Site Location
The 9.6 acre Brunswick Mill Site (Site), located at 57-59 Brunswick Avenue in a residential area of the town of Plainfield, Windham County, Connecticut, is bordered to the north by the Moosup River and North Main Street (Route 14); to the east by the Moosup River; to the south by Brunswick Ave., a private residence, and a Town sewer pump station; and to the west by private residences. The site includes an abandoned two-story office building, a demolished three-story mill building, and a garage. The abandoned mill building had been destroyed by a fire in 2000, but the northern and eastern portions of the mill remain largely intact. The majority of the mill building is in a state of disrepair with portions having collapsed onto themselves or into the Moosup River, a Class A river under the Connecticut State Water Classification Program. The river is used for fishing and various other recreational activities. Approximately 57 homes are located within a quarter mile. An elementary school is located approximately half a mile away.
Description of threat
The Site was owned and operated by a defunct business, Brunswick Worsted Mills, Inc. (Brunswick) and is located adjacent to another mill operated by a related company, Carvill Combing Company (Carvill). Industrial operations took place at both facilities from the 1890s until the 1970s.
On October 21, 2000, a fire broke out and destroyed the abandoned mill building. After the fire, the three story structure began to collapse. On October 23, 2000, the town of Plainfield hired a construction company to stabilize the building. In the course of performing this work, the construction company discovered abandoned transformers and exposed asbestos, and immediately ceased operations. The fire had also caused asbestos from the building to be released into the environment. Subsequently, CT DEP and the Town referred the Site to EPA’s Removal Program.
Current Situation
START engineers prepared specification plans for demolition/asbestos removal. Shaw E&I (EPA ERRS Prime Contractor) subcontracted effort and received proposals from prospective demolition/asbestos removal contractors. In December 2003, Shaw awarded the subcontract to Dec-Tam. ERRS Subcontractor Dec-Tam mobilized to the site to install additional perimeter fencing and begin some pre-removal activity measures such as starting the installation of erosion control measures. Background perimeter air sampling for asbestos and lead and aqueous and sediment samples from the on-site fire suppression pond have been collected. Samples for total lead and Toxicity Characteristic Leaching Procedure (TCLP) lead analyses have also been done. At this time there is no field activity on-site while the ERRS subcontractor resolves comments by CT DPH to their alternative work practices plan.
Activities since the last POLREP:
• On September 11, 2003, EPA/START mobilized to the site and conducted supplementary surveying activities at the site.
• Since October 2003, OSC Allen Jarrell assisted OSC Tsang in coordinating field activities including attending meetings and participating in conference calls for the site.
• On October 7, 2003, EPA/START and the EPA New England Regional Laboratory (NERL) mobilized to the site to conduct sampling and field analysis of the debris piles for lead and asbestos, and in-situ lead analysis of painted surfaces of standing portions of the mill. Confirmation analysis was conducted at NERL on 10% of the debris pile samples.
• On October 27, 2003, EPA/START and CT DEP met with the property owner to review and discuss EPA’s demolition/asbestos removal scope of work.
• On October 29, 2003, EPA/START/ERRS conducted subcontractor bidwalk for site demolition and asbestos removal.
• On December 10, 2003, a pre-removal action conference, including representatives of EPA, CT DEP, CT DPH, START, ERRS, Dec-Tam Corporation, Dec-Tam subcontractor New England Disposal Technologies (NEDT), Town of Plainfield, and Plainfield Police, was convened at the Plainfield Town Offices to discuss project specifications, logistics, scheduling, and safety requirements, etc.
• From December 15 to December 17, 2003, START/ERRS and Dec-Tam personnel mobilized to the site to construct a vehicle/equipment decontamination pad, install additional perimeter fencing, secure the on-site corrugated metal building for equipment storage, and begin installation of erosion control measures. Two office trailers were mobilized to the site, and electric and telephone service were installed at the ERRS trailer. START conducted 2 days of background perimeter air sampling for asbestos and lead. NEDT personnel mobilized to the site and collected aqueous and sediment samples from the on-site fire suppression pond.
• From January 20 to January 22, 2004, START, ERRS, and ERRS subcontractor mobilized to the site to collect samples from the on-site debris piles for total lead and Toxicity Characteristic Leaching Procedure (TCLP) lead analyses. Dec-Tam personnel utilized a mini-excavator to access the interior of the debris piles, and START personnel collected four composite samples for analysis at a private laboratory procured by ERRS. START conducted a third day of background perimeter air sampling for asbestos and lead, and OSC Allen Jarrell mobilized to the site and inspected site conditions and sampling stations.
• Provide site security measures to restrict access. If deemed necessary by the OSC, provide security guard service.
• Conduct topographical (land and aerial) survey to establish base line reference (e.g., elevation) for further removal planning.
• Conduct structural evaluation of the building, the dam and its hydroelectric power plant and implement the recommendations as required in order to allow safer access to these areas for the cleanup.
• Conduct additional sampling including, but not limited to, conducting soil, water and sediment sampling to further delineate the nature and the extent of contamination on-site and installation of monitoring wells. The sampling results would be used to estimate the volume of waste that needed to be removed or otherwise stabilized/treated.
• Sample, stage, analyze, remove and dispose of drums.
• Segregate, stockpile and dispose of asbestos-contaminated debris to a CERCLA-approved disposal facility.
• Evaluate cleanup methods for the water pit and soil contamination. Data obtained from sampling soil, water and sediment will be used to determine the appropriate removal cleanup methods. The removal methods to be considered include removing (via excavation, treatment and disposal), or otherwise stabilizing the contaminated soils and/or a combination of all of the above. The method selected will eliminate the threat of direct public contact with contaminated soil and will also reduce the potential for off-site migration.
• Conduct building demolition and/or reinforcement and site stabilization/restoration activities in accordance with an engineer-designed plan.
• Perform applicable air monitoring.
∙ Perform applicable environmental sampling and monitoring including soil and/or water testing during the removal.
• Perform a land survey and document the Site conditions with as-built drawings if deemed necessary by the OSC.
• Coordinate with CT DEP, CT DPH, START and ERRS for asbestos removal and demolition plans.
• Commence the removal actions.
Some of the masonry wall of the mill building serves as the hydroelectric dam wing wall. Special demolition procedures must be implemented in order to minimize any major vibrations that could cause the masonry below the dam forebay water level to leak.
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