'n UPDIKE, KELLY & SPELLACY, P. C.

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Superfund Records. CenterSITE: A' ' - ' ' i- p OBREA K:IIOTHER;,h \ 'nUPDIKE, KELLY & SPELLACY, P. C.-aCOUNSELORS AT LAWPETER G, K E L L YB O U R K E G, S P E L L A C YTHOMAS J . SHORT ELLT H O M A S W. D e M I L L EC H A R L E S F. C O R C O R A N , mPAUL L. MCCORMICKJ A M E S H. L L O Y D . IDJ O H N C. KINGJ O H N R. M A L L I NJ A M E S T. G R A H A ME L I Z A B E T H R. C O L L I N SA L A N I. SCHEEROF C O U N S E LD O U G L A S M. C O S T L E "S T U A R T N. U P D I K E(I90 4-I963)S H A R O N L. A R E S C OK A R E N P. B L A O OA N N M. B O G O R O W 5 K IW I L L I A M F. BREGC A R O L S. C L A P PJ A M E S M. C O N N O RJ O H N J . CRANMORECELIA J . DONNELLYJ O H N C. F I T Z G E R A L D , J R .E M I L Y G. H O L C O M B EP E T E R R. H U N T S M A NBRENDA MALLORYD E B O R A H A. M O N T E I T HM I C H A E L D. N E U B E R TCHARLES J . NICOLR. D I A L P A R R O T T MARK H. O U A T T R OJ O H N M. R O M A N O WJ A M E S e. SCHREIBERFRANK J . SCINTOMARK J . Z I M M E R M A N NO N E STATE STREETP O S T OFFICE BOX 31277HARTFORD, CONNECTICUT 0 6 I 0 3(203)5 4 a - a 6 0 0CABLEDIRECTMarch 9, 1984:'UKSLAW"DIALNUMBER' f\\ / A D M I T T E D T O DISTRICT OF COLUMBIAAND CALIFORNIA BARS ONLY*ADM1TTED TO MASSACHUSETTS BAR ONLYLauren Stiller Rikleen, Esq.U.S. Environmental Protection AgencyOffice of Regional CounselJFK Federal Building, Room 2203Boston, MA 02203RE; i-: - SDMS DocID481997Yaworski, Inc's. Lagoon. Canterbury, ConnecticutDear Ms. Rikleen:As requested, the following additional information is being supplied inresponse to the requests set forth in Merrill Hohinan's letter ofNovember 10, 1983:1.As stated in Rose Yaworski's affidavit dated January 24, 1984v/hich has been provided to you, no such records or documents presentlyexist.2.GeneratorsWith the exception of Pervel Industries, Inc., all of the businessrelationships entered into between the generators and Yav/orski, Inc.v;ere commenced generally with the knowledge and/or upon the recommendation or approval of Connecticut Department of EnvironmentalProtection (DEP) officials or their equivalent before the creation ofthe DEP.a.Pervel Industries, Inc.Community AvenuePlainfield, CT 06374''"Pervel's Plainfield plant is involved in the upholst(and plastic manufacturing business. It is believed that .good portion of its operations consists of the printing oJ \-i r

U P D I K E , K E L L Y & SPELLACY, P. CLauren Stiller Rikleen,.Esq.March 9, 1984Page 2cloth, paper and upholstery. Pervel dumped cleaningsolutions, chemicals used for v/ashing printing machines andink from the cloth printing operations into the lagoon. Someof the waste barrels indicated that MEK and acetone wereamong the chemicals disposed of in the lagoon. , It isestimated that 80% of Pervel's waste consisted of saturatedrags.Pervel appears to have been a major generator of v;astev;hile the lagoonvvas in operation, that is, from Hay, 1950 toAugust, 1973. During approximately the first ten years,Pervel transported the barrels to the lagoon. Then atrucking firm by the name of Merchant Farmers, from Moosup,CT, transported it for a very short period of time(approximately 2 to 4 weeks) before Yav/orski, Inc. began totransport the material to the lagoon for Pervel.During the first ten years Pervel dumped approximatelytwo loads a day, each containing about 12 fifty-gallon stee]barrels. Beginning in about 1960,.V7hen Yaworski, Inc. begcto transport the material, it is estimated that Pervel woulodispose of anywhere from 3 to 5 loads per day. Each of theseloads would contain about 16 fifty-gallon steel barrels.Besides the barrels, Pervel would dispose of bunker oil onoccasion and from 1970 through 1973, also a tank (7,()00gallons)' of blanket-wash (residue from the printing presscleaning operations) a v/eek.In approximately 1970, Pervel bought out a companycalled Ross & Roberts, Inc. located at 1299 West BroadStreet, Stratford, Connecticut. On occasion Ross & Robertswould have barrels (50 gallon barrels) transported toPervel's Plainfield plant, which would then be disposed of atthe lagoon with the rest of Pervel's barrels. These barrelswere transported by a company called Rapid Transit Truck &Terminal, previously located in the Plainfield area and.nowreportedly out of business.b.Rogers CorporationOne Technology DriveRogers, CT 05263During the relevant time period, Rogers Corp. v;asinvolved in the manufacture of rubber products at its Rogersplant. Rogers disposed of approximately 16 barrels fifty-

U P D I K E , KELLY & SPELLACY, P. C.Lauren Stiller Rikleen, Esq.March 9, 1984Page 3gallon barrels) a v/eek, from 1970 through 1973. The wastewas believed to consist of diluted and dirty thinners andcleaners. The v/aste was transported by Yaworski, Inc.c.Plastic Wire & Cable, Inc.Triangle IndustriesEast Main StreetJewett City, Ct 06351This company was originally knov/n as Plastic Wire &Cable, Inc. (PWC) and was bought out by Triangle Industriesat some point during the lagoon's operation. The plant'sprimary business was the plastic coating of v/ire and cable.From the early 1960's through 1973 PWC disposed of a load ortwo (approximately 16 fifty-gallon steel barrels per load)per month. The v/aste was transported by Yaworski, Inc. andconsisted of cleaning solvents and the waste products fromthe manufacturing of plastic pellets.d.Kaman Aerospace Corp.South Main StreetMoosup, CT 06354andBlue Hills AvenueBloomfield, CT 06002During the time period in question Kaman manufacturedaircraft and helicopter parts, as well as fiberglass guitars.Once a month Kaman would transport a load or tv/o (16 fiftygallon steel barrels per load) from its Moosup plant to thelagoon. On a couple of occasions, Yaworski, Inc. v/asrequested to pick up a trailer load of 78 fifty-gallonbarrels at the Bloomfield plant. Sometimes Raman'sBloomfield plant would transport waste barrels to the Moosupplant for eventual disposal at the lagoon. Kaman's wasteconsisted of paint and glue residue, cleaning solutions,degreasers and some type of acid solution derived from itschemical milling operation.e.Revere Textile Print Corp.P.O. Box 552Branford, CTRevere was in the cloth and upholstery printingbusiness. From approximately 1968 through 1973, Yaworski, "

UPDIKE, KELLY & SPELLACY, PC.Lauren Stiller Rikleen, Esq.March 9, 1984Page 4Inc. transported from one to three loads per week (about 16fifty-gallon steel barrels per load). The waste consisted ofpaint thinner, some type of kerosene solution used to cleanmachinery, dirty ink, and paper and rags saturated with inkand oil drippings.f.Inter-Royal CorporationCommunity AvenuePlainfield, CT 06374During the time the lagoon was in operation, Inter-Royalmanufactured metal furniture, office equipment and hospitalequipment. From approximately 1968 through 1973, inter-Royaldisposed of one or tv/o loads (16 fifty-gallon steel barrelsper load) per week. This material v\7as transported byYav\7orski, Inc. and is believed to have consisted of cleaningthinners, dead paint from spray booths and acid material usedto clean metals, which had been mixed with me prior todisposal.g.C & M Corp.So. Walnut St.Wauregan, CT 06387C & M's operations included the plastic coating ofelectrical v/ire and cable. It disposed of several loads (16fifty-gallon barrels per load) of waste per year fromapproximately 1968 through 1973. The waste was transportedby Yav/orski, Inc.h.Daisey Print Works. Inc.Wauregan, CT 06387Daisey's present location is unknov/n. For the lastcouple of years during which the lagoon v/as in operation,Yaworski, Inc. transported several loads a year of v/astebelieved to consist of dirty ink from cloth printingoperations and thinners.i.Ivy Printers, Inc.Wauregan, CT 06387Ivy's present location is unknown, although it may havebeen purchased by C & M Corp. a few years ago and itsoperations were possibly moved out of state. For the last

U P D I K E , KELLY & SPELLACY, P. C.Lauren Stiller Rikleen, Esq.March 9, 1984Page 5couple of years of operation of the lagoon, Yaworski, Inc.transported several loads a year of dirty printing ink andthinners (about 16 fifty-gallon steel barrels per load).3.See the response to question #1 above.4.During the lagoon's years of operation, Yaworski, Inc. doesnot recall one episode involving a spill or release of waste to thesoil, surface waters or groundwater. This statement excludes anyreleases which might be attributed to or a result of simply thepresence of the material in the lagoon area itself.Since the lagoon ceased operations in 1973, two separatedewatering processes have taken place at the site. In the summer of1975 the Connecticut DEP and Yaworski, Inc. jointly participated inpumping the free liquid from the lagoon into two sand beds constructedon the west side of the adjacent field, v/hich is used for theproduction of silage corn. In 1982, pursuant to the terms of theconsent order entered into with DEP. a drain pipe was placed in thedike at the v/est end of the lagoon. This drain pipe allowed thelagoon's free liquid to drain to a natural depression southwest of thelagoon. This drain pipe was removed by Yaworski, Inc. v/hen there wasno longer any free liquid remaining to be drained from the lagoon.5.As v/e discussed with you at our recent meeting, the closureplan as contemplated by the consent decree with DEP is approximately95% completed. The remaining work consists of loaming the existinglandform and planting a vegetation cover. This vegetation cover hasnot been put in place principally because of its inconsistency orincompatibility with at least several of the possible alternativeremedial measures discussed by EPA's contractor NUS in the RAMP.Pursuant to the consent decree with DEP. and with DEP's knowledge andapproval, the lagoon has been filled with non-hazardous bulky materialssuch as timber, brick, baled vinyl and cloth, etc. The bulky materialhas provided a stable base for equipment used in the filling operation.The bulky waste was compacted and the lagoon area backfilled to form alarge mound where the lagoon was once located. Besides the wasteitself, the empty barrels, which v/ere in the lagoon due to pastactivities, have been compacted into place with the bulky waste andbackfill material.6.Hazardous substances, hazardous waste, pollutants orcontaminants from the lagoon have not been used as fill material.7.See the response to #5 above.

U P D I K E , K E L L Y & SPELLACY, P. C.Lauren Stiller Rikleen, Esq.March 9, 1984Page 6':8.For approximately the first ten years (1950-1960) ofoperation the area vs hich is now known as the lagoon consisted ofapproximately six pits into v/hich waste was deposited. Each pit wasapproximately 8 feet deep and 12 feet wide by 36 feet in length and v/ascapable of containing approximately 100 barrels of waste. Prior tocommencing operations, the local State Health Officer, Doctor ArthurBarry, approved the location of the disposal area. The StateDepartment of Health also approved the burning of the pit contents.The capacity of one pit would be exhausted and ignited before disposaloperation would commence in the next pit. This process was strictlyadhered to in order to ensure that the pits had cooled sufficientlyprior to the acceptance of additional waste.During this time period, Pervel disposed of waste in the pits, ofwhich approximately 80% consisted of saturated rags. On a number ofoccasions, Pervel hired contractors to clean out the pits so thatadditional waste could be accepted. As a result of the cleaningoperations, the asheis and bupned metal residue would be bulldozed outand to the side of the pits. The area where the pits were located anv.the burned residue was bulldozed is within the four acres nov/ referredto as the lagoon.In approximately 1960, pursuant to a State order and directive,Yav/orski, Inc. ceased burning the waste and began to lagoon thematerial. There was a causeway leading out into the middle of thelagoon. The transport trucks would drive down the causev/ay and pull upto the lagoon's edge on the east side of the causev/ay. The barrelcontents would then be emptied into the lagoon. The barrels themselvesv/ere never dumped into the lagoon, unless the contents had hardened andcould not be emptied. When the contents could not be emptied, then thebarrels would be disposed of after the top had been removed and/or thesides split so that the contents would eventually empty as the sundried the material. The salvagable empty barrels v/ould be returned tothe respective generators.Once or tv/ice a year Yaworski, Inc. would rent heavy equipment toscoop the rags from the lagoon's unloading area east of the causewayand pile them in another area of the lagoon where the sun v/ould drythem out.For the first fev; years that the material v/as lagooned there wasno need for a dike because of the natural depression in the land.However, in approximately 1962 or 1953, Yaworski, Inc. was instructedby Dr. Barry to build a dike to contain the v/aste materials.

UPDIKE, KELLY & SPELLACY, P. C.Lauren Stiller Rikleen, Esq.March 9, 1984Page 7Subsequently, on three or four separate occasions, the DEP instructedYaworski, Inc. to build up the lagoon's dikes in order to contain thewaste. Pervel paid Yav/orski, Inc. to! build up the sides of the lagoon,so that additional waste could be accepted.9.Prior to 1950 the lagoon area was open pasture land, whichv/as used to graze cows. The area was not used for the disposal, ortreatment of hazardous waste.10 and 11.See the responses to #2.Should you have any further questions, please feel free to contactthe undersigned. We v/ill provide additional information as acquired.Very truly yours.MARK J. ZIHMERMANNcc:Yav/orski, Inc.::3

updike, kelly & spellacy, p. c. counselors at law ii -a p o h \ 'n peter g, kelly bourke g, spellacy thomas j. short ell thomas w. demille charles f. corcoran, m paul l. mccormick james h. lloyd. id john c. king john r. mallin james t. graham elizabeth r. collins alan i. scheer of counsel douglas m.

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