CT 06489 (203) 628-3232 (203) 276-6200

Contact: John Weischel Contact: Jerome Auclair Capac ity: Approx. 100 Capacity: 900

Joseph A. DePaolo Junior High School 385 Pleasant Street Southington, CT 06489 (203) 628-3262

Contact: Gerald Gingras Capacity: 4 35

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APPENDIX B

KEY CONTACTS LIST

EPA CONTACTS

Margaret Velie

Remedial Project Manager

US EPA (HEC-CAN6)

JFK Federal Bldg.

Boston, MA 02203

(617) 573-9664

Margaret Leshen

CT Section Chief

US EPA (HEC-CAN6)

JFK Federal Bldg.

Boston, MA 02203

(617) 573-9660

Matthew Hoagland

US EPA (HSS-CANl)

JFK Federal Bldg.

Boston, MA 02203

(617) 573-9666

STATE OF CONNECTICUT

Ross Bunnell

RCRA Contact

Waste Management Bureau

CT DEP

165 Capitol Ave.

Hartford, CT 06106

(203) 566-5019

Diane Aye

CT Dept. of Health Services

150 Washington St.

Hartford, CT 06106

(203) 566-8167

Eric Jorgensen

Water Compliance Unit

CT DEP

122 Washington St.

Hartford, CT 06106

(203) 566-3654

Susan Frank

Community Relations

Coordinator

US EPA (RPA)

JFK Federal Bldg.

Boston, MA 02203

(617) 565-3419

John Podgurski

RCRA Contact

US EPA (HEE-CAN6)

JFK Federal Bldg.

Boston, MA 02203

(617) 573-9673

Paul Jamenson

Superfund Contact


CT DEP

165 Capitol Ave.

Hartford, CT 06106

(203) 566-5486

Elsie Patton

Water Compliance Unit

CT DEP

122 Washington St.

Hartford, CT 06106

(203) 566-3654

Ed Parker


CT DEP

122 Washington St.

Hartford, CT 06106

(203) 566-3654

-17

APPENDIX B (continued)

KEY CONTACTS LIST

Ernie Bouffard

Air Contact

CT DEP

122 Washington St.

Hartford, CT 06106

(203) 566-8230

LOCAL OFFICIALS

John Weichsel Arthur Blumer, M.D.

Town Manager Director of Health

Town Hall Town Hall

Southington, CT 06489 Southington, CT 06489

203) 276-6200 (203) 276-6275

Nicholas DePaola, Chairman Gilbert Bligh, Super.

Town Council Water Works Dept.

Town Hall 65 High St.


(203) 276-6211 (203) 628-5593

Melvin Schneidermeyer Administrator

Town Planner Conservation Comm.

Town Hall Town Hall


(203) 276-6248 (203) 276-6248

CITIZENS GROUPS

Marie Tuccitto

Co-President

(203) 621-5146

Thomas Willametz

Co-President

(203) 621-9808

Southington Assn. for the Environment (SAFE)

P. O. Box 551


ELECTED U. S. GOVERNMENT OFFICIALS

Senator Christopher J. Dodd Rep. Nancy L. Johnson

Putnam Park One Grove Street

100 Great Meadow Road New Britain, CT 06053

Wethersfield, CT 06109 (203) 223-8412

(203) 240-3470

-18

APPENDIX B (continued)

KEY CONTACTS LIST

Senator Joseph I. Lieberman

One Corporate Center

Hartford, CT 06103

(203) 722-2882

ELECTED STATE GOVERNMENT OFFICIALS

Steven C. Casey Ann Dandrow State Senator State Representative 83 Peach Tree Lane 10 Annelise Avenue Bristol, CT 06010 Southington, CT 06489 (203) 589-1666 (203) 621-5660

Angelo M. Fusco State Representative 1 Main Street Southington, CT 06489 (203) 628-0027

-19

1

APPENDIX C

MEDIA CONTACTS

^s Desk

MMfCN-FH

1039 Asylum Avenue

Hart ford, CT 06105

News Desk

UUUH-FM/Univ. of Hartford

200 Bloonfield Avenue

West Hartford, CT 06117

News Desk

UTWS-TV

216 Broad Street

New London, CT 06320

News Desk

Conntercial Record

435 Buck Iand Road

South Windsor, CT 06074

News Desk

'B-TV

^ r^ Constitution Plaza

Hartford, CT 06115

News Desk

WPOP-AM

345 East Cedar Street

Hartford, CT 06111

News Desk/Connunity Calen.

UTIC-FM/AM/TV

Financial Plaza

Hartford, CT 06103

News Desk

UQTQ-FH

415 Granby Street

Hartford, CT 06112

News Desk

Danbury News Times

Main Street

News Desk

WTXX-TV

414 Meadow Street

Uaterbury, CT 06702

News Desk

WVIT-TV

1422 New Britain Avenue

West Hartford, CT 06110

News Desk

WIHS-FM

PO Box 117

Middletown, CT 06457

News Desk

WCNX-AM

PO Box 359


News Desk

WELI-AM

PO Box 85

New Haven, CT 06501

News Desk

UESU-FM

POB 2300/Uesleyan Sta


News Desk

New Haven Register

40 Sargent Drive

New Haven, CT 06511

News Oesk/Connunity Calen.

UJMJ-FM

St. Thomas Seminary

Bloomfield, CT 06002


UPKN-FM

244 University Avenue

Bridgeport, CT 06601

News Desk

Briarwood Coll. Bulletin

2279 Mount Vernon Road


News Desk

WEOH-TV


Hartford, CT 06106 5310

News Desk

Uaterbury Republican Amer.

PO Box 2090

Uaterbury, CT 06722


UNTY-AM

PO Box 459


News Desk

UUBC-FM

PO Box UYBC

New Haven, CT 06520

News Desk

UKCI-FM

59 Quinnipiac Avenue

North Haven, CT 06473

News Desk

UCCC-FH

243 South Uhiney St.

Hartford, CT 06105

News Desk

UFCS-FH/Central CT Univ

1615 Stanley Street

New Britain, CT 06050

News Desk

Stafford Spring Reminder

250 West Main Street

Stafford Spring, CT 06076

News Desk

UEDU-TV

240 New Bedford Avenue

Hartford, CT 06106

News Desk

WNPR-FM/WPKT-FM


Hartford, CT 06106


'UIOF-FM

PO Box 2719

Uaterbury, CT 06723

News Desk

Southington Observer

PO Box 648


News Desk

ULIS-AM

PO Drawer U

Old Saybrook, CT 06475


UNEZ-AM/URCH-FH

Radio Park

Farmington, CT 06032

News Desk

Step Saver

213 Spring Street


News Desk

URTC-FH/Trinity College

300 Siimit Street

Hartford, CT 06106

News Desk

ULVH-AM/FM

905 Wethersfield Avenue

Hartford, CT 06114

-21

IiM Gibbons Hal Gillam Jackie Ouinn

hington Observer Meriden Record Journal UPOP-AH

,«.« Spring Street IT Crown Street PO Box 11-1410

Southington, CT 06489 Meriden, CT 06450 Hartford, CT 06U1

News Desk Maxine Bernstein Lauren Borsa URYH-AM Hartford Courant New Britain Herald

1056 UiHard Avenue 285 Broad Street 1 Herald Square Newington, CT 06111 Hartford, CT 06115 New Britain, CT 06050

-22

APPENDIX D

FACT SHEET COMPARING RCRA AND SUPERFUND

FACTS ABOUT

RCRA

' " i p w s ^ "

COMPARING

RCRA AND SUPERFUND

Tl response to public concern about hazardous wastes. Congress has The RCRA Program provided the Environmental Protection Agency (EPA) the authority to

administer two major hazardous waste statutes - the Resource Conser Congress passed RCRA in 1976 as an* vation and Recover>' Act (RCRA) and the Comprehensive Environ amendment to the Solid Waste Disposal mental Response, Compensation and Liability Act (CERCLA). CER Act of 1965. In 1984, RCRA in turn wa;

amended by the Hazardous and Solicp» CLA, more commonly known as Superfund, mandates the investigation and Waste Amendments, which greatly ex

cleanup of abandoned or uncontrolled hazardous waste sites. RCRA. panded both the scope and requiieme regulates current and planned hazardous waste treatment, storage, and RCRA regulations. Under RCRA. disposal activities, and includes provisions for cleaning up contamination of separate regulatory programs have Been

established, covering solid waste, hazardthe environment occurring as a result of these activities. Because provisions ous wastes, and underground storage tanks of both laws overlap in some cases, it is useful to compare the roles that the

The RCRA hazardous waste progranl"' two laws play in protecting health and the environment. provides a system for controlling hazardous wastes from "cradle to grave" — fron

- 2 3

The RCRA Program How RCRA and Superfund Overlap the lime the wastes are generated until they

-e ultimately treated, recycled or disosed. EPA has set standards for three

categories of waste handlers: generators, u^nsporiers, and owners or operators of treatment, storage, or disposal (TSD) facilities. Regulations for TSDs provide ihe basis for developing and issuing permits that ensure that faciliiics manage wastes soundly.

The Superfund Program

In 1980, Congress enacted CERCLA, enabling EPA to investigate and respond to releases of hazardous substances that may endanger public health, welfare and the environment. The 1980 law set up a S1.6 billion fund to pay for the investigation and cleanup of sites where parlies responsible for contamination are unable or unwilling 10 clean up. In October 1986, Congress "mended and reauthorized Superfund, in

.jasing the size of the fund to about 58.5 iilion.

The Superfund program operates by identifying,inspecting, ranking and cleaning up the nation's worst abandoned hazardous waste sites. The Superfund program accomplishes these tasks in three v,ays:

• it makes responsible parties carry out hazardous waste cleanups wherever possible;

• it sets up an S8.5 billion Hazardous Waste Trust Fund ("Superfund") to pcrfomi remedial cleanups of inactive hazardous waste sites where responsible parties could not be held accountable, and to respond to spills and other emergencies involving cnvironmenial releases of hazardous substances; and

• it allows recovery of costs from responsible panics, where the government is forced to do the cleanup.

RCRA and Superfund share the goal of protecting human health and the environment They also complement each other in their efforts to reach that common goal, by doing the following:

• promoting environmentally sound disposal or treatment of hazardous wastes;

• providing for rapid response to environmental releases of hazardous wastes which pose an immediate health threat;

• promoting the cleanup of contamination from environmental releases — taking "corrective action";

• involving states; and

• involving the public.

• Disposal of Hazardous Waste

When wastes are removed from a Superfund site, the TSD facility to which they are taken must have a RCRA permit and comply with the appropriate RCRA

It-miiHrrii'nftiSiiSaiiK îi'r ^Mu- ^ J M ' K ^ ̂

Unregulated hazardous waste generator

regulations. In addition, any individual transporting these wastes must adhere to RCRA requirements for hazardous waste transporters. This includes waste identification and labelling, tracking (using a RCRA manifest), and proper handling during transportation. Transported wastes are also subject to U.S. Department of Transportation requirements under the Hazardous Materials Transportation Act

Q Immediate Response to Imminent Danger

RCRA and Superfund both contain provisions enabling EPA to require parties responsible for an imminent hazard to health or the environment to take appropriate action to abate the hazard or clean it up prompdy. Under Superfund, EPA can obtain prompt court action to abate releases of hazardous substances into the environment. Similarly, under RCRA, EPA can secure prompt action through the courts to abate imminent and substantial endangcrment resulting from past or present waste management practices of waste handlers and transporters.

wmm • ^ C fcS^ ^ H B - I ^ l t M.-^^^^^SBT^^^m^jf^CSSf^t

Improper disposal Superfund clean-up of on or off-site inactive contaminated

prior to regulation disposal site

Superfund cleans up improperly disposed waste and uses the

RCRA system to manage it

- 2 4

G Corrective Action By Responsible Parties

RCRA and Superfund both contain proWsions requiring parties responsible for hazardous substance releases to conduct necessao' investigations and cleanup actions. Superfund covers cleanups at inactive sites while RCRA addresses facilities that actively manage hazardous wastes. Coirective action can be required regardless of when the waste was placed at the facility, thereby allowing past as well as current problems to be remedied. At inactive sites, Superfund requires EPA to pursue parties responsible for site contamination to make them conduct and pay for cleanup or reimburse EPA's cleanup cost Under both RCRA and Superfund, EPA broadly interprets the term "corrective action" to include site investigations, shonterm measures, and long-term cleanups. (See RCRA Fact Sheet "Cleaning Up Hazardous Waste Sites.")

In permitting TSDs, RCRA requires that owners and operators provide financial assurance that they will take corrective action if necessary. Superfund requires that all actions be made to comply with other applicable federal and state environmental laws. RCRA requirements which

RCRA-permitied transporter

"9!m^

mm

mm n RCRA-pcrmiucd

apply to Superfund remedial actions include:

• RCRA standards for closure of TSD facilities must be metata Superfund site if the requirements are applicable to the waste or remedy at the site.

• If wastes are disposed of or treated on-site, the disposal or treatment units must meet the technical requirements of RCRA (e.g. double liners for new or expanding landfills).

• If hazardous wastes are to be disposed of or treated off-site, the off-site facility must meet RCRA requirements.

Corrective actions at RCRA facilities can be conducted under the authorities of RCRA, Superfund or both. In order for corrective actions to be conducted under Superfund, sites must be listed on the National Priority List (NPL). Listing sites on the NPL involves investigatingand ranking them on the basis of the threats which they pose to human health and the environment. EPA has established three criteria under which RCRA facilities that are not normally addressed under Superfund can be listed on the NPL and thus become eligible for corrective action under Superfund:

• The facility owner/operator is bankrupt;

• The owner/operator has lostauthorization to manage hazardous wastes under RCRA and has shown probable unwillingness to perform corrective action; or

• In cases other than loss of RCRAauiho zaiion, the owner/operator has shown proL—. able unwillingness to perform corrective action.

• State Involvement

Both Superfund and RCRA provide an opportunity for state involvement Under Superfund, the lead responsibility for conducting investigation and cleanup efforts resides with EPA. EPA may allow a state to conduct a Superfund action by entering into a cooperative agreement This cooperative agreement delegates lead responsibility to the state for response at a site, but requires EPA to maintain final authority over the remedial action.

RCRA, however, was designed to have the entire hazardous waste program administered by states with only minimal oversight by EPA. To obtain responsibility for permitting facilities under the RCRA hazardous waste program, states must develop a program which will be approve/' by EPA. States also are encouraged

^mmnmA / •?

5iP^3 RCRApenniaed

3 Regulated hazardous

off-site TSD facility V

-transporter waste generaior

r \ Both RCRA and Superfund wastes are

shipped and treated by RCRA-approved TSD's and transporters.

RCRA manages wastes properly from cradle 10 grave.

- 2 5

RCRA and Superfund Overlap

EPA to take over the responsibility for the •ogram's enforcement. (See RCRA Fact

^^neet "The State and Federal Partnership.")

• Public Involvement

Both RCRA and Superfund provide opportunities for public participation in

I hearings or through written comments on enforcement orders, draft TSD facility permits (under RCRA), and at key points during the cleanup process. A response to public comments is issued once a final decision is made on the permit application. There may be other opportunities for public

i input on a case-by-case basis. Coniactyour EPA/State Public Involvement Coordina

tor for information about activities at a specific site. Information reposittxies are established in communities to provide citizens access to information on TSD permit applications, enforcement orders, technical data, cleanup plans and other issues. (SeeRCRA Fact Sheet "Getting Involved in the Permitting Process" and Superfund Fact Sheet "Public Involvement in the Superfund Program.")

Suggested Readings

The National Contingency Flan, (Title 40, Code of Federal Regulations, Part 300).

Standards and Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities, (Titie 40, Code of Federal Regulations, Parts 264 and 265).

For Further Information

For further information, contact the RCRA/Superfund Hotline, Office of Solid Waste (WH-562), U.S. Environmental Protection Agency, 401 M Sueet, S.W., Washington, D.C. 20460. (800) 4249346

For information on specific aspects of RCRA and CERCLA and on where to obtain other RCRA fact sheets, contact your EPA Regional Office.

EPA RCRA Fact Sheets

Land Disposal Public Involvement The State and Federal Partnership Regulating Hazardous Waste Official Butlness

Facilities Penalty for Privatt U M $300 Health £. Risk Assessment

Corrective Action ClosurelPost-Closure RCRA / CERCLA Comparison

- 2 6

APPENDIX E

SUPERFUND CLEANUP PROCESS

AND ESTIMATED TIMEFRAME FOR SRSNE CLEANUP ACTIVITIES

Superfund Process

This exhibits provides a simpiiHed explanation of how a long-term Superfund response works.

1. After a site is discovered, it is investigated, usually by the Sute.

2. The State then ran/fej the site using a system that takes into account.

o Possible health risks to the human population.

o Potential hazards, (e.g., from direa contaa, inalauon, fire, or explosion) of substances at the site.

o Potential for the substances at the site to contaminate drinking water supplies.

o Potential for the substances at the site to pollute or otherwise harm the environment.

If the problems at a site are deemed serious by the Sute and the EPA, the site will be listed on theNational Priorities List (NPL), a roster of the nation's worst hazardous waste sites. Every site on the NPL is eligible for federal Superfund money.

3. If a site or any portion thereof poses an imminent

threat to public health or the enviroment at any time,

EPA may condua an emergency response referred to

as an immediate removal or an initial remedial measure.

4. Next, EPA usually conducts iremedial investigation(RI). The RI assesses how serious the contamination is. what kind of contaminants are present, and charaaerizes potential risks to the community.

5. Following completion of the RI, EPA performs a feasibility study.(PS) which examines the feasibility of various cleanup alternatives.

6. EPA holds a minimum three-week public comment period to receive citizen input concerning the recommended aitemadves. Citizens may provide conmients either orally at public meetings or through wrinen correspondence to EPA.

7. After public comments have been received, EPA then chooses a specific cleanup plan.

8. Once the design is finished, the actual remedial activities of the site can begin.

BThe time necessary to complete each of these steps varies with every site. In general, a remedial investi

iuon/feasibility study takes from one to two years, esigning the cleanup plan may take six m o n ^ .

And implementing the remedy - the actual containment or removal of the waste - may take from one to three years. If groimd water is involved, the final cleaup may take many more years.

Ongoing commuiuty relations activities during a cleanup include public meetings and other activities intended to keep citizens and officials informed and to encourage public input. These activities are scheduled throughout th course of the remedial cleanup process. Specific activites vary from site to site depending on the level and nature of concern. The . range of community relations activities that can occur is described in EPA's Commuiuty Relations Plan for the site.

- 2 7

EPA is currently on Step 4, the Remedial Investigation (RI),

described in general terms above. An EPA contractor, the NUS

Corporation, began field work with EPA oversight at the SRSNE

site in May of 1990. The RI is divided into three phases. Phase

1 focuses on the former Cianci Construction Company property and

the land north of the Quinnipiac River owned by Southington. The

goal of Phase 1 is to determine the extent of contamination by

testing surface water and sediments in the River, sampling

existing monitoring wells and defining the subsurface geology.

Phase 2 of the RI, which began this spring, focuses on the area

inside the SRSNE fence. Activities include testing soils,

installing monitoring wells and identifying buried material.

Phase 2 should be completed in late 1991.

Phase 3 tests will be designed based on the results of Phases l

and 2. Activities may include defining contamination migration,

groundwater flow direction and the extent of contamination in the

environment as well as the performance of treatability studies

for potential cleanup technologies. A risk assessment, which

determines the potential current or future health and

environmental risks posed by the site, will be conducted.

EPA expects the RI work to be completed by late 1992. A

Feasibility Study (FS), Step 5, will be conducted concurrently

with Phase 3. The FS identifies various cleanup options for the

site, based on the information developed during the RI. The FS,

together with the Proposed Plan which explains the RI/FS in non

technical terms, is expected to be released for public comment in

late 1992 (see Step 6, above). EPA's decision on the cleanup

remedy is then documented in a Record of Decision (ROD). EPA

anticipates the ROD signing in 1993.

Remedial Design (evaluating and designing the specific cleanup

methods), shown in Step 7, typically takes 1 to 1 1/2 years.

Remedial Action, Step 8, the actual cleanup phase, can take from

1 to 30 years or more, depending on whether a long-term

groundwater treatment strategy is a component of the project.

-28

Schedule of Community Relations Activities

Community

Relations

Activity

Information Repositories

Information Contacts

Mailing List

Contact Local Officials

Press Releases

i ro Public Informational Meeting

Fact Sheets

Information Updates

Hotline

Proposed Plan

Public Comment Period

Informal Public Hearing

Responsiveness Summary

Newspaper Announcements

Review of CRP

Completion of During Completion Work Plan Rl o fR I

1 ^ " " "

1

1

1 s 1 1

1 1

1 1 1

1

Completion of Proposed Plan & FS

update as needed

update as needed

update as needed

as needed

as needed

' '

provide as needed

as needed

1 1

1

1

1 1

ROD

Start of Remedial Design/ Remedial Action

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