Embed Size (px)
Citation preview
1
From: Thomas Smith <[email protected]>Sent: Sunday, August 28, 2016 2:24 PMTo: DiLorenzo, James; Jennings, RonaldCc: Mccarthy, Gina; [email protected]; [email protected];
[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; Mayor Harkins; [email protected]
Subject: Re: EPA Proposed Clean-up Plan for Raymark Industries, Inc. Superfund Site, Operable Units 2, 3, 4 and 6
Attachments: Jim Di Lorenzo and EPA Region 1 letter.pdf
Dear Mr. Di Lorenzo and EPA Region 1: Thank you for the opportunity to comment on the EPA's latest proposal regarding the Toxic Raymark Waste here in Stratford, CT. Attached for review is a copy of SaveStratford's comments regarding that proposal. We've highlighted several significant flaws in your proposal and suggest that you go back to the drawing board and revise this plan as it is not acceptable to the community in its current form. We've offered a few suggested changes at the end of our letter to help you get started. As we've consistently stated since 2007, the best solution for Stratford is the complete removal of all or as much of the Toxic Raymark Waste from town. Please provide us with a proposal that accomplishes that. If you have any questions or need any additional information, please feel free to contact me. We look forward to seeing your revised comprehensive proposal. Regards, Tom Smith SaveStratford.org Log On, Find Out, Take Action...
Mr. Jim DiLorenzo [email protected] Superfund Project Manager US EPA Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 Re: EPA Proposed Clean-up Plan for Raymark Industries, Inc. Superfund Site, Operable Units 2, 3, 4 and 6 Dear Mr. Di Lorenzo and EPA Region 1: It’s hard to believe that 9 years ago, EPA Region 1 provided Stratford CT with a substandard, underfunded clean-up plan that didn’t clean up any of the Toxic Raymark Waste. The EPA ignored the Stratford community and we successfully enacted a state law that prohibits anyone from dumping toxic waste in a residential neighborhood in the state of CT. In 2008, the EPA continued to ignore SaveStratford and the community – summarily rejecting each and every one of our proposals to clean-up the Toxic Raymark Waste by removing that waste from town. The EPA even ignored SaveStratford’s recommendation to re-offer the sub-slab ventilation systems to the homes that didn’t have them at that time. Now, nine years later, the EPA is back with a “new conceptual plan”, but continues to ignore the community. Specifically, we asked the EPA for a fully funded comprehensive clean-up plan that removes a significant amount of Toxic Raymark Waste from town. Instead, the EPA offered Stratford half of a proposal that leaves up to 90% of the waste in an unlined landfill in a residential neighborhood that doesn’t even meet the basic design standards for a site where toxic waste will be dumped. The EPA’s current proposed plan is fundamentally flawed. We’ve noted at least five significant issues with what the EPA has proposed. First, where’s the rest of the “comprehensive” clean-up proposal (addressing OU-5, OU-7, OU-8 and OU-9)? The EPA has requested community acceptance of the current proposal before any details of what the EPA is going to do to remediate these sites has been released. That’s not acceptable. The EPA needs to provide details on all sites that will be remediated in order for the community to have a full understanding of what the EPA will be actually cleaning up. Second, your statement (echoed by Mayor Harkins) that the EPA is going to “take 50% of the Toxic Raymark Waste out of Town” is disingenuous. Based on what the EPA has provided thus far, it appears that the EPA is leaving up to 90% of the Toxic Raymark Waste in Stratford. (110,000 CY – 11,000CY required 10% most toxic waste for removal = 99,000 CY left in Stratford). The fact that the EPA has not released any details on the remaining OU’s also does not give us any guarantee that the EPA will actually keep its end of the bargain regarding removing waste from Stratford. Third, on page 7 of your proposed clean-up plan, it is clearly stated that “The CAMU rule establishes standards and minimum design requirements to ensure that waste consolidation is implemented in a protective manner. The minimum design standards for a new CAMU require a cap, liner and leachate collection system…” However, that is not what the EPA is proposing in this plan. Instead, as outlined on pages 7 and 8 of the proposed plan, the EPA is proposing an “alternative design” - an unlined landfill with none of the standard protections used to handle toxic waste containing lead, PCB’s and Asbestos. Despite your emphasis of using “Best Practices” here in Stratford, the EPA is starting off this massive project by ignoring its own minimum design standards for handling toxic waste.
Fourth as part of the your proposed “clean-up” the EPA is recommending “the Construction of a permanent, low-permeability cap over the consolidation area to isolate contamination” (page 2). We note that while this sounds reassuring and safe, a closer inspection of the Caps that the EPA uses as part of its designs for sites like this reveals that these types of Caps eventually degrade and fail – releasing the materials that are supposed to be contained. There are numerous examples of this all across the United States. Finally, while we appreciate the EPA, after eight years, is finally offering sub-slab ventilation systems to the 20 homes that don’t have them, it certainly “begs the question” why has it taken the EPA eight years to act? Additionally, you and your colleagues have repeatedly stated that there are no viable solutions to address the toxic groundwater plume (something the EPA deemed as “Stratford’s #1 Environmental Problem”). Based upon our own research, this is not true. In fact, the EPA appears to be using a method to extract VOC’s from polluted ground water at a Superfund site in California using a local waste water treatment facility. Why hasn’t this been explored further here in Stratford (where our own water treatment facility is currently operating well under capacity)? As such the members of SaveStratford cannot in good conscience agree to the EPA’s proposed clean-up plan in its current form. The EPA’s former cabinet secretary Lisa Jackson once stated “The only thing worse than not having the EPA, is having an EPA that doesn’t do its job…” Whether it is incompetence or ineptitude, it’s clear that after 15 years the EPA still isn’t doing its job here in Stratford. Next Steps: Here’s what the EPA needs to do in order to begin to gain community acceptance for “conceptual” clean-up plan for the Toxic Raymark Waste: 1. EPA needs to show Stratford its proposed clean-up plans for all sites around Stratford (not just 4 of
the 9 OU sites with the remainder to be addressed at some vague later date) 2. EPA needs to provide Stratford with a fully funded, comprehensive clean-up plan – one that
removes 50% of the Toxic Raymark waste from residential neighborhoods in Stratford (OU-6 properties) now not later. If the EPA, under the direction of the Federal DOT, can excavate Toxic Raymark waste from a vacant, uninhabited parcel of land at the end of an airport runway in Stratford and ship that waste out of town for disposal, then it can certainly do the same for toxic waste located in residential neighborhoods.
3. Best Practices - The EPA needs to waive its immunity from Civil and Criminal Prosecution. This will ensure that the EPA will actually adhere to its “best practices” when undertaking this clean-up project.
4. OU-1: EPA needs to immediately re-offer the installation of sub-slab ventilation systems to the 20 homes that don’t currently have them. We asked you to do this in 2008. The fact that the EPA has taken eight years to act on this issue is Gross Negligence.
5. OU-1: EPA needs to look at ways to utilize Stratford’s Waste Water Treatment Facility as a means to address the toxic groundwater plume.
If you have any questions, please feel free to contact us. We look forward to seeing your revised comprehensive proposal. Regards, Tom Smith and the members of SaveStratford.org Log On, Find Out, Take Action…
Cc by email to: [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected]
NATIVE FILE TARGET SHEETUS EPA New England
Superfund Document Management System
To view the attached files, open the “Attachment Panel” by clicking on the paper clip icon in the left side panel of this window.
Please Note: To view attachments the software corresponding with the specified file type is necessary.
For any additional assistance please contact the EPA New England Office of Site Remediation and Restoration Records and Information Center
617-918-1440
File Type(s) attached: Example: .jpg, .xls
Description or Comments:
.MSG
Mr. Jim DiLorenzo [email protected] Superfund Project Manager US EPA Region 1 5 Post Office Square, Suite 100 Boston, MA 02109-3912 Re: EPA Proposed Clean-up Plan for Raymark Industries, Inc. Superfund Site, Operable Units 2, 3, 4 and 6 Dear Mr. Di Lorenzo and EPA Region 1: It’s hard to believe that 9 years ago, EPA Region 1 provided Stratford CT with a substandard, underfunded clean-up plan that didn’t clean up any of the Toxic Raymark Waste. The EPA ignored the Stratford community and we successfully enacted a state law that prohibits anyone from dumping toxic waste in a residential neighborhood in the state of CT. In 2008, the EPA continued to ignore SaveStratford and the community – summarily rejecting each and every one of our proposals to clean-up the Toxic Raymark Waste by removing that waste from town. The EPA even ignored SaveStratford’s recommendation to re-offer the sub-slab ventilation systems to the homes that didn’t have them at that time. Now, nine years later, the EPA is back with a “new conceptual plan”, but continues to ignore the community. Specifically, we asked the EPA for a fully funded comprehensive clean-up plan that removes a significant amount of Toxic Raymark Waste from town. Instead, the EPA offered Stratford half of a proposal that leaves up to 90% of the waste in an unlined landfill in a residential neighborhood that doesn’t even meet the basic design standards for a site where toxic waste will be dumped. The EPA’s current proposed plan is fundamentally flawed. We’ve noted at least five significant issues with what the EPA has proposed. First, where’s the rest of the “comprehensive” clean-up proposal (addressing OU-5, OU-7, OU-8 and OU-9)? The EPA has requested community acceptance of the current proposal before any details of what the EPA is going to do to remediate these sites has been released. That’s not acceptable. The EPA needs to provide details on all sites that will be remediated in order for the community to have a full understanding of what the EPA will be actually cleaning up. Second, your statement (echoed by Mayor Harkins) that the EPA is going to “take 50% of the Toxic Raymark Waste out of Town” is disingenuous. Based on what the EPA has provided thus far, it appears that the EPA is leaving up to 90% of the Toxic Raymark Waste in Stratford. (110,000 CY – 11,000CY required 10% most toxic waste for removal = 99,000 CY left in Stratford). The fact that the EPA has not released any details on the remaining OU’s also does not give us any guarantee that the EPA will actually keep its end of the bargain regarding removing waste from Stratford. Third, on page 7 of your proposed clean-up plan, it is clearly stated that “The CAMU rule establishes standards and minimum design requirements to ensure that waste consolidation is implemented in a protective manner. The minimum design standards for a new CAMU require a cap, liner and leachate collection system…” However, that is not what the EPA is proposing in this plan. Instead, as outlined on pages 7 and 8 of the proposed plan, the EPA is proposing an “alternative design” - an unlined landfill with none of the standard protections used to handle toxic waste containing lead, PCB’s and Asbestos. Despite your emphasis of using “Best Practices” here in Stratford, the EPA is starting off this massive project by ignoring its own minimum design standards for handling toxic waste.
Fourth as part of the your proposed “clean-up” the EPA is recommending “the Construction of a permanent, low-permeability cap over the consolidation area to isolate contamination” (page 2). We note that while this sounds reassuring and safe, a closer inspection of the Caps that the EPA uses as part of its designs for sites like this reveals that these types of Caps eventually degrade and fail – releasing the materials that are supposed to be contained. There are numerous examples of this all across the United States. Finally, while we appreciate the EPA, after eight years, is finally offering sub-slab ventilation systems to the 20 homes that don’t have them, it certainly “begs the question” why has it taken the EPA eight years to act? Additionally, you and your colleagues have repeatedly stated that there are no viable solutions to address the toxic groundwater plume (something the EPA deemed as “Stratford’s #1 Environmental Problem”). Based upon our own research, this is not true. In fact, the EPA appears to be using a method to extract VOC’s from polluted ground water at a Superfund site in California using a local waste water treatment facility. Why hasn’t this been explored further here in Stratford (where our own water treatment facility is currently operating well under capacity)? As such the members of SaveStratford cannot in good conscience agree to the EPA’s proposed clean-up plan in its current form. The EPA’s former cabinet secretary Lisa Jackson once stated “The only thing worse than not having the EPA, is having an EPA that doesn’t do its job…” Whether it is incompetence or ineptitude, it’s clear that after 15 years the EPA still isn’t doing its job here in Stratford. Next Steps: Here’s what the EPA needs to do in order to begin to gain community acceptance for “conceptual” clean-up plan for the Toxic Raymark Waste: 1. EPA needs to show Stratford its proposed clean-up plans for all sites around Stratford (not just 4 of
the 9 OU sites with the remainder to be addressed at some vague later date) 2. EPA needs to provide Stratford with a fully funded, comprehensive clean-up plan – one that
removes 50% of the Toxic Raymark waste from residential neighborhoods in Stratford (OU-6 properties) now not later. If the EPA, under the direction of the Federal DOT, can excavate Toxic Raymark waste from a vacant, uninhabited parcel of land at the end of an airport runway in Stratford and ship that waste out of town for disposal, then it can certainly do the same for toxic waste located in residential neighborhoods.
3. Best Practices - The EPA needs to waive its immunity from Civil and Criminal Prosecution. This will ensure that the EPA will actually adhere to its “best practices” when undertaking this clean-up project.
4. OU-1: EPA needs to immediately re-offer the installation of sub-slab ventilation systems to the 20 homes that don’t currently have them. We asked you to do this in 2008. The fact that the EPA has taken eight years to act on this issue is Gross Negligence.
5. OU-1: EPA needs to look at ways to utilize Stratford’s Waste Water Treatment Facility as a means to address the toxic groundwater plume.
If you have any questions, please feel free to contact us. We look forward to seeing your revised comprehensive proposal. Regards, Tom Smith and the members of SaveStratford.org Log On, Find Out, Take Action…
Cc by email to: [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected] ; [email protected]
