The Site is a 100.8-acre vacant lot located in Litchfield County, Watertown, which abuts the town line of Waterbury.
From 1868 to 1976, the Site had been used as a waste disposal area for process waste including metal turning waste and construction debris generated by CB&C. The exact manufacturing processes and types of waste generated were not documented.
In December 1999, the Connecticut Department of Environmental Protection (CT DEP) referred the site to the EPA Emergency Planning and Response Branch (EPRB) as a potential removal Site.
In March 2000, the OSC conducted a Preliminary Assessment/Site Investigation (PA/SI) and observed the following:
• Two empty above-ground storage tanks (ASTs) were outside the chain-link fence at the north side of the substation fence.
* Numerous areas with noticeable and partially buried rusty crushed drums and metal debris were along the embankment/ river bank downgradient from the substation.
• Stained soil and stressed vegetation were along the embankment/riverbank.
• Miscellaneous construction debris and metal turnings had been disposed of at various locations on-site.
• Several small containers and 55-gallon drums were along the embankment/riverbank.
• The City of Waterbury had installed a couple of sections of chain-link fence on the access bridge in an attempt to restrict access. However, the fence has been breached and the site was accessible to the public.
• Beer cans and other food and beverage containers were noted on-site.
EPA collected the miscellaneous samples and revealed the following:
• Chrysotile asbestos concentrations in the bulk samples ranged from 5 to 80%.
• The maximum concentration for each heavy metal found in surface soil samples is as follows:
- copper, Cu (56.6 %)
- zinc, Zn (8.48 %)
- lead, Pb (3,160 ppm)
- chromium, Cr (5.34 %)
- nickel, Ni (2.39 %)
• The maximum toxicity characteristics leachate procedure (TCLP) concentration for each heavy metal found in surface soil samples is as follows:
- Cu (1,460 mg/l)
- Zn (1,100 mg/l)
- Pb (16 mg/l - estimated)
- Cr (13.5 mg/l)
- Ni (10 mg/l)
• The total PAHs concentrations in surface soil samples ranged from 47.9 ppm to 2818 ppm. Other SVOCs including dibenzofuran and bis(2-ethylhexyl)phthalate were above detection limit.
As a result of all of the above, the OSC determined that the Site warranted a time-critical removal action.
The Deputy Office Director of the EPA Office Site Remediation and Restoration (OSRR) signed an Action Memorandum dated August 29, 2000 authorizing a removal project ceiling of $1,999,200 to perform the following:
• Provide site security measures (including, but not limited to, repairing existing City-owned chain-link fence and/or installing a new chain-link fence) to restrict access. If deemed necessary, provide security guard service.
• Conduct topographical (land and aerial) survey to establish base line reference (e.g., elevation) for further removal planning.
• Conduct field survey/evaluation and/or literature research for rock contour plan.
• Conduct structural evaluation/analysis of the access bridge to confirm that the bridge is viable for transporting heavy equipment.
• Evaluate alternatives for equipment access including, but not limited to, feasibility of repairing existing bridge and/or constructing a temporary access bridge.
• Conduct additional sampling including, but not limited to, conducting soil gas and mercury vapor survey to further delineate the nature and the extent of contamination on-site and installation of monitoring wells. The result of the sampling will be used to estimate the volume of the waste that needs to be removed or otherwise stabilized/treated. Off-site activities may include sediment and water sampling in the Naugatuck River.
• Remove and dispose of drums.
On August 28, 2001, the OSRR Director signed an Action Memorandum requesting a ceiling increase, 12-month and $2,000,000 emergency exemption approving the following scope of work:
- Investigation of the Substation: Despite the fact that EPA had done a comprehensive sampling for polychlorinated biphenyls (PCBs) at the electrical substation, there were three pieces of electrical equipment and a man-hole for underground electrical wiring which may still contain PCBs. At the request of Trout Unlimited during the June 19, 2001 meeting, EPA will access these areas for inspection in cooperation with Connecticut Light and Power. Pending the inspection of the equipment and the man-hole at the substation, EPA will sample and address these areas if deemed necessary.
- Development and Implementation of the Engineer- Designed Cleanup Plan: The engineer-designed cleanup plan consists of the following:
• excavation and consolidation of contaminated soil, debris and sediments along the riverbank;
• placement of these materials in areas above the groundwater table;
• slope protection and stabilization;
• construction of a soil cover, a drainage and erosion control system; and,
• implementation of the site restoration plan.
If necessary, de-watering and water treatment operations will be set up and implemented to facilitate the excavation.
This Plan will mitigate any direct contact threat posed by the contaminated soil and debris to the public and also mitigate the transport of contaminated soil and debris to the Naugatuck River. To the extent practicable, the OSC will continue to coordinate with the City and other interested parties to accommodate any plans the City and other parties may have for the future development or use of the Site. The OSC will also continue to consult with CT DEP, USACE and Trout Unlimited and address, to the extent practicable, issues related to restoring habitat via site restoration.
- Materials including Empty Drums and Miscellaneous Scrap Metals debris that are deemed not to be appropriate to be capped: Materials uncovered during excavation and deemed inappropriate to be capped, e.g., drums, containers and packages with contents, will be removed, inventoried, sampled, and recycled or disposed of at a CERCLA-approved offsite disposal facility.
- Site Stabilization/restoration Activities: EPA will restore the Site to a physically safe condition and also, to the extent practicable, in a manner that is consistent with the restoration activities planned and/or conducted by the Naugatuck River Corridor. EPA, the City, CT DEP and Trout Unlimited agreed in principle to the following site restoration features:
• A river’s edge walkway will be incorporated with habitat enhancement features, where feasible;
• The final size of the staging area will be minimized and have no paving as requested by CT DEP;
• The access road to the substation will be restored as requested by the City; and,
• The final site conditions will be such that minimal future maintenance will be required as requested by the City due to the City’s financial instability.
