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Misc Correspondence 300 Rye Street (2)
Town of South - POLICE SERVICES Vindsor INCIDENT REPORT 1.Incident Type 2.Location of Occurrence SWAX 1 9.Data TFack S.W. - 300 Rye St. 6 i? j 4 Date Occurred 5.Day 6.Time 7.D to Reported 8.Day 9.T e 31 Oct.92 Sat 1844 �4 4�56 INVOLVEMENT CODES: V-Victim S-Suspect W-Witness A-Arrested RIP-Reporting Person O-Other J-Juvenile 10 Involve° 11.Last Name(Business Name if Victim)First Middle 12 Race 13.Sex 14.Age 15.Date of Birth Wells Fargo operator �461 UNK, k 16.Hgt 17.Wgt. 18.Hair 19.Eyes 20.Drivers License 21 Miscellaneous 22.PIN Number TINK 23.Home Address SW ❑ 24.Home Phone 25.Business Address SW ❑ 26.Business Phone 80 State Street Hartford Ct. 249-7555 27 n olve�f 28.Last Name(Business Name if Victim)First Middle 29.Race 30.Sex 31.Age 32.Date of Birth S.W. Metallur ical N/A 33.Hgt./A 34.Wgt. 35.Hair, 36.Eyes 3ZDrivers License 38.Miscellaneous 39:PIN Number 40.Home Address SW ❑ 41.Home Phone N A 42.Business Address SW K 43.Business Phone 300 Rye St. 282-0871 44.Narrative Section A:Summarize details relating to Incident A Fire Alarm was reported for the above business. Toxic-type smoke was `found to 1 be roming from the building, Lt. Godin assisted me in blocking Rye street so that 2 yi--hicli-S �ioiild not drive by the affected area. 3 Chief Sk'lton that the smoke was caused from printed 4 smoldering. Apparently, the boards are burned and 5 then placed into a barrel, The boards are then covered and st,op burning. Some- 6 thing wpnt wrong and the boards continued to smolder several hours until the 7 alarm wpnt off, No one was working at the time. 8 9 10 11 12 13 14 15 16 17 " 18 45.Emp ee's Signature EIN Number 46.Accomp.Ofcs.EIN 47. rove Appd By 48.Additional Copies a 110 100 RELEAS OF ANY JNFOR TI N CONTAINED HEREIN SUBJECT TO ALL APPLICABLE LAWS 49.Page 50.Case Number .WPS.RR fR_9A1 1 of 1 92-08152 7C1�-c'1-1y 1U;jw FROM SOUTH WINDSOR POLICE SERV TO 6443781 P.02 - Town of South POLICE SERVICES Vindsor INCIDENT REPORT 1.Inofdent Type 2,Location of 0comence 5W 13.061ama* f• 4.pate Occu*red 5.D 6.Time r.Date Repotted 0,Day S.Tg" INVOIVEtYtENT OODES: V-Victem S-Suspm W-Wetness A-Arrested RIP-Reporting Parson O-Otber J-Juvenile 1 1 ",i"v 4; 11.LAM Name(Business Ntrakl If ftlim)Fimt M1010 12.Race 13,Wx 14,Aga 15.Date of Birth/ .`A.,. 16,Hilt, ... 177.wpt. 18.Hair 19.Eyes 20,Drivers Liwn$c 21.Misce44aneouS 22.PIN Numbe, 23.(Horne Address sw 24.Home Phom !•} 25.Busi�my_es Address SW O . 26.11winese Phone fT . 27.r, tve ;;: 29L Last Name(Susineas N*mo 41 Vletim)First Middic 29.Race 3d;S 31,- 32. e ,f Birth S LiO�•E ti D e M f- #R't.�L ti+r 6: r-ft K) R 11.J ri 34.wgt. 39,Hair 36.Eyas 37,Drivers 1.4eeme 38.Miscellaneous 139.PIN Number 40,HomeAddreSs SW Q Al.Home Phone 42.Business Address SW xe 43,4usiness Phone T 44.Narrative Section As Summadto dotaits reiatfnp to inckk"O Rrt eft LLC-k Ll FQ jzY ej�2-vL j _ SLJ L F U Z QV- P E,STC£-1 p E TYp 0-0-0-IL WA_S jD F r F-C' 4 R n 7 CRY1 aALF AF PA-Ln ! BM S C c `,1 b. A L P L U M � . 1n S l fl S D m Tt-� 7 1J Li nfl I,-)fts mu-r op `T teVfST 7.9 'P- 14.2 A 11 nT A STA-r6 10 11 12 t� 14 15 16 1$ 1� a toys` I n turd IN Ntamber 46,Accomp,pfes.ON 47.Apo"8y 4i#,Additicaa!GDpfeB C7�Lr! �aU� RELEMIE OF ANY lblFtJItAMATiON CStdTAYttEO FE19£lN SmEGT TO ALL APPLlCA91.E LAWS 46•f'p4e TOTAL P.02 t J h sa� 1540 SULLIVAN AVENUE • SOUTH WINDSOR. CONN. 06074 �,��soe.cora AREA CODE 203/644-2511 Fax.# (203) 644-3781 FACSIMILE MESSAGE TRANSMITTAL FORM G � Date PLEASE DELIVER THE FOLLOWING PAGES TO: NAME: 130` l ct, ADDRESS : FAX. MESSAGE FROM: NAME. ADDRESS: J��,GyTtc�sv/- /V cx� D MESSAGE q/i s C-C,3-.1 i vq NUMBER OF PAGES TO FOLLOW:,/ If you did not receive all pages (including the cover) or if you have any questions,, please call 644-2511 'as soon as possible. a 2 .f��1R�134L 11�12l�Ii 'FRI'A , • y PX o r::. dwd- S News' , 4, � a• �}�h i 5145. <FY: � i �ew A `■ eiia 4. ty: � - fp�,,,.•Fi4'`� } rt r, <'. •.8. :G,,_.;. b �q �% '�.Y �`� w}N: ' � - !« is ,rethNU BACKING, .DOWN.,.Family, pl n iri brit un.*. roughout the.country, including°those' kof Planned Parenthood of Connecticut;,-say;they'll;risk;�losingF federal aid rather than refuse to,.counsel:their,-,clients imposed'pe lties: 4 " "'* 'wine from a metal reclamation 'in- about abortion. And four:members of;;the,.state s B EILEEN McNAMARA �John•Bullock,the.metallurgical com-,'cinerator at the refinery. Congressional delegation say,they'll.push to reverse Y pany's lawyer for environmental issues, "It took us a long.time to even.track Journal.Inquirer Staff Writer a ban on abortion counseling that was upheld Thurs ` said today company officials have not down.the.source of the odors,"Pave to day by the U.S. Supreme Court Page 5 -,Y`* _ SOUTH WINDSOR. r A local r jet reviewed the=order`'and haven't 'said,, adding that airborne fumes .are metal:recove 'coin an has been;?orF N , r ry. ,, p y decided wha! action,they'will;take transient",and difficult.to trace. . TOWN LAYOFFS._LOOM. '.Since'the=East Hartford Mtdered.Eby,•<state,environmentalyofficials `� He said," however, companyXfiad- The,DEP, stepped-up: .its monitoring Town Hall. workers rejected a'contracf.that would to stop emitting noxious:odors and lias e:•ministirators are still not:convinced that' and unannounced inspections at..the have,frozen.their~pay fora Kyear.,' Mayoreltusa„ -G . :<r been told�t;must draft a planto�reduce the.company is the source of the odors. ;; lantlast earfollowin increased coin- . Kniep said today that there,could=be;a sizabIaAa. ff �the'emtssions �" �"�- h' ''' � ".No'one's�yet identified where the plaints from residents in the.Farnham The union rejected the.contract,which uaranteed no; - Although the order, issued Thursday "odors are coming from," Bullock said., 1 9 Environmental^ Protection ,,Coin "-It's in;extremel =difficult',situation" - Estates subdivision.of a chlorine like layoffs,°because"of;*.a clauseT requiring meml)ers• o Eby , Y . fry, * a 5. ercent of•:thei salt era 1 masstoner Timothy.R.E.,..,Keeney,-,states H-:said,South Vindspr�Metallurgial P Y _p a y4 „+ ,E ., xThe;homeowners.:haxe,said>that:-.the. that:South"Windsor'Metallurgical`Ina `'would•`contmue`rts ownmonttomg'to odors_. sometimes are so strong some -T - must,addre_ssodor emission problems at ;determine' from'where..- the -smells - g NEW BUDGET PROPOSAL.,MADE�4f ter this•w. eek s:� �. the :;R a :`:'`StreeC'` precious `'metals 'emanate. ' $'-have difficulty breathing defeat of a 1991-92;budget prgposalrsWmdsorw,_q �' ~ -Y P r -- "' y µ" 'Re Kevin Rennie"'AR-South. reclamattan plant,wtthin 24 hours,state,, :The:DEP.'order represents a more P Council members,:have •formulate. a ew 0,,wo �lavv 'ants:an`a to atic' to of 30 da �ythan- ear-lon 'effortu dent en theme�!mdsor,swho Chas ;been helping�'`the $47.2 million, reflectin ra.-2:75 ercent,i 4reas iciver` ..� s Y Y�, 3a: ..fir 9. P - ; , e> during .which 'Ume...company officials agenej+. ao etermme•�;,the ourbce of; residents:in their'efforts to get the;DEFT . current`spendmgaThe.•new:proposal hasKraised?the can a `ppeal a the decision io the'En 'odors to the=Rye *Street'$area wthat ;toaake action against., company,said hackles'of those'in favor.of-freezing.spendingand �,uonmental?,:rotectton De artment.; "; nearby;restdents;'haVe�''said are',objec today he,'`hopes-'Keeney's°order,solves those who think the school system will suffer if more `�� '• q • p - .., r `The r order',re utres the metal re tionable 'and . may be a w health the long-standing problems.` cuts are made Page 12. �} covery'company`to bring its emissions ahreat - "This has been a very long undertak-, intg;compliance with state law and to Carl Pavetto, chief.of the DEP's air. ing and this order will provide perma- r r^4 , ALL IN THE FAMILY.?Louis Failla thinks'the world of 'adopt:a perm.anent compliance plan: management�bureau,;;`said.Y today his 'vent relief Rennie;said ".We're very e . Y agency rmmed that the odors pleased" his grandson, according to.-both;the 1a g ,. R it falls to do so,t t could face court a en has dete L g gwyer for,;th � } East Hartford .racketeering defendant and a gvecn ment informant who testified against Faillarin federal x '• ` �� Curre to:seek�return=to drool court this week. But they'.disagreed duringcross s y .� s board .. •fin. h,4. 4F.�,r (> .� .�;i,, d �?^',.+a r�,;}rY9K 'c t. r h?cb f .[i examination "Thursday over wbgther�t Faille hh �€ . make a'run;;for the"Town Council this fall., sought to kill.the lad's father Page�'17t��''y; �(crL� �A �,r �` « � �� �',Y By::ANDREW..P. NELSON t r -.I:ve,;been;looking;to get back into the public sector, ,lournal Inquirer,Staff Writer-: -• De.Crescenzo said thismeek. The school board, now that I Editorials fr comment , "� " have a daughter, is something I m interested in. THE 'CONVENTIONAL'.BUDGET.<It es �[rtue'or EAS'lr HART);ORD —`.Board.of Education z ;The $3-year old lawyer this winter lost a bid for De- ,... h a,v_ ,., well I f i I �. ;Donald M:`:,Currey`said he!seeks'his'fourth.term,on.,the mocrat�c sown: chairman to John W.`:Shaughnessy"'He two, as a as a lot.o big prob erns,,B, -4.'. ep most , `school,board,this fall faced:with the:challen a of runnin the•."became"assistant-'publicworks director in 1985 after win nin attractive thing r about,.it is that„it 'pr .r►ies' the" 'x hools''.duriri economic'hard ttmes tfi, g' g= " raise as a?ma al; aid for helping:ex-Ma or Robert:.F deadlock and convulsion in, state- overnment,that r ��f g �+ P Y Y r ,; $ , was"a pxoached;_for other offices, the;Democrat said SFMcIVulty adjust.to Town Hall. contractor. Connecticut needs Page 30:':Yrk � �;;.� �`�, .gi wee a ` pt I:don't think anything ts."emore,,m ortant A`-.1975' raduate of the old Penns Hi h,School;he works a g� 4 �f� artford lyr:firm.of Updike Kelly-& Spellacy. ,p t ' an•thg�education,,we give our, of`.the Ii LIVIn & . ., 'r4 : `'' r' ``' s� a=ti Detnbcrattc :Town •'Committee .endorsed r.:Currey, �.Currey ;:40, `as;named:chairman after winning his third g ` � .yMichael Christ;who is,seeking,hissecond term on.Xhe board; four-year-term on``the school board in. 1987 COUNTRY.:CONCERT '.Radio:s atio ; .-„ �FMt '`andfo ei'town::offici I Robert`1VI escenz '� who' r' a said.the'achool board faces.:the;challen a of running �. I t, , ; promoting one big;=countrym inustc*rconcartt'an '',ex+� ^seekang�hts fuel term;. yN ~tas r h:�,: golsY-during a=time whew, money for education':is w A �,. �+tti,TM—�FI ,'�9.4.� V4 1� . .. y+r. 1, T�tN.+..4'•L`� C'h pects o sell 35,000 tickets;far th,";tJuly T eventyat+they" .' ° �DeCre$cenzo�was!;a:`.former assistant"directory of public ,running:low.""As chairman, Currey is trying to recoup a Big E: Station personalities.arext avelmg'to differeP. rks'`and;'assistanflii ex-Mayor George A:'Dagon On;the 14 nearly.,$4'million cut in,the school budget,made.by;the.mayor` locations in their listening area o e 'tic ets p�f1r. p,) `�` school'board'•he would replace 'Richard:'Kghoe,',who will a}j1jd;"TowntCouncil' I. 9 t, ,.. :W�C;+wsg:..16.t7ay.. ,',c..s.•.i, qA'+>:'. .•7,,....a'^4R'1 ^•. cs .�...;d'w°.'38...W�roc:,:,s .....`�i',. .e+•a ri«.pas,Gk :. is. SA?. r r, u. E f Efts "y tf?}< 2gF}ft 2.ffE ri: 8 kF{ 2ti E 9 - n ? t f 3 COMPLAINT COMPLAINANT ram' - - ADDRESS . SEX ���LLL•. DOB PHONE NO. - - 07 INCIDE T LOCATION Q in a 44 in N REC'D BY DISP.BY - OFF. SSIGNED '+1 Zt Z d UNIT ASSN'D BACK UP S1GNA TRACT DAT &TIM/�OCCURRED rr ti REC'D - DISP. - ARRIVED CLEARED a /l073 REMARKS/VEHICLES INVOLVED - IL UI -- - .. _• - _ .. _ C 1 •Q 4 1 I- Q ► a In a�•1 f NAME OF PERSON INVOLVED ADDRESS _. SEX DOB - PHONE NO. NO REPORT ❑ACCIDENT ❑INFRACTION ❑CASE ❑U.A.R. ❑MISDEM. ❑WARNING ! CODE — -"VIEWED BY j SWPS y,` !.ti 3�E> Ek ''ify2i, yy�1 ~2{}} r'` .�22f -.�. ..,� rs•. t. ""R qrr ten.'!x r rc a < tii .1 S y , f �}}b� 22ti.`� •;'��`r3��� ��}�'jjt�?Sl �v t�tatifti y,`}}1 [ ,3 s ! j!l1i�ii jil yr} ; :�M1 �• > {}' ., � - m i• ...s.. - _3. .. .._. .. .. .... .reif,.. ?Ch_-.° .[; � .4#"v^.•. •:'�7. -. ��� - `ifF 1•.'� 5 `+s.r. 2�ss t - ,,_�F<!�;,t}�Nyt t}f}, t}!}2>f;F} f<r#;�Y;F >;' {�2;2 f,•:`##}# "# # #f ;<4' f3£ f #? ?�;,,Y.,.# } ,!f#,s3}isff?}�FfF<!` ,i,i;7!l: ! � ��t i<rf!> ;i'?�?t;!?F:h<;#f?` ti { COMPLAINT A fi Q)og Comm i' lyr to C MPLAINANT / 2 s ADDRESS 113A R. V. 1 �UV rf< - SEX DOB PHONE NO. a • - INCIDENT LOCATION r lYl� n r a IA f REC'D BY DISP.BY OFF.ASSIGNED N 03 €(�t} UNIT ASSN•D BACK UP SIGNAL TRACT Zs t Z DATE A TIME OCCURRED _x O Q _ 7 REC'D - DiSP. ARRIVED CLEARED 2 s I ! } IL r)n W 036 Una 7 W RREamp. MARKS/VEHICLES INVOLVEDAl R ,k•+a,.::; ;7i•erFrf'cr•:f.,t ;( <.:: ~Y?:Y YsY Et, t J NAME OF PERSON INVOLVED }f ! ! ADDRESS r - SEX DOB PHONE NO. 4NO REPORT ❑ACCIDENT ❑INFRACTION CASE ❑U.A.R. ❑MISDEM. ❑WARNING Z. t CODjA REVIEWED BY SWPS-19(11-88) Y t}�Ia ?•}YY 2 `' jrY tk �,•,!YF 2Y• .Yr f •SiS,, IYYY�i }2#ff>',I,y #Y�! I, ?#YjY; �,E. 1 - _r�.�� •k!#:fr, `�. -3^: €�' �I,s �i'' -F f 0,0 U w� 7111::)'U� ap Slot,& V&"�Ot 1540 SULLIVAN AVENUE • SOUTH WINDSOR. CONN. 06074 soR•ca�� AREA CODE 203/644-2511 July 19 , 1989 Mr . Thomas Flynn South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 Dear Mr . Flynn: As follow-up to our telephone conversation of July 19 , 1989 regarding the chemical odors noticed by area residents, I appreciate your assistance in resolving this problem. As I have reported, residents have noticed said chemical odor in the area of the South Windsor Metallurgical Facility on numerous occasions in the past. The latest incident was on July 18, 1989 late in the afternoon between the hours of 4:00 p.m, and 5 :30 p.m. . The odor has been variously described as an iodine-like odor and as a sweet/sickening chemical smell. Please contact this office when further information is available. Thank you for your cooperation. Very truly yours, (11 C. F . Shaw Assistant Director of Public Works CFS :bmr cc: Robert Deptula, Environmental Health Officer Michael Gantick , Director of Public Works .14 Journal Ir'tguu'er DAY,MARCH 14, 1991 1T WIN, 4 r HA.! fine, f� m to ay';_isa eta _ r A reement' settles 22 violations' of employee health, saftey regulations hire an outside co' nsultant to helptrain the and poured into ingot molds.The ingots are respirators designed to protect :workers By KEVIN MAYHOOD employees in handling a wide range ,cooled and separated according to the major against lead exposure: hazardous in John Stanton; OSHA metal contained. Lead was also allowed to accumulate'on Journal Inquirer Staff Writer area director said. all the issue The exhaust from incinerating and melt- cafeteria surfaces, and.employees were not SOUTH WINDSOR..— South Windsor "We s, Stanton ing is channeled through a complex system required to remove lead contamanation Metallurgical Inc. and the Occupational. said. What we're getting is'protection for of heat exchangers-and water scrubbers and from their work clothes before entering the Safety and `Health Administration have the,people who;work there, which is very a bag house that.collects'airborne particles. lunchroom, OS14A found. agreed that the Rye Street stration. nery importantao us." . ?: ' ' The dust collected is shipped overseas _ Lead was sometmes swept, not vacuumed g 9 as safety standards require' and when will pay $7,000 in fines and hire an outside. ' `Stanton said his a en is not,aware that where metals are reclaimed.The li uid and agency to train employees in' handling` any employee has become ill;from exposure, sludge` from the filtering processes are vacuumed, filters that would prevent 'lead a,,. p t p particles from re entering the work environ, hazardous materials to[lead;:but';OSHA's're or included find stored and later tncinerated; to ,reclaim Metal lurgical ical was cited by,OSHA lateklast ings'thaO..Metallurgical_failed;ao.,maintain metals '�, > ment,were not used, the agency charged . month for 122'serious' violations �.of� the proper,records on-monitoring lead exposure OSHA ,found. that in some.'of'=theseThe state DEP has cited the'plant"for an federal Occupational:Safety and Health Act: Officals,for-South:<Windsor;;Metalluri$cal, processes; employees exposed to ex- odor violation in December and is now and the company had faced up to$17,300 in' were:unavailable;for.comment,today, '`: .;":cessive levels:of'airborne inform e p o ees o reinvestigating the company in light of the fines. ` Metallurgtrcal burns'computer..and m- -pany also,,tailed to inform employees of ; OSHA findings. Metallurgical was cited fo.; Most of the serious_infractions stemmed dustrial equipment; and recovers- gold, corrective action which~would,be:aaken to ` improper storage of. hazardous wastes.in from exposing employees"to high levels of platinum, and other metals.from the ash It reduce:exposure., lead which can damage"the'nervous, `also"has takenihnzardous:-waste.;'from The';.federal � agency.. also believed inadequately marked, and. in some case. re roductive; renal" and .gastrointestinal-.Virginia,:flammable, and�toxic-compounds...employees were placed';in danger .because open or corroded, barrels, by DEP,in the P , systems. The'OSHA findings have`sparked from,:as far away as Pittsburgh,and Quebec;:Metallurgical=.,failed' 'to test `the ''fit of late 19.80s. investigations by state and.local agencies and recovered precious metals from the who are seeking to find if the'corimpany may, materials;state Department of Environmen- 3' have polluted outside the building- tal'Protection records:show: h Town Sanitarian Robert Depiula plans to The company does not reduce the wastes sample soils in Farnham Estates to see if and scrap to usable'metals but to ingots of yhip F y airborne pollutants may have-accompanied a combined-metals that;are..sent to smelters chlorine-like" smell that" occastonally; ,elsewhere to corttplete'the'refining. y' Z . pervades the nearby neighborhood Using incinerators, the'. company burns After `an informal hearing between"computer transistor boards which contain representatives from the federal'.agency, .gold, an&sometimes platinum ,and lead �W& ;� management,and labor„three of the serious solder,among other metals.The incinerators violations were reduced to less serious;an-;,`are -also:used to:.evaporate _metal-bearing fractions andthe'fines reduced. liquids. Metallurgical also agreed to develop and The metals are screened and milled to implement a safety program for employees,,-separate them from.ash.They are..then taken begin a safety.communication program with to.a furnace in.the_foundry and, sometimes metal wastes, ,melted'., self-awareness and testing rocedures and fo combmded with raw � 76ners delay decision on STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION �.` Z, LEGAL NOTICE f STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION PUBLIC NOTICE OF APPLICATION BY A DIRECTOR OF HEALTH FOR DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION POLLUTION PURSUANT TO SECTION 22a-2a-1 OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES Gerald Schwartz, M.D. . Director of Health of the South Windsor Health Department, has applied to the Commissioner of Environmental Protection for delegation of authority: to investigate certain existing or potential air pollution discharges as described in Chapter 446c of the Connecticut General Statutes being limited to violations of the standards, criteria and other requirements pertaining to odors contained in Section 22a-174-23 of the Regulations of Connecticut State Agencies. No authority to investigate any existing or potential source of pollution originating from a facility or property owned by the state or any instrumentality of the state shall be granted. The applicant shall be considered an agent of the Commissioner. Information regarding the application can be obtained from the Planning and Standards Division of the Waste Management Bureau of the Department of Environmental Protection, 165 Capitol Av9nue, Hartford, Connecticut 06106 (203-566-2860) . Any comments regarding said application should be filed by 4:30 p.m. , April 22, 1991 with the Planning and Standards Division of the Waste Management Bureau, attention Judy Belaval. r Carmine DiBattista Director Planning and Standards . Waste Management Bureau Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer blendin --ate-.vn3 ==vcCcz ror tine Graduate School of Design in 1942, He'wasp a'member' of the.First ,g of native stone and glass in when he was awarded the gold med- Company Governor's Foot Guard for a design that was well suited to the al of the American Institute of Ar- nearly 50 years. heavily wooded site. He built the chitects. Conroy,a graduate of East Hart- house for his own use. He leaves his wife, Pamela Whit- ford High School,was captain of the Among his architectural works marsh Gores; four daughters,Cath- school's 1922 football team and then are the House for All Seasons, a erine Lynch of Miami;,Ainslie Gilli- played semiprofessional football for private residence in New-Canaan gan of Croton,N.Y.,Valerie Gores of 10 years for teams including the using alternate sources of energy; Lyndhurst, N.J., and Elizabeth Manchester Cubs and Majors. Van Dores Hospital and Strathmore Gores of Howell, N.J.; a son, Karl The funeral will be Saturday.at Village in Fairfield; and the middle Gores of San Anselmo, Calif.; a 9:15 a.m.,from the Sheehan-Hilborn- school and science buildings of New brother, Guido Gores Jr. of Cincin- Breen Funeral Home, 1084 New Canaan Country Day School. na ••and eight grandchildren. Britain Ave:, West Hartford. Other Legals Hartford Canton Connecticut Other Legals NOTICE OF - CITY OF HARTFORD - - LEGAL NOTICE LEGAL NOTICE - PUBLIC HEARING ZONING BOARD OF APPEALS TOWN OF CANTON STATE OF CONNECTICUT INVITATION TO BID In accordance with the provi- APRIL 3,1991 INVITATION TO BIDDERS DEPARTMENT OF SEALED BIDS FOR: stone of Section 13a-58 of the In conformity with the to. The Town of Canton,.acting ENVIRONMENTAL Charter of a manned sub- General Statutes of Connecticut quirementsof the Zoning Ordi- Through the WeTer Pollution - PROTECTION - merstble and support ship for - as amended Y and the Conment of ppnooecti- nanceppand the State oard of p Law, the Control Authority,will regester 0ceive PUBLIC NOTICE OF APPLICA- research conducted in thecut �? volvemPent/PublldHearings}or hold p 13ea991gat 7f00Wp m�in ihY Wafe peals will bids oPollutionTDh lCo of olAu hor OHEALTH AAU HOR(TY FORA THE EnglanSer. TION BY A DIRECTOR OF- Gulf d andei�l ddle Atlantic Highway Layouts end Designs, Function Room, Municipal cli office, second floor of the ABATEMENT OF AIR POLLU- Total time frame for opera- a public hearing will be con- Building, Hartford, CT on the Canton Town Hall, 4 Market TION PURSUANT TO SECTION tons Is 28.July through 5 ducted concerning the Dapert- following applications: Street,Collinsville,CT 06022 un- 22a-2a-1 OF THE REGULA• SaPI 1991. ment's proposal to Improve Carlos Mouta requesting tie April 9,1"1,2:00 P.M.local TIONS OF CONNECTICUT Bid N10482 safari and correct geometric from rear yard requlrement for time,afferwhich time the Bids STATE AGENCIES - - .Bid Opening Date:4/3/91 pprob ems on U.S.Route 6 from lot number one and floor area, will be publicly opened and Gerald Schwartz M.D., DI- COPIES OF SPECIFICA- - $500 ft.west of Potter Road In lot size,lot width at street line read aloud in Rom 201 of the rector of Health of the South TIONS MAY BE OBTAINED IN the Town of Hampton To 3,,5011 ft. and rear yard requirement for Canton Town Hall. - Windsor Health Department, THE OFFICE OF DENNIS GA- east Road Stetson Intersection Road/Cherry tion f blot att236l? sLaural consist of furnishing all materi- ar of Envit nmentel Protlection NECTICUT,CENTRALWARE- Town of Brooklyn.The hearin Street.R-1 - -py aapells,labor,tools,equipment,su- for delegation of authority:to HOUSE BUILDING,ROOM 260, �30 be at on epConsolidated variance ffroBmcsideayerd-and forcleaningoneorrbothanaero- Potentfof ate ir pDollutionn9diir STORRS CITORICALL44866.2620 School!ntheTgouwnofHampton, rear yarnt weather or other d yrequirements foallow bic digesters at The Canton chargesasdesscribedInChapter DURING THE HOURS OF 9:30 conditions ead nS will be require, tpo ed ifo feet of 511t5 3 P a klinnt enue .q Add T r o In ormet n aille. t structure to exceed 15 Wastewater Treatment Facility �s a the stalimited d ted orviol e of the Connecticuti THRU R DAY•(EXCEPT April 5, 1991 at the same hour B-4 - - Scope of Services may be ob- and other requirements per- INVITATION TO BID end location.Notice of the post- American Linen Corporation tamed from: - - taming To odors contained in. SEALED BIDS FOR: ponementwill be given on local requesting variance from.ten - Carl Graff- SecTion22a-174.23of the Regula- Calan Vacuum E ui to and television stations or foot set back from residential Plant Superintendent lions of Connecticut State Agen• q peed can be obtained by telling the zone boundary to edge of park- Town of Canton ties.No authority to investigate -Data Ranger.Mobile feedingy. Department of Transports- in lot to allow one foot set back - 4MarketStreet - anyexistingorpotentialsource system with eomDuterizetl fl memory scale system, com- Tion's Maintenance Operations from residential zone boundary Collinsville,CT 06022 of Pollution originating from n table with Calan Broadbent Center in Wethersfield at Tole- to edge of perking lot et 490 Tel:693.2235 fat lily or property owned by Individual AnimalFeeders phone number 5664890. Wethersfield Avenue.B-3 - - Fax:693-6612 - the state or any ins rumentalif System B". Eight A plan showing the recom- L 6 L Repair Service,Inc.re- 9:00 A.M.to 4:00 P.M. of the stele shall I granted. fl Custom mended proposal will be on des• questing Approval of Location Monday-Friday The applicant shall be consid- Tombstone Fence Installed. play In the Town Clerk's off Ice to allow Used Automobile Deal- The Town of Canton Water ered an agent of the Commis• Twelve LureCala Self-locking offer March 22,1991.More de- ership at 426 Woodland Street. Pollution Control Authority re- stoner. Information regarding Cow Capture System. tailed Information is available B-3 serves The right to reject any the application can be obtained Bid M1pp0ee461 9y for�ubllelnppspecTionettMCon- WWVZ FM Radio/Stephen and all Proposals;waive any In- from the Planning and Stan- BIpLANS^ANo SPEC FICA- porcttatlon'seOffi a of Engineer- from 30foot heis ht requirement verbageior technicialndefects in Management Bureau of the Dee TIONS MAY BE OBTAINED IN Ing,160 Pescone Place Newing• in B-1 zone to allow temporary the Pro osai(s) received and artm,nt of Environmental THE OFFICE R DENNIS ON- I p I p CIOCH,UNIVERSITY OF CON- are Mondayi thro ghcFriday not tonexceed 90 feet In helyht der deemed ed fo beccTin the best Hartford,�C neciticutv06106 HOUSE BUILDING, CENTRAL WARE- are a.m.to 4:30 p.m.,excluding for a period of 30 days at 10 Interest of the Town of Canton. (203'-%6-2660). Any comments HOUSE BUILDING,ROOM D, holidays. Spruce Street.B-1 The Town of Canton Is an regarding said appplication ST AUDITORIUM ROAD, The Connecticut Department ALL PERSONS INTEREST- Equal Opportunity/Affirmative should be filed by 1:30 p m., HOU S, CT, DURING THE of Transportation has recom• ED MAY ATTEND AND BE Action Employer. April 22,1991 with the Planning HOURS OF 9Y A.M. RI AY mended that this project be HEARD - Dated this 19th day of March, and Standards Division of the P.M.MONDAY THRU FRIDAY classified as a Categorical Ex- Dated at Hartford,Connecti- 1991- Waste Management Bureau,at- (EXCEPT HOLIDAYS). cclusion In accordance with the cut this 20th day of March,1991 ROBERT J.SUTMILLER, tention Judy Belaval. -- Environmental the 23 Courant ontMarch 22 Hartford 25 IN Pollution Control Aut Authority CARMINE RIBA pl�ec ar East-Hartford CFR,Pert 771.115. ZONING BOARD OF APPEALS Planning and Standards Tentative schedules for WILLIAM A.SMITH, Other Legals Waste Management Bureau 'INVITATION TO BID#1044 rights-of-way acquisition and Chairman NOTICE The East Hertford Public construction will be discussed DONALD BIANCAMANO, INVITATION TO BID Pursuant to Section 16.50p(d) Schools, 110 Long Hill Drive, at the public hearing. Reloca- Vice Chairman SEALED BIDS FOR: of the General Statutes of Con- East Hartford,CT 06108,will re- tion assistance Information will HENRIETTA S.MILWARD, Provide all labor and materi. necticut,the Connecticut Siting ceive sealed bids for also be provided. Secrete of tosuDpply and Install one(1) Council announces that, on SOCCER FIELD Department of Transports- - RONALD BIELAWIEC Varlabta Speed Controller for March 11, 1991,the Council is- DEVELOPMENT flon personnel will be available - 75 H.P. bioter feed water sued Findings of Fact,an Opin- (3.75 acres) at the public hearing location J pump No.1. Ion,and a Decision and Order Bid information and specifi- one our prior to the scheduled New Haven Bid NC-218 approvint a Certificate of Envl- cations are available In the formal start time for consults- Bid Openin9 Date:4/17/91 ronmenta Compatibility and Business Office of the School tlon with Interested parties. REQUEST FOR PROPOSAL PLANS AND SPECIFICA- Public Need for The construc- DepartmenT.Sealed bid' be Written p statements and ex- The Office of the Controller of TIONS MAY BE OBTAINED IN tion,maintenance,and opera- received until 2The:00 p id' Tues- }obont atafsYymenfs made atttne in9�s an o outside contractven or to pro- CIOCHFUNIVERSITDENNIS OF CON- fly In the cellul ar Wethe sfllaid, theywhl ebe pubuclYtoDened and Cheratgthe timeeosubmitted, the hearings sservicesntouImpl software new HOUSE BUILDING,ROOM 260, pRAL WARE- osed for the•Townsfofect any or eE��oonfiaid Prtford,Connecticut, uublicl Sud chools to accept reeslfe vesHartfthe f ri fo may M Barton,Chief system To the departm nture� STO RSS, FDA INTO 3 E Theapplication en181 AUDITORIUM OAD, and East without i re t p(Dxkat technical isr thre right toil is Ie of Consultant Design, Depart- A copy of the requirements ment of Transportation, 160 may be obtained at the Bureau P,M.MONDAY THRU FRIDAY No.139)is available for public the best Interest of the School Pascone Place, Newington, of Purchases, 200 Orang9e (EXCEPT HOLIDAYS). - Inspection in the Council's of- Department to do so. Connecticut 06111, telephone Street, New Haven, Conneetl• face,736 Main Street,Suite 40/, RICHARD A.HUOT, number 666.7249,until April 18, cut,06510. NOTICE TO CREDITORS New Britain,Connectl,..# - Director/Business Services 1991.Such written statements or TItlto will be a pre-proposal ESTATE OF:ALBA GARCIA exhibits must be reproducible conference at the Office of the The Hon. Robert K. Killian, In black and white on paper not Controller, 200 Orange Street, Jr.,Judge of the Court of Pro -- to exceed 81h" x 11' in size. New Haven, In Room 306,on bete,District of Hartford at a - These written statements or ex- April 2,1991 at-10:00 a.m. hearing held on March 20,1"1 _ - - hibit will be made part of the Sealed proposals will be ub• ordered that all claims must b p presantedtotheffduciar atth public hearing transcript and. IlclyopenedatthaOff[coofthe address below. Failure T ` will be considered in the same Controller, 200 Orang�e Street, Promptly present any such way as oral statements. New Haven,Conn=Pcut,06510 y =�-= All persons Interested in this Room 306,at 3:00 p.m.on Aprll claim may result In the loss o matter are welcome to attend 18,1"1. ri9Ms to recover on such claim. -this public hearing. - Certified from record, Commissioner of - SONDRA J.WATERMAN, Transpportation Other Le ale - ry Ass't Clerk - 234879/234880 g 7 Fernando Sainchez INVITATION 70 BID 22 Elliott Street,Apt.201 , Hartford - - SEALED BIDS FOR: Hartford, Charter of a manned sub- STATE OFF ONN NECTICUT ' € merstble and support ship for DEPARTMENT OF NOTICE TO CREDITORS research conducted in the ENVIRONMENTAL + �� I ESTATE OF: Gulf of Maine,Southern New PROTECTION - ANTONIO DINATALE aka England,and Middle Atlantic WASTE MANAGEMENT _ \�`� • _ _ Then '. ANTONINO DINATALE,JR. Bight• BUREAU ` A/� /w� The Hon. Robert CK.ourt of Pro To Is 22 fMayethroh opera-7 ENFORCE I DIVISION ENGINEERING ON �\�`�` R`yyVIO Jr.,Judge of the Court of Pro- y • bate,DQQistrict of Hartford aT a BiCuNI%48 1• PUBLIC NOTICE `� orderetl that all eiefms must be In accordance with Section Bid Opening Date: ECI 22a-209.4(b)(4)of the Connectl- presentedtotheflduciaryatthe COPIES OF SPECIFICA- cut State Agencies,the Commis- ` ` •���///�/� address below. Failure to TIONS MAY BE OBTAINED IN stoner of Environmental Pro- promptly present any such THE OFFICE OF DENNIS GA- tection hereb gives notice of CIOCH,UNIVERSITY OF CON- may elagim may result in the loss of his decision o lyiana to P.M. ri his to recover on such claim. NECTICUT CENTRAL WARE- Services,Inc.a solid waste facie- HOUSE BUILDING ROOM 260, .fly permit to construct private } ertlfied from record 181 AUOITORIL ROAD 99 so J.WATAERsaStlClefk S70RRS,CT OR CALL 4862621I ollftylocatedatt25Nor1onPlace, The fiduciary Is: DURING THE HOURS OF 9:30 Plainville,CT 06062. Giovanna DlNatale- A•M• TO 3:30 P.M., MONDAY RICHARD J.BARLOW - 581Broadview Temp THRW FRIDAY (EXCER Bureau Chief `� Hertford,CT 061067 ' HOLIDAYS). - Waste Management Bureau - 1 , a / - Ti� C-- 72C Environmental , s ta n ln . I IL-rl Hand y& Harman fn Precious Metal Refining Division:300 Rye Street,South Windsor,CT 06074 Telephone:(203)282-0003•Fax:(203)282-7461 April 18, 1990 �` W 0 Mr. C. F. Shaw s RECEIVED Assistant Director 10 Public Works / Pollution Control APR 1 9 1990 Town of South Windsor 17 TOVIR of Snkith' i �sor 1540 Sullivan Avenue �__rgn^erng rl South Windsor, CT 06074 RE: South Windsor Metallurgical Odor Investigation Dear Mr. Shaw: Enclosed is a copy of the odor investigation report prepared by TRC Environmental Consultants and submitted today to the Connecticut Department of Environmental Protection (CDEP) . This report is based upon investigation efforts from December, 1989 through February, 1990. As you will note, TRC has recommended still more investigation, but we have decided to submit these results now, rather than wait until additional studies are completed. A supplemental report will be submitted. TRC found no objectionable odors in the area of the plant or nearby neighborhoods. It further found no stack odor emission from any plant process which it predicted would be objectionable in those neighborhoods. These conclusions were based upon direct odor investigation within the neighborhoods, and also upon odor samples taken directly- from all plant stacks, and mathematical modeling of such samples carried to a number of downwind receptor locations. TRC did find, as the CDEP had before, that some faint and unobjectionable odors are emitted by the plant on some occasions. TRC therefore recommended that we pursue further testing to determine the specific process which may be the source of odor. We have accepted that recommendation and have requested TRC to continue its investigation. If you have any questions concerning the report, please call. Very truly yours, r Richard -'1-:-'Kettler Manager-Refining Operations Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum group metals t ODOR ABATEMENT STUDY SOUTH WINDSOR METALLURGICAL, INC. SOUTH WINDSOR, CONNECTICUT Prepared by: Karen E. Brown Environmental Scientist Samuel Cha Program Manager TRC Project No. 6850-M51-00 April 16, 1990 7?C Environmental Consultants, Inc. 800 Connecticut Boulevard East Hartford, CT 06108 (203) 289-8631 A 'TIC Company t z a EXECUTIVE SUMMARY An odor study was completed at and around the South Windsor Metallurgical, Inc. 's , facility in South Windsor. No odor was perceived during the study to be objectionable. However, under certain meteorological conditions, faint odor could be perceived in the residential area along McGrath Road. Study has also shown that emissions from the process stacks of South Windsor Metallurgical have the potential of contributing odors to the residential area and the immediately adjacent area near the facility. Although the odor impact at this area predicted to be very low, nevertheless, it is recommended that further studies be carried out to determine the exact cause of the odor and feasible odor control methods. -ii- t x S t TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION . . . . 1 1.1 Plant Surrounding Description . . . . . . . . . . 1 1.2 Plant Operations . . . . . . . . . . . . . . . . 3 1.3 Meteorological Conditions . . . . . . . . . . . 4 1.4 Odor Perceptions . . . . . . . . . . . . . . . . 5 2.0 METHODOLOGY . . . . . . . . . . . . . . . . . . . 7 2.1 Community Odor Surveys . . . . . . . . . . . . . 7 2.2 Determination of Odor Emission Rates . . . . . . 7 2.2.1 Odor Emission Sampling . . . . . . . . . . 7 2.2.2 Olfactometric Odor Evaluation . . . . . . . . . 9 2.2.3 Data Analysis . . . . . . . . . . . . . . . . 9 2.2.4 Odor Panel . . . . . . . . . • • • • • • • 11 2.3 Odor Dispersion Modeling . . . . . . . . . . . . 11 3.0 RESULTS AND DISCUSSION . . . . . . . . . . . . . . 13 3.1 Community Odor Impact Survey Results . . . . . . 13 3.2 Odor Emission Inventory Results . . . . . . . . . 14 3.3 Dispersion Modeling Results . . . . . . . . . . . 17 4.0 CONCLUSIONS AND RECOMMENDATIONS . . . . . . . . . . 21 LIST OF FIGURES FIGURE PAGE 1-1 SITE LOCATION MAP . . . . . . . . . . . . . . . . . . 2 1-2 WINDROSE . . . . . . . . . . . . . . . . . . . . . 6 2-1 GAS SAMPLING EQUIPMENT . . . . . . . . . . . . . . . . 8 2-2 A DYNAMIC DILUTION FORCED-CHOICE TRIANGLE OLFACTOMETER 10 3-1 SWM RECEPTOR LOCATIONS . . . . . . . . . . . . . 19 LIST OF TABLES TABLE PAGE 3-1 A-SUMMARY OF ODOR SURVEY RESULTS AND POTENTIAL PLANT RELATED ODORS . . . . . . . . . . . . . . . . . . . . 15 3-2 ODOR EMISSION SAMPLE RESULTS 16 3-3 DILUTION-TO-THRESHOLD (D/T) VALUES AND DOMINANT ODOR DESCRIPTIONS REPORTED ON SOURCE EMISSION SAMPLING DATES . . . . . . . . . . . . . . . . . . . . . . . . 18 -iii- s i x 1.0 INTRODUCTION Several residents who live in the neighborhood of McGrath Road in South Windsor have recently been experiencing odor episodes, and the origin of the odor is uncertain. ' Since South Windsor Metallurgical, Inc. is one of the major industrial facilities in the area, some residents suspect that the odor is generated from the plant. The Connecticut Department of Environmental Protection has investigated the South Windsor Metallurgical facility on numerous occasions, and has on several occasions detected a faint medicinal odor in areas immediately adjacent to the property boundary. The detected odor has been classified as not objectionable. To evaluate the current situation, South Windsor Metallurgical asked TRC Environmental Consultants, Inc. (TRC) to conduct a study to identify the origin of the odor episode and to recommend corrective actions if the study determines that the odor is generated from processes in the plant. During December 1989 through February 1990, TRC staff performed community odor surveys, sampled emissions from process vents, determined odor emission rates, and predicted odor impact under various meteorological conditions using dispersion modeling calculations. This report presents the results and conclusions of TRC's study. Section 2.0 describes the methodology used in the study. Section 3.0 summarizes the study results, and Section 4.0 presents the conclusions and recommendations. In addition, TRC is also in the process of installing a meteorological monitoring system on-site. The installation is not discussed in this report. 1.1 Plant Surrounding Description South Windsor Metallurgical, Inc. 's plant is located at 300 Rye Street in the north-center of the Town of South Windsor (see Figure 1-1) . It is bordered by Rye Street on the north side, Troy Road on the east side, Conrail -1- i •_ � `v � \ Qom., o , 11 '" r, .. '„ Z •,. `,�, , ,�� to`-A �'.<S ;fir i:;. ���✓������ccccc:1 I ,•. q t• •IR :h61'A R 'JON" f` _ i•�{ I o P CONNECTICUT ?J I I (� .� ? '+ •.1' a 1, r ( � ��•j i' !`. ��� �j-, �..•�!� I• ,II. ,I',�� o J � � U fit... �L-'�- •� '^' fill Farnha IN R ,` ;1 50j '—� ,r \ 1 \�♦;1(' Rye Street ��{�j a' ,�,•' �' �,�1' \ ESL `�"indsor \� _ >".�• /. A \BMB2 � Naplt I�}Worm 90 SV SOUTH WINDSOR L- l; /• ,ti METALLURGICAL ��%�� I� Q�� . _ fi r/ -- \ Imo• ��_. . .)�* �1 'I• �I�', ±'I /; o �pAr� C' �_ �-r 'yard 1 d 41 .celrarPol�•fe¢I:nc�f, itutr /'('��-y CIaypit '�•3 �/ ` _ ., j r !a�tford Gru�,�le C"ty+li 1 /• < I , statrOn"N" •�, o I 1 0 1 WLE 1000 0 1000 2000 303: 40^0 5000 6X_ 7000 FEET 1 5 0 i K4UNEIEF T?C 800 Connecticut Boulevard East Hartford,CT 06108 TRC Environmental Consultants,Inc. (203)289.8631 FROM MANCHESTER, CT 7 1/2' USGS SOUTH WINDSOR TOPOGRAPHIC MAP, 1963 METALLURGICAL SOUTH 14'INDSOR, CT PHOTOREVISED 1984 FIGURE 1-1. SITE LOCATION MAP —2— t ; Y on the south side, and wooded areas on the west side. The landscape on the north and east side of the plant includes a dry creek with the lowest point approximately 50 feet below the plant elevation. Further north of the dry creek there is a residential area with approximately 200 single family homes. This is the area where several residents have been experiencing odor eposides. On Troy Road directly east of the plant is one residential home. Beyond the intersection of Troy Road and Conrail there are two additional residential homes. These homes are located southeast of the plant. Located south of the plant adjacent to Conrail are two tobacco storage sheds. The remaining landscape is predominantly woods. 1.2 Plant Operations South Windsor Metallurgical processes secondary materials for recovery of precious metals. Its processes include burning of electronic materials such as computer circuit boards and drying and evaporation of wet residues. These operations take place in several custom-built furnaces, specialized in accordance with the material to be processed. Furnace exhausts are processed through a number of pollution control devices, including secondary furnace chambers, caustic scrubbers and baghouses. All furnaces and pollution control equipment operated by South Windsor Metallurgical are considered to be state-of-the-art within its industry, and have been formally reviewed and approved by the Connecticut Department of Environmental Protection prior to their installation and operation. Processes at South Windsor Metallurgical should result in exhaust gases consisting primarily of carbon dioxide and water vapor. Pollution control systems at the facility should capture and control most potential odorants. Operating records at the facility indicate that these pollution control systems have been in operation during the times indicated in odor complaints. -3- D T T A . Nevertheless, the possibility exists that odorants are being created which are not fully controlled by present systems. 1.3 Meteorological Conditions In order to comprehend the odor dispersion and transport phenomenon, it is necessary to understand the meteorological conditions in the area. For the odor be perceived at the receptors, it is necessary that the suitable wind patterns carry the odorants from the source to the receptors. On a typical day, the following meteorological conditions can be expected: Time Period* Expected Meteorological Conditions • Night (11:00 pm - 5:00 am) Calm, inversion condition, very stable • Early morning (5:00 am - Light and variable winds, 10:00 am) possible fumigation • Mid morning to early afternoon Light wind, sea breeze (10:00 am - 2:00 pm) established (if near water) • Afternoon to evening (2:00 pm - Maximum wind speeds, greatest 7:00 pm) instability • Evening to night (7:00 pm - Transitional period, wind 11:00 pm) becoming light and variable, possible land breeze- established * During the summer and winter days, the exact start and ending time for each period may change depending on the sunrise and sundown. At South Windsor Metallurgical, the facility operates mostly between 7:00 am to 3:00 pm with much lighter or no operation schedule after 3:00 pm every weekday. The unstable meteorological conditions during these periods of time (i.e. , 7:OO *am to 3:00 pm) create greater dispersion and dilution' of emitted , odorants (if any) due to the turbulence and mixing by the wind. :Only the puffs of odor could be pushed to the ground occasionally by the gusty wind usually associated with the unstable conditions. -4- 4 Another important factor is wind direction. According to the actual weather data collected at nearby Bradley Airport, the prevailing wind is from the north and northwest during the fall, winter and early spring, and is from the south during the summer. The southerly wind, which could blow odorants emitted from South Windsor Metallurgical directly to the McGrath Road area, accounts for approximately 260 of the total time (see Figure 1-2 windrose) . In summary, the operating hours at the South Windsor Metallurgical and the prevailing wind direction coming from north provides a relatively favorable situation; the residents in McGrath Road are not always exposed to air emissions from the facility. 1.4 Odor Perceptions Human perception of odor is based on a combination of frequency of occurrence, character, intensity, and pleasantness of the odor perceived. While the above mentioned factors are relatively objective and easy to quantify, the individual annoyance reaction of the perceived odor is subjective and difficult to measure. For example, a persistent penetrating fragrance from a perfume factory can annoy, while a fragrance in a garden is expected and acceptable. On the otherhand, cheesy odor found pleasant in the dining room can be found unacceptable in a factory's neighboring community. In real life, the population response reaction is very complex. The responses are highly individual. One important thing should be noted that many odorants are perceptible at concentrations far below harmful concentration levels. Therefore, when an odor is perceived, it does not automatically indicate that a health risk is present. -5- N a 9 12� 6 W 3 E S (� 11 .0 1.8 3.3 5.4 8.5 I INDROSE WIND SPEED CLASS BOUNDARIES STATION NO. 14740 (METERS/SECOND) CONNECTICUT NOTES: PERIOD: 1970- 1974 DIAGRAM OF THE FREQUENCY OF OCCURRENCE FOR EACH WIND DIRECTION. WIND DIRECTION IS THE DIRECTION FROM WHICH THE WIND IS BLOWING. EXAMPLE — WIND IS BLOWING FROM THE Environmental NORTH 12.4 PERCENT OF THE TIME. Engineering Figure 1-2 -6- t 2.0 METHODOLOGY The complete odor study methodology consisted of three integral tasks: community odor surveys, determination of odor emission rates from various plant sources, and prediction 'of the odor impact under various meteorological conditions using dispersion modeling calculations. 2.1 Community Odor Surveys The purpose of the community odor survey is to locate and quantify possible plant-related community odors. This is done by tracking plant odors and mapping their area and range. Community surveillance in South Windsor was accomplished by driving downwind of South Windsor Metallurgical. Whenever odors were perceived, the location, time, weather, windspeed and wind direction, temperature, odor character (description) and odor detectability (in terms of dilution-to-threshold (D/T), i.e. the dilution required to dilute the odorant to the threshold level determined by the Scentometer, Barnebey Cheney Model I-3) were noted. Usually, if a persistant odor perceived is determined to be above 7 D/T, this odor will be normally considered objectionable by the general population. An effort was also made to identify the odor source as plant or non-plant related by tracing the odor in the upwind direction until the suspected source was identified. 2.2 Determination of Odor Emission Rates 2.2.1 Odor Emission Sampling Odor samples were collected at locations on-site at South Windsor Metallurgical which were believed to have the potential to contribute to both on- and off-site odors. Samples were collected in Tedlar gas sampling bags using a "bag-in-the-drum" technique as illustrated in Figure 2-1. Sample bags were preconditioned with the sample air prior to taking the final sample to -7- TEFLON SAMPLE LINE VACUUM LINE PUMP 4 RIGID, LEAK PROOF TEDLAR CONTAINER BAG Figure 2-1. Gas Sampling Equipment equilibrate the inner surface of the bag with the material being sampled. Without preconditioning the sample bag, odor sample values can be significantly less because of adsorptive losses on the inner surface of the bag. Sample storage time prior to analysis was also kept as short as possible (less than eight hours) to avoid deterioration of the sample. During source emission sampling on December 12, 1989, stack flow rates were measured using a conventional pitot tube and manometer, following EPA stationary source measurement method 2. Sample locations included: the TR2, TR5 and TR10 furnace stacks, three of the four roof top fans in operation during sampling periods, the gas-fired and oil-fired evaporator vents, the dry pan and palladium furnace stacks, and two of the baghouse stacks representative of the two baghouse groups. 2.2.2 Olfactometric Odor Evaluation All odor samples were evaluated for threshold of detection in TRC's Olfactory Laboratory located in East Hartford, Connecticut. Dilution- to-threshold (D/T) levels were measured with a dynamic dilution forced-choice triangle olfactometer (IITRI System, 1979 model) which uses carbon filtered air to make six simultaneous dilutions of the odorous air. The six dilutions were presented in an ascending series method of limits in 3-fold concentrations steps. The dilution ratios were approximately: 1/2000, 1/630, 1/200, 1/70, 1/30, and 1/10. Flow rates from the sniff ports were at least three liters per minute. Panelists chose which of the three ports (if any) differed from the other two. The olfactometer is depicted in Figure 2-2. The olfactometer and its procedures meet the recommended requirements of ASTM Standard Pratt-ice E 679. In-addition, sample odor characters were recorded. -9 FIGURE 2-2 A DYNAMIC DILUTION FORCED-CHOICE TRIANGLE OLFACTOMETER 1 2 3 4 5 fi -10- 2.2.3 Data Analysis The dilution-to-threshold (D/T) value that is reported in Table 3-2 is calculated by log dilution level versus probability plots. The probability of correct response at• 50 percent was plotted against odorant concentration for a best fit (least squares) straight line function. The values were tabulated by means of linear regression. Ten percent of the regression curves were re-calculated for quality control purposes. This D/T determination method is the one recommended for use with the IITRI Olfactometer System. 2.2.4 Odor Panel TRC's. in-house Olfactory Laboratory maintains a pool of trained experienced panelists from the Hartford area. Panelists are calibrated with a butanol intensity series to monitor olfactory changes over time. Panels are composed of individuals chosen to represent a normal distribution of olfactory sensitivity such as found in the general population. 2.3 Odor Dispersion Modeling Dispersion modeling is a tool that enables air quality scientists and engineers to investigate different emission scenarios. Models can be used to indicate which source is a likely contributor to a perceived odor and to explore potential control strategies. Dispersion models themselves are mathematical formulations of idealized plume (stack emission) behavior. Models attempt to predict the plume path and the amount of dilution that the plume will undergo as it travels to different receptor areas in the community. Dispersion model accuracy is limited by the accuracy of the input data, the level of detail of the model, and the natural variability of the emission source and the atmosphere. Model predictions, therefore, should be regarded as indicative of air quality trends, but should not be considered as absolutes. -11- TRC's ODOR dispersion model was used to investigate the relative• contributions of odor emission sources to the observed community odor. Due to plume fluctuations the odor perceived in the community is an instantaneous phenomenon: Unlike conventional dispersion models which predict time average values, the TRC model is designed to predicted instantaneous occurrences of odor at various receptor locations. Specifically, odor level and frequency are predicted. The model was used to predict ambient odor levels under the meteorological conditions actually encountered during the community surveys. The most reliable calibrations are obtained when a broad spectrum of meteorological conditions has been sampled. The agreement between predicted and observed odor levels and frequencies of odor occurrence confirmed that the model had been reasonably created and calibrated under those conditions and could be used to investigate source contributions to the odor impact in the community. -12- 3.0 RESULTS AND DISCUSSION The series of community odor survey results, source emission test results, and odor dispersion modeling results are presented in the following section. 3.1 Community Odor Impact Survey Results In order to provide assessment of potential odor impact situations, TRC odor technologists performed a series of surveys in December 1989 and January 1990. When the wind was directed from the north and northwest, odors were observed along Troy Road and on the property adjacent to South Windsor Metallurgical and Conrail where two steel tobacco storage sheds are located. The dilution-to-threshold (D/T) values were recorded to be 2 D/T, which is less than 7 D/T, the odor level which may be considered as objectionable. In addition, TRC characterized the odor as burnt roc On several occasions, TRC odor technologists did observe the plume of the palladium furnace downwashing onto the land where the tobacco storage sheds, mentioned above, are located. Odors were detected along the property lines when this occurred. Odors were also detected along Troy Road, southeast of the plant, where there is a tobacco field adjacent to a small pine forest. Odors did not exceed 7 D/T and were characterized as both sweet and burnt process odors. On two occasions odors were detected in the neighborhoods located north of the plant. On these dates, the wind was directed from the south and southwest. The odors were detected as faint puffs and did not exceed 2 D/T. On several occasions odors were detected on-site of the South Windsor Metallurgical facility. Below the evaporator vents, odors were characterized as both sweet and burnt. At the southwest corner of the building, with the wind direction from the north and northwest, chlorine-type odors and sweet odors were also detected on-site. -13- Table 3-1 presents a summary of survey results and potential plant related odors both on- and off-site detected during the odor surveys. Wind direction is also noted. Odors detected at the tobacco field located south of South Windsor Metallurgical indicate that odors have the potential to be detected one half-mile from the South Windsor Metallurgical facility. A chlorine-type odor is detected only at the southwest corner of the facility and it has been reported at D/T values between 0-2 and 2-7 on different days. 3.2 Odor Emission Inventory Results Odor emission sampling was performed on two dates, Tuesday 12/12/89 and Monday 12/18/90. An effort was made to sample all the potential odor sources on both the sampling dates; however, there were a few exceptions. The baghouses were not sampled on 12/18/89 due to their significantly low odor levels that were reported on 12/12/89. The three operating roof fans were sampled on 12/18/89 rather than just the one that was sampled on 12/12/89. The odor emission sampling results and the odor emission rates are presented in Table 3-2. The difference in the reported dilution-to-threshold (D/T) values on the two sampling dates may be a result of the different products that were processed on the two days. The average dilution-to- threshold (D/T) values indicate that no one source was significantly higher than the others. The two baghouse samples, however, were much lower in D/T values when compared with the other sources. The odor emission rates reported in actual cubic feet per minute (ACFM) were calculated by multiplying the average dilution-to-threshold (D/T) values by the measured flow rates (ACFM) of the corresponding source: These values indicate that the TR10 furnace, the palladium furnace and the roof-top fans -14- TABLE 3-1 A SUMMARY OF ODOR SURVEY RESULTS AND POTENTIAL PLANT RELATED ODORS M Wind Sampling Wind Speed Off—Site On—Site Not Date Time Direction (mph) Odors D/T Odors D/T Operating Comments 12/6/89 1355-1430 SE 1-3 Troy Road — 0-2 Puffs of odor at Chem./Plastic off—site locations Rye St. Park — Chem./Plastic 12/8/89 0955-1030 N, NW 1.5 No Odor TRIO 12/12/89 1105-1135 N, NE NO Troy Rd. & Conrail — 0-2 Evap. Vents and 2-7 Puffs of odor at Sweet/Process SW Corner on—site location 12/18/89 1100-1130 NW .5-2 Troy Rd. Clearing — 0-2 SW Corner — 0-2 Puffs of odor at Sweet/Process 0-2 Sweet/Process off—site location Troy Rd. & Conrail — 0-2 Very Faint Process Odor 12/28/89 1340-1420 NW 6-11 Troy Rd. & Conrail — 0-2 SW Corner — Chlorine 2-7 TR5 Burnt/Process Troy Rd. Clearing — 0-2 Evap. Vents — Chlorine 2 Burnt/Process Mis. Vents — Burnt/ 0-2 Odor 12/29/89 0940-1015 N, NE .5-2 No Odor SW Corner — Process 0-2 TR5, TR10 Faint, then stronger Evap. Vents — Burnt/ 0-2 when plume washes down Process 1/2/90 1020-1100 W, NW 1-4 Troy Rd. & Conrail 2-7 SW Corner — Chlorine 2-7 TR2, TR5, TR10 Evap. Vents — Sweet 0-2 Very Sweet Odor 1/8/90 1030-1120 S, SW 1-3 McGrath & Cherry 0-2 Evap. Vents — Sweet 0-2 TR5, Puffs of odor at Blossom Palladium off—site location 1/12/90 1045-1120 W, SW .5-1 Troy Rd. — Burnt/ 2-7 Evap. Vents — Sweet 2-7 Process Rye St. Park — 0-2 SW Corner — Sweet, Burnt Odor Faint Chlorine East Side SWM 0-2 Very Faint V have the greatest potential to contribute to off-site odors. Due to the low' flow rates of both the baghouses and the evaporators, these sources appear to have the least potential to contribute to off-site odors. The higher of the two dilution-to-threshold (D/T) values for each source were used as the input values for the odor dispersion modeling calculations in order to present worst-case scenarios. The dilution-to-threshold (D/T) values and the dominant odor descriptions reported on the two sampling dates are presented in Table 3-3. As mentioned above, the difference in the reported D/T values and also the odor descriptions for the two dates may be a result of the products that were processed on those days. The predominant odors appear to be medicine and chlorine type odors. The samples taken from TR10, TRZ, palladium furnace, and the dry pan were all described as having medicine and chlorine odors on both sampling dates. 3.3 Dispersion Modeling Results Five potential receptors were chosen at different locations near the plant, and models were created to determine if measured odor emissions could be detected at these locations. Receptor locations represented neighborhoods which had the potential to be recipients of odor as a result of varying meteorological conditions. The receptor locations are depicted in Figure 3-1. The first series of model outputs that were generated indicated that the roof top ventilation fans had the greatest potential contribution to the majority of odor malodors in the immediate vicinity of the plant. In order to focus upon more distant receptors away from. the plant property, the roof fans were eliminated from the model, simulating that they had been turned off, and the model was repeated. -17- a l +P TABLE 3-3 DILUTION-TO-THRESHOLD (D/T) VALUES AND DOMINANT ODOR DESCRIPTIONS REPORTED ON SOURCE EMISSION SAMPLING DATES 12/12/89 12/18/89 D/T Value Dominant Odors D/T Value Dominant Odors TR2 110 Chlorine 50% 225 Chlorine 43% Medicine 33% Burnt 29% TR5 73 Musty 100%. 190 TR10 202 Chlorine 50% 170 Chlorine 86% Medicine 33% NW Roof Fan 110 114 Chlorine 43% Medicine 29% Gas-Fired 226 Burnt 33% Evaporators Chlorine 33% Oil-Fired 322 Burnt 50% Evaporators Palladium 82 Medicine 50% 240 Chlorine 71% Furnace Chlorine 33% Dry Pan 124 Chlorine 33% 170 Chlorine 71% Baghouse B 48 Burnt 50% Rubber 33% Baghouse G 13 Medicine 50% SE Roof Fan 95 SW Roof Fan 190 Medicine 29% -18- - 1 / •• • • • •� • •% • • \ \ • . C i • • i 'Rye Street r-- - S. WINDSOR `•�\. �� �� . • ;� \. METALLURGICAL lzvil CONRAIL \ o . 84 _ I �' �\ •• 0 0 2000 FT. ram\ O �.. • SCALE. LEGEND T?C 800 Connecticut Boulevard 1 - TROY ROAD East Hartford, CT 06108 TRC Environmental Consultants,Inc. .(203)289.8631 2- RYE STREET BY THE CEMETERY SOUTH WINDSOR 3- McGRATH ROAD AND APPLE METALLURIGAL SOUTH WINDSOR, CT ORCHARD LANE 4 - ALISON DRIVE AND DOWER ROAD FIGURE 3-1. 5 - HIGHTOWER ROAD AND MERYL ROAD SWM RECEPTOR LOCATIONS —19— • v Next, dispersion models were created which focused solely on the contributions of the five stack sources (which includes the furnaces TR2, TR5, TR10, dry pan and .palladium furnace) , the contributions of the gas-fired 'and oil-fired evaporators, and the contributions of the baghouses. The results generated from mathematical modeling of the contributions of the five stacks indicated that receptors may experience an episode of odor when these stacks are in operation, when the wind is toward the receptor, and when unstable meteorological conditions, i.e, day time, light wind conditions, are present. A maximum detectable odor is 2 dilutions-to-threshold, i.e. , 0-2 D/T, or at threshold level would be received at two downwind locations: McGrath Road and the Cemetery at Rye Street. The mathematical modeling results of the potential contributions made by both the evaporators and the baghouses are similar. The receptors would only experience odor when these stacks are in operation, when the wind direction is toward the receptor, and when stable meteorological conditions, i.e. , night time, . early morning no wind conditions, exist. In summary, mathematical modeling suggests that the taller stacks potentially provide episodes of odor to the receptors when unstable meteorological conditions exist. Similar mathematical modeling suggests that evaporator vents and the baghouses have impact on the receptors when stable meteorological conditions are present. However, no odor impact predicted by the mathematical modeling would be objectionable at those receptor locations. -20- 4.0 CONCLUSIONS AND RECOMMENDATIONS Based on the finding from the community surveys, the stack emission evaluation, and dispersion modeling calculation studies, the following conclusions can be derived: 1. Emissions from South Windsor Metallurgical contribute intermittent odor at downwind locations. Under certain meteorological conditions, odor arising at the facility could be perceived in the residential areas along McGrath Road. 2. No odor was perceived during the field surveys to be objectionable. Field measurements indicated dilution-to-threshold (D/T) levels no higher than seven, generally considered unobjectionable, in the immediate area of the facility. Field measurements in the McGrath Road residential area did not exceed two D/T in faint puffs. In addition, the mathematical model predicts that no odor impact would be considered objectionable at the receptors. 3. Low stacks (evaporation vents, palladium furnace stack and baghouse exhausts) contribute odor under stable weather conditions. Roof vents contribute the most odor. The highest impact area from these sources is located immediately adjacent to the plant. 4. High stacks (furnaces TR10, TR5, TR2, and dry pan) contribute odor under unstable conditions to areas located approximately one half mile downwind from the plant. When the wind is from the south, this would include the residential neighborhood on McGrath Road. Based on the above conclusions, and notwithstanding that odor emissions do not appear to be at objectionable levels, TRC recommends that South Windsor Metallurgical should take the following steps: 1. Limit use of roof vents. Because these vents are the largest potential source of odor, with impact in the areas immediately adjacent to the facility, they should be turned off or used to a limited degree when possible, and when ventilation inside the facility continues to be adequate. 2. Further study the emission composition at the outlet of the high stacks, the TR10, TR5, TR2, and dry- pan. These stacks should be tested for volatile organic compounds as the most likely odorants. Because these stacks have the potential to be a source of odor in the McGrath Road residential neighborhood, it should be determined what the odorants are. -21- 3. Determine the feasibility of odor control methods. Depending upon the type of odorants actually emitted: a) determine the original source (e.g. , furnace feedstock materials, additives, creation within processes) and whether the source can be eliminated or reduced. b) determine the feasibility of additional odor control methods such as mist scrubbing, activated carbon adsorption, bacterial digestion, etc. 4. Calculate the effect of raising stacks. While higher stack heights will not eliminate odorants, they will further disperse odorants. This should decrease the incidence of odors in areas distant from the facility and significantly decrease the incidence in immediately adjacent areas. -22- r , a TVC Environmentif Consultants . A TRC Company San Francisco, CA (415) 382-8271 East Hartford, CT Washington, DC New York, NY (203) 289-8631 (202) 337-0307 _: . (212) 643-2050 _�:<.. ... .. .. Mission Viejo, CA Somerset, NJ Troy, NY s (714) 581-6860 (201) 563-1100 (518)-283-872,2 L �T - Denver, CO Seattle, WA Austin, TX (303) 792-5555 -...>: (206) 778-5003 (51.2) 328-2410 -- �- / JOURNAL INQUIR Townes T THE-TOWN OIL <`'.: :;.........:.;....:........ .::. State DEP , town ? r G p9 d. :' PriceSu 'ect to change -: <:E <>z:»>s> i5:'s:>«:'•>E«;:::»>::»>s:i:E:::»>:«:»::>::> 150 al:minimum 9 minimum hold inve stigation ate 0 n C D - urner Service Available Abw S_gq 8.,.,E S/dtpd SyiaispM►o for lead- ex osure I wesre p y Unite Volume Discounts. exposed to.high levels of airborne 627-9690 55 No.- Mahe By KEVIN MAYHOOD ' lead and copper fumes _ Journal Inquirer Staff-Writer; ' "We're ,reviewing `their whole. ' NEarEC M file with a view toward particular Fri. 4-8PM • Sp SOUTH. WINDSOR - South `Problems cited by OSHA"-Carlton <. Windsor Metallurgical- Inc:;: AUTO RADIATORMEATER - charged- with exposing its Dodge; supervising- an-,- pollution &AIR CONDMONING REPAIR p g en ineeer for the DEP Air Com. Yvonne Gonzal employees to high levels of g j�; .. pliance Unit said.. will havE airborne lead inside the building,is De tula said "If there is � tfa> Wa # am now under investigation by the p ' ? ivcli is: t.#1alr .•::::::::::::.:.:;: $a#. Mar state De artment of Envi airborne lead inside, the question <: 1pk illp . pronmen- :: .:... is, is there airborne lead outside'. askabwour tal Protection and Town Sanitarian "FOREVER GUARANTEE"- Robert Deptula, .to find out if "We're trying to find out-what +. .Free nearby residents are- also being they're discharging." Oro Shoham Rd.,E.Windsor,CT. exposed to airborne lead. A DEP official said investigation (next to Trolley Museurra exposure to lead ..inside,' • Proceeds t0 b1 of a .inside the The company .was- cited this . ' week with with 22.violations of the building is under the OSHA's federal 'Occupational _Safety and jurisdiction, but if the lead is-dis- Health Act, which has renewed charged outside,it be -- comes'a mat- ` scrutiny by local and state agencies. ter for DEP and-possibly the.U.S. The DEP charged the metals Environmental Protection Agency. • refinery; located. on Rye Street, ' State Rep._ Kevin-. Rennie, with an odor violation discovered R-South` Windsor,: said. he. will -. i' �• C ,,,. in December.Residents of nearby : meet with newly-, a rated DEP Farnham Estates believe the corn- y PPo f ' Commissioner Timothy Keeney pany is the cause of an occasional.;-•and ask hum to pursue.an investiga- _ chlorine-like odor pervading their tion and; if warranted, vigorous neighborhood. The townspeople >- enforcement: have told officials they fear then -r It, seems that. plant deserves t �/ health maybe affected by it: L r ,� * ' State officials could not say at their full attention, -Rennie said.: ,, h !�) The company,which opened for this point if there may be a link business in 1985,-reclaim fi s and re- I'1 between the odors and Occupa- fines precious metals from com- tional Safety and Health . =. Admnistration's findings that puter and industrial equipment. = employeesinside the building were: See COMPANY, next page 01111 j e '`•would`oversee''the towns pig itc fo 'e'tn disrepair"and'"in need of Kriiep has'pcoposed the an at jat$ oao or !r will % library system better maintenance. the request of local police and pLrMouTH '••• An ordinance mandating the As proposed b Knie , the new public works officials,who say they $2,a dr.List resses, g P P Y P P cons. or b the in- ( formation of a Library Commission ,commission would be advisory in need town streets to be clear at pond. TH t- will now be forwarded"to the full nature, similar to the Emergency night. pwMouTH a !nd the wgn., imma council for a public hearing and Medical ',Services Commission, The council rejected the power, i - .I -_ ' motor,$400t Consideration. which oversees the -towns proposed ban last summer, after a PLYMOUTH 1 1 . 'We'll have to get some imput paramedic serice. hearing at"which only six people Voyager. I from the public before we decide Libra Director :Patrick 'M. spoke. cond.$11,9C Ponot sour anything;'.'said Democrat Harry A. Jones would be asked to attend the "We need to hear from more PONTIAC 796E Egazarian, chairman of bath. the commission's meetings to answer that just six people," said,Re to ., er. and _$21t _ordinance committee and the full ;questions`and report on various publican Councilwoman Marylee �s-042t. ie service council. aspects of the library systems Hickey, also-an ordinance commit- polvnac 19e AT,2 dr.bo 1 Mayor Susan G. Kniep last year -operations,.Kiiiep has said. tee member. $400 or envelope ' 1 .proposed the Library Commission Jones, who earns an annual ;Egazarialn has criticized the t��s 781 5t pONTIAC 19E as a method of providing residents °salary of of$50,748,has declined to proposed parking_ban, saying it cyl., AT, a 1 with a better avenue for their sug comment on the -proposed com- could be a-hardship for residents $2,000, ru 1 gestians and concerns_about the mission. without enough off-street parking PONTIAc tsE town's four libraries. i , 'm not sure we need it,but I'm for.:all their vehicles = 2 dr, s sao 't sell.Loadec The new panel would be asked willing to-hold a hearing on it and Maybe we should think about dition.$650 to investigate how to improve see_what people think," Egazarian one-side parking," he said. *_ PRICES :=SW grand fist �sliows s igh-t increase ON All i -_ SOUTH _WINDSOR 'The we have to really hold down the And if the state Department of PEl ",tow grand list grew 2.2 percent, budget." Public Utility Control allows Con- _ _ 1981 as .projected earlier this month, The town has to make payments .necticut Water Company to .raise 2 dr champ yielding an additional $650,000 in on a-$26 million bond package for its rates as requested, "we face an clutch,low n 1 tax money, town officials said. a South Windsor High School"ex- increase of.$150,000," she_added. SA 1 s The growth, substantially lower pansion project, major medical in- Zurbrigen has been meeting 1977 Cht' 1 than the double-digit expansion re- surance costs are expected to rise `kith deartment heads and is ex-' 4 dr Sedan, corded in the late 1980s, is-still the -40 percent and health insurance is with only 68, 1 - ected. to -propose ,a bud et to Must be see highest among nearby towns — expected to increase 25 percent, p _ g ARI 1 ..tied with Glastonbury._ Zu_rbrigen rsaid. .; Town Council later in March. 1 ,The tax :revenue . generated 198` I _represents less_than a mill,and the 'COMPANY: Uhder InVeStIgatIOn a'ARealS 1 small increase, in , light`.'.:of z "and insurance premiums OSHAi°proposes to fine .South a dr Sedan DI 1 ;and other fixed costs,_means this Continued from previous page .Windsor`Metallurgical $17,360 if AT,Ps,ps. ;will be an., exceptionally tough OSHA inspected the plant this .the charges stand. SI .budget session, Town Manager -fall and winter-and charged Tues- Metallurigcal has until.March 11 :Jean Zurbrigen said =day that Metallurgical has exposed '"."We are the leaders, if you can :its employees'to high. levels-of to contest the citations and MAN( man: 1 osed pen before the in- call. 2.2 percent increase leading, airborne cad and has failed to take prop P P lY Zrbrigen said. " a'number of steps to tryao reduce 'dependent Occupational Safety Route 83 1 "And it means that because we -the exposure , , and Health Review Commission. Tahomine --are not generating the tax dollars, ' .�, STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION `►«.„ STATE OF CONNECTICUT VS. SOUTH WINDSOR METALLURGICAL, INC. IN THE MATTER OF AN ORDER TO INC. TO COMPLY WITH CONNECTICUT'S HAZARDOUS WASTE MANAGEMENT REGULATIONS. Having found that South Windsor Metallurgical, Inc., located at 300 Rye Street in South Windsor, Connecticut is in violation of Connecticut's Hazardous Waste - Management Regulations under the provisions of Chapter 446k of the Connecticut General Statutes as amended, the Commissioner of Environmental Protection, acting under Sections 22a-6 and 22a-449 of the Connecticut General Statutes, hereby orders South Windsor Metallurgical, Inc. to take such action as is necessary to: 1 . Bring all waste handling procedures and facilities. into compliance with all applicable Connecticut Hazardous Waste Management Regulations. South Windsor Metallurgical, Inc. is further ordered to accomplish the above described program, except as may be revised by the Commissioner of Environmental Protection, in accordance with the following schedule: A. On or before May 31 , 1989, verify to the Commissioner of Environmental Protection that a qualified consultant has been retained or that in-house expertise exists to perform the necessary studies under Directive 1 . B. On or before July 31 , 1989, submit to the Commissioner of Environmental Protection for review and approval a detailed report providing an inventory (identify and quantify) and hazardous waste determination and/or precious metal declaration for all wastes and/or recyclable materials stored on-site. C. On or before July 31 , 1989, submit to the Commissioner of Environmental Protection for review and approval a detailed report providing for necessary management procedures to comply with Connecticut's Hazardous Waste Management Regulations. This report must include, at a minimum, container management procedures, record keeping requirements to document that materials are not accumulated speculatively, and a demonstration that materials are legitimately recycled. Phony: 165 Capitol A%enue • Han dford, Connecticut 06106 �/E� An &,-uul Opportunit) Entplo.Ver F Rr P_ Order No. HM- 606 Page Two D. On or before July 31 , 1989 submit to the Commissioner of Environmental Protection for review and approval a report detailing manifest procedures. E. On or before October 31 , 1989 verify to the Commissioner of Environmental Protection that all hazardous wastes identified in the report approved under Step B have been removed and disposed of properly. F. On or before October 31 , 1989 verify to the Commissioner of Environmental Protection that the remedial measures approved in compliance with Step C have been implemented. G. On or before October 31, 1989 verify to the Commissioner of Environmental Protection that the manifesting procedures approved in compliance with Step D have been implemented. 'Entered as an Or er of the Commi ioner .of Environmental Protection this day of , 1989. Leslie Carothers Commissioner Order No. HM- 606 Town of South Windsor Town of South Windsor Land Records Sent Certified Mail Return Receipt Requested P 701 020 472 DIRER THURS.)AY. FEBRUARY 28, 1991 4 , :JOURNAL INQ 3' :.....:::....:;:.;:.Ax F .... TOWNS r e` t DEP : Scat own invetsao ldJ ;for lead ex osure exposed to high levels of airborne By KEVIN MAYHOOD _ lead and copper fumes. > 3 Journal Inquirer Staff Writer '°We're"'reviewing their *hole file with- a view toward particular SOUTH WINDSOR ---South. problems cited by OSHA,'Y;C"Iton Windsor `Metallurgical '"Inc., Dodge, supervising air:pollufion charged with exposing its engineeer for.the DEP in- employees to high 'levels of pliance Unit, said. �,- irborne lead inside the building,is Deptula said,; `If there -'is ' ow under investigation by the "airborne lead inside, the q� state Department of Environmen- is, mere airborne.Lead outside:': tal Protection and Town Sanitarian „We're trying to find out what Robert Deptuta, to. find out S they're discharging." F nearby residents are also being A DEP official said investigation exposed to airborne lead. 'of a osure o lead inside _:the The company was cited this building is 'under the OSHA's week with with 22 violations of the g federal Occupational Safety and jurisdiction, but if the lead is dis- Health Act, which has renewed charged outside,it becomes amat- ,scrutiny by local and state agencies. ter for DEP'and possibly the`U.S. The DEP charged the metals _Environmental Protection Agency. -refinery, located on Rye Street, State Rep. '.Kevin Rennie, _*ith an odor violation discovered R-South Windsor, .said he will in December. Residents of nearby .meet with newly- appointed DEP ;Farnham Estates beliove the com- `Commissioner Timothy Keeney pany is the cause of an occasional and ask him to pursue an mvesti n ga- chlone-like odor pervading their tion and; if warranted,}vigorous neighborhood. ' The ,townspeople 'enforcement have told officials they fear their "It seems that. Plant deserves health may be affected by it. '- weir full attention,' Rennie said. State officials could not say at Tlie company,which opened for this point if there may be a link business in 1985, reclaims and re k -between the odors:and Occupa- ,fines precious_metals froin 'tional Safety .and Health putewdug tnal equipme P w AAdmnistration's findings A"= loyeesinside the building were Se e COMP EfY� next page MPAIV,Y: lender investigation t OSHA proposes fo fine Stfit ., 'Continued from previous page -Windsor Metallurgical $17,300�it OSHA inspected the plant this., - - the charges stand ' r fall and winter and charged'Tues- Metalungcal has until March Ub day that_Metallurgical has exposed its, employees'-to high levels `of to contest -the:' citations and " airborne lead and has failed-to take" proposed penalties before the in a number of steps to try to reduce dependent Occupational',-Safety e the exposure. and Health Review Commission P WAD -= 1ti"7rr �r /GA!7c7�:77 V nn•,•n r*• - :.ti.., BUSINESS OSHA cites SW firm for violations gastrointestinal system, renal workers against lead exposure. By KEVIN MAYHOOD system, and reproductive system of ■ Failing to keep cafeteria Journal Inquirer Staff Writer individuals exposed to lead in the surfaces free of lead accumulation. workplace." ■ Dry sweeping instead of SOUTH WINDSOR — The Oc- Company officials did not return vacuuming, to remove accumula- cupational Safety and Health Ad- calls for comment on the citations. tions of lead. ministration is seeking to- fine Of the 22 serious violations ■ Using vacuums without filters -South Windsor Metallurgical Inc. cited, 15 were related to exposure that would prevent lead particles $17,300 for 22 serious violations, to lead. They include: from re-entering the work environ- including exposure of its ■ Exposing employees to ex- ment. .employees to high levels of lead. cessive levels of airborne lead. ■ Failing to require employees The agency,basing its allegations ■ Failing to monitor quarterly to remove lead contamination from .-,on inspections since October to and every six months employee their work clothes before entering `pbruary, said the precious metals exposure to lead in areas where the lunch room. eft; mery should have been aware exposure is known to have ex- ■ Failure to conduct regularly that' the hazards it cited could ceeded permissible limits. e biological monitoring of employees cause serious physical harm or ■ Failure to notify employees exposed to lead. even death'to its employees. exposed to lead of corrective action - ■ Failure to keep accurate re- South Windsor Metallurgical that would be 'taken to reduce cords of monitoring for lead ex- =was also cited, but not fined, for exposure below permissible levels. posure seven less serious violations, such ■ Failing ;`to implement The federal agency .also cited 'as blocking an emergency exit and engineering and work practices to South Windsor Metallurigical for failing to store properly respirators reduce employee exposure to lead exposing employees to excessive not in use. and maintain it below permitted levels of airborne copper fumes, "'Employers exposing workers to levels. storing more than four times the dead must and should be aware_ of ■ Failing to provide a written permissible --aniourit of liquid their responsibilities to take all compliance program to reduce lead propane gas inside the refinery, possible steps°to limit that ex exposure to or below permissible and failing to monitor oxygen defi- posure and ultimately protect their limits _ - - ciency or combustible gases in con- employees from it," OSHA Area ■ Failing to perform proper fined spaces ;Director, John' Stanton :said. .ventilation:checks to-demonstrate The company has -15 days to `.`OSHA's premissible exposure the effectiveness.of the'system in .`contesi'the citations and proposed #unit for lead was .established to - controlling exposure to lead =",- penalties` before the independent event cumulative damage to the Failing to test properly the fit Occupational Safety ands., Health -Iood system, nervous system, of respirators designed to protect Review Commission. �towN Sf,t� a 9 71 a_ u� 01te So� V&U&Ot 1540 SULLIVAN AVENUE . SOUTH WINDSOR. CONN. 06074 f'1oSOR-C AREA CODE 203/644-2511 November 13, 1989 Mr. Edward Kish Chief Refining Engineer Handy & Harman 300 Rye Street South Windsor, CT 06074 Dear Mr. Kish: Pursuant to our telephone conversation of Monday, November 13, 1989, two odor complaints wre received by the Town on this date from residents in the area of McGrath and High Tower Roads . The Town Environmental Health Officer responded and confirmed the presence of the odors, which were described as "chlorine-like. " He took notice of the wind direction and reported that the wind was coming from the direction of the Handy & Harman facility; no odors were detected up-wind from the facility. Please complete your investigation of the Facility's processing units on this date as a possible source for chlorine or bromine odors . I will be looking for your report. - - --- - --Please report, as- well;---the-findings of Mr.- Kettler concerning an odor complaint brought to his attention on October 16, 1989. There is an odor problem, and we appreciate your cooperation in finding the source of these odors. Please feel free to contact this office. Very truly yours, C. F. Shaw, Ass't. Director Public Works/Pollution Control CFS:bmr / cc: Robert Deptula, Environmenal Health Officer✓ Gary Rose, DEP M. Gantick, Director of Public Works l�WN Sf+ O � 1540 SULLIVAN AVENUE SOUTH WINDSOR, CONN. 06074 Soe•co AREA CODE 203/644-2511 JEAN E.ZURBRIGEN Town Manager November 1, 1989 Mr. Carl Pavetto, Bureau Chief-Air Management Air Monitoring Department State of Connecticut D.E.P. 165 Capitol Avenue Hartford, CT 06106 Re: Odor Complaints - McGrath Road Dear Mr. Pavetto: A three year old recurring odor problem in the area of McGrath Road and Rye Street in the Town of South Windsor has been a source of great concern and distress for local residents. The D.E.P. Air Compliance Enforcement Unit has worked cooperatively with area residents during this period to identify the source of the odors and to correct the problem, unfortunately these effects have been unsuccessful. The Town believes that this problem has gone on far too long without achieving any meaningful progress. The Town has solicited the assistance of Mr. Gary Rose of the Air Compliance Enforcement Unit in reviewing the air compliance permits of those manufacturing facilities near to 3 McGrath Road and Rye Street. The Town requests your assistance in this matter. The Town requests that air monitoring/sampling equipment be installed and used in this area so that a sample of the odor producing gas may be collected and identified so that the source of these odors may be better determined. r Page 2 Odor Complaints - 1111189 The residents and Town staff have informally described the odor as a chlorine-like (or bromine) odor. The Town of South Windsor would appreciate your prompt action in this matter to resolve a long standing concern for air quality and public health in the area. Very truly yours, an E. Zurb gen Manager CAA wn of Sout Win cc: Robert Deotula, Environmental Health Officer C. F. Shaw, Assistant Director of Public Works � • Y U = f~ OR-co •+t r aaaa �► sa„ +► aA w �'� a�i+:*+� �t . .+a4�►.�+. �FRIDAY;OCTOBER 6 1990".' t.+b y' ` s tx !1 ` n' Zii",� N Ya ,,,.` .� '...d'u •,u:� �`'d xd ';!:+.,,. +!4`-. YShY .?a,ti, a ..a 9,2'TSB�, �:..3 Y a y 'f�F y.,%N.. .r •3 :�' t ^�A:RPr v' '.{' F£q�t ' 1` acyr 4's' ..: ..Yrw,":.. , F'p r 2 ..,1•i;; a ,✓`$y a <7� i,`$n:.: y ,*fix �° �:` -"�' a ✓ ,,,r-x.: .. y,+ j'S.� :+ w5K5�:, -i ,R�. ",7�';'f T i:: . ``' �`kfii.�d'''c.�' „n Qa „,� c .s. ;;.: '",Yt ?'�`. 's.�r '�� ..�,s' �... '�✓, r ✓. �.. ..+.:: :.. CN e.�w .LF.. k;.A • .r Y_i::""'4t... ,: d'+.5.,..'1t Y.t.; •T.iK b .Y .. fd+1n� 1?l.ir'y,� V e }.• �.�, nr'g;�r"'. 'Y ,4`• ,,q "yp 3{ , a R6curang _foul odors turn 't , t" x �P 1� Y rF. .�. �. . %+r n �� s rd ,$.... ^a r: .s ci'+,, � { :needs,:limits FKto vchecl �fornew�� sourc ea� �- ;g ,,y' i us'n .,,.rta�"�"-wp q�v. �.'.' ",Ml 4 ) r '°"'r 'a 4 t�✓f x�F:,� 7r' '?%�7r� +iC'�' �`,� 3 y �k x �- '�` 4�`'+°r,'`•S, .'1 ��.:'n �.�O. �. �''a: :",.t'}9t:. ;' 'r�Gt.,.� Ft''• :.�..�k, c, .; �h' ,., � ( �.` ik 1 +, sj 4t:.." a,, '',: I. ,...:ia 's. •.^ r':.s.-` o., .a ._,. ,.n q}:,r r a >.-% <. F .: c r. .` •' . "'.r,a ,;tb .� .E >� i;WflS'fthe+.y:cUl rit ` r -i• 5:" , The wind:dtrection-leads us,Fta•believ believed the coin an p. ,. By KEVIN 'MAYHOOD ;xahe:odor'may be'from a;.differe _ source'��,espectally ;•when ;the <'DEPx found <"a it tall Writer.,.,. ;' x s ;, olittle said.; wWe - lan to' do a; eneral -sniokestack.scrubber designed.to remove the . By CHRISTINE DEMPSEY ; Journal.nqu e[. ^.,, D P gi g residuerwas not operating this Journal Inquirer Staff Writer a-.:survey of other odor sQurces.within the next odofi�causm :aSOUTH WINDSOR After reserving two weeks" '' ` `, :�;:year: "�, r hq r r r;. �: The,towel needs, three coin Taints':of fout ;,odors :.:in= the. . Reidents';of Farnham-Estates,,, mt.r the ,le'.company `promised not toa.use%the WINDSOR =- P limit overall development but encou Farnham.Estates subdivision:``in.one week,; oorth-central section of awry,:•have`com-_,stack until the scrubber was,fixed and also ;affordable. ' housin ';,.for the,"eld the state=Department of''Environmental plained=•about`an,:occasional'"chlorine-like_promised to.take further that,;would " g Protection said it will do a general study of •single•parent families;and other h�odor; permeating neighborhood ;for reduce the amount of residue that escapes segments of'its population, accordin the area and lookfor a source of the odors. more than three;`.years On•;niost days,;the from the plant housin uidelmes in..the towa'a.: r;the study; DEP official:&; ors`sa it'is:`a li 't,'smell : button :When the stack tvas;out.of.operationthis laneof develo ment. : _ The reason fo neighbors , y, gh said,,' is that on 'twto"of the'three days:l :` _,;;-others,„it..has been;described as "Stifling," summer,the number of complaints .`slowed Without new-limits the towm' complaints were lodged, the.wind was blow_ -;. ::,.;makin if-difficult,for'same to breath The: .dov in significantly,we be11heve,ti Dohttle said ^have;as many as 35,000 residents by .,:-mg in'.a''direction>'that :would 'not carry ' g g P j 1? ,y ` year`2000 -'only 10 years henceN+,. exhaust from the buisness generally blamed odor'has,;almost alwa�+s made`its appearaiice Durin an:ins ection .of the coin an two ' w.,between 9 a,m to'Ss�p,m., leading:offlcials to,f.weeks ago,'' Dolrttle said' South<,Wnsdsor ;its rvacant' residentially.zoned'1 for the smells.toward;the,neighborhood.' b sines. .`Metallur ical had ,taken ;`quite,a few ;re developed under current regulation , bell ve it frotrf`an`.area., u „ g The"",,;bus.iness, °'South .Windsor; h . e. - Tan-says..Windsor's ulaholn.; r ieal:recently took sle s'to ease the- ';`the=DEP•identified,the odor in;19$9 'as"',medialF steps 4 k p y PoP Metallu g � Y P, :;" he result of a DEP.;tns ection,said:. residue from'burned;computer=equipment Up' until` last.:�week; ,Town= Sanitarian about'27,500 odors as t :, v;,;, p :, .a process em to eel.,„b , South;Windsor •Robert;Depiula-said he., received on � The plan, which the town ha3' ;: Jack Dolittle, senior air pollution con p P. Y Y. t -workin on for.five. ears, is.beln" 'M w a•,r`., �- etallur ical: Nei born nand .the DEP twocotriplaints since July.:: , a >:a:� g Y trol egineer� �+ 1 k viewed by the Town Planning and;, _ 4 g tin Y Wmmission and will bt x ,afterward at a public heanng 1 available;at-the Windsor Pub tii and at Town,HA Among 26 housing repo wthe:first.is to t'edtice;the town', ` development potential by l that 15'.percenC of,the,requited x, f ,';be in nornwedand and•:non- A., 'No is no h 'aCCOrdin 'i tothAsslstantf Town' i•' .`;: �. /AI. ` �a ra M i,r.^ ':.• "' Eric AW I But 'while `the plan ad i overdevelopment, it also says'; should strive to keep,housmg� 1.0 "fit Despite the town's wealth! , eaprta'than that.,of' , �„-, ,. � "municipalities in 1980 - •and ? 7r .providing' some affordable high-affordability, problems t -' ♦ �j and not enough low-cost b 4 ;j: been built,the plan sa -- -�- _-- Mu who is assigned to the com- . len students to consider t .the high school, this year money two part-time counselors to work y+ g ging ^will be used to counsel teenage and with students at the Mayberry,Nor- munity-outreach unit. fects of drugs. �reteen students and enhance police ris and O'Brien elementary. schools, The department will also use the Last year,part of East Hart „presence in targeted neighborhoods. and at the East Hartford Middle grant to fund visits by police officers grant financed operation May ra - CO V r - Officials continue mvesti a m re orts g p rf6um l m odor a:of ls e .• - _ - - _3'! • cials could not be reached for com.- + By LEE FOSTER ment Friday. Courant Staff Writer Paula Rowley of McGrath Road` . said she notified the town sanitarian. SOUTH WINDSOR-State envi- that the .smell had returned last _sonmental officials said Friday that.. week.The last time Rowley noticed they will continue to investigate a' the odor was in June,when it was so • foul smell that has been reported in a strong residents had to shut their residential area in the north-central _`doors and windows • part of town. _S r "It is definitely the same smell as_r w • Department of Environmental in June,"Rowley said,although the a Protection officials said South Wind smell was not as intense.."It has b sor Metallurgical Inc., a business gotten better, but it has not gone that was blamed for-the chlorine- away.": • like odor in June,probably was not Farnham Estates is in-a slight ` responsible for complaints received depression,separated from the met- last week: - ._ . 1 '" allurgical company by a small river " ■ The company fixed faulty equip-', «I can see where an odor that was « ment after a June DEP investiga blown into that area would just sit ' tion, and environmental officials . there,"Benny said said the company was an unlikely t• South Windsor Metallurgical has source because the wind apparently,,' installed wind-direction devices,;; was blowing in a different direction. Benny,_said, so_the,company, can,..,,. ■ .: The DEP will begin investigating `,-quickly track the odor's directaon:: other possible sources in the area, . q y such as sewer outlets, said Brian when complaints are received. • Benny, a DEP air pollution control : "Residents have been encouraged':` engineer. to notify South Windsor Metallurgi "The first time,there was no ques-!-0; Cal immediately when they smell tion afterburners in the company's anything"Kenny sazd. 4 • smokestacks were not getting up to Courant Staff WriterGiouanna T mci_- temperature," Benny said.. After chi contributed to this story 'h t" burners, which are designed to re-- bum smoke to eliminate pollution,'` South Wind r . must reach a certain temperature to Soulmeet Wi « be effective,he said. 4::, • gs Residents of Farnham Estates— who live on Farnham,McGrath and ■ High Tower roads have complained TOM/1 Hatt, 1540 Sullivan Ave., 644-` for several ears about a chlorine- 2511.All meetings are in town hall unless Rar .m h y otherwise noted. like smell that can last from five Public meetings this week:, � * minutes to all day, town officials ■ • Tue Historic district commis- Saki..�,.:: . sdays After several complaints in Jun sion,7:30 p.m.;planning and zoning com- •-■ p e;. mission,8 p.m.;town council,7:30 p.m. the DEP determined that the source .P . Wednesday. Parks and recreation of the smell was a malfunction 1n commission, 7:30 p.m.; housing task d equipment at South Windsor Metal force,7:30 p.m.' . lurgical. '-a • Thursdays Design review board,7:30 . South Windsor Metallurgical offs P.m.—.- --` (I 2 r'Fyl 1 L - x - a, .. t -£ , -.fit :i+. 't; -.'• a .. ..a ■After a year as principal of Manchester High School,Jim ■ r - g education has prompted school officials and teachers to S 411 ry Princl aQ ucatDedication fan p P - South Windsor Metallurgical, Inc. A Handy&Harman Company 300 Rye Street,South Windsor,CT 06074•Telephone (203) 282-0871 October 19, 1990 Mr. Bob Deptula Sanitarian Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Bob: This is to inform you of the reason for the odor complaint which we received on Wednesday morning at 11:00 A.M. from Angeline Goodlin, 41 McGrath Road. As I mentioned during our phone conversation on Wednesday morning, we had two servicemen from Yankee Gas here at the plant, who were changing a gas meter on the incoming gas line. We were assured that there would be no interruption of gas service because there are provisions for bypassing the meter. Unfortunately, one of the two regulators in the bypass line did not fully open thereby causing a fuel shortage, which then automatically shut off all burners. Only one piece of equipment was affected by this shutdown of gas service. The service was restored in about thirty minutes. At the time of the call, the wind was out of the South and Southeast at 2-3 mph. In the future, in order to prevent another occurrence of the above incident, any changes which may be required in our gas distribution systems will be scheduled for the weekend when our production equipment is not operating. Should you have any questions or if additional information is needed, please cal me at the plant. Sincerely, Edward Kish Chief Engineer EK/mef Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum ,r Y South Windsor HE fl Metallurgical, Inc. A Handy&Harman Company 300 Rye Street, South Windsor,CT 06074•Telephone (203)282-0871 October 2, 1990 Mr. Bob Deptula Sanitarian Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Bob: This letter will confirm the discussion which you and I had on Friday, September 28th, relative to the odor complaint which you received from Lucille Shay of 61 High Tower Road. She called to report of the odors which she detected in front of our plant and at her home on September 26, 1990 between the hours of 11:30 and 11:45 P.M. After investigating both the times at which our operations were running and the wind direction during this period, we offer these comments: 1. Two major operations were not running during the time in question because of maintenance. 2. We begin our shutdown operations at approximately 10:30-10:45 P.M. 3. The wind direction at that time was out of the East and Southeast. 4. By 11:00-11:15 P.M. , our equipment is cleaned and shutdown. 5. From 11:00 P.M. to 12 Midnight, the wind was out of the North and Northwest. On the basis of the above information and the recorded wind direction, the odors reported on the 26th could not have come from our plant. We have attached a copy of the wind direction chart for your information. Should you need anything further, please let me know. Sincerely, Edward Kish Chief Engineer EK/mef Attachment Fabricators of precious metals, special metals and alloys• Refiners of silver,gold and platinum IIIIIIIII.wI�u���ali��lllllllllllllllllillllllllll!! � Illlfllllllfllllllllllllllllllilllllllllllllllll IIIIIIIIIlIIII�i�I�IIIIIIIIIII111111111N1111111IIIIIII ,f�lllllfllllllllllllllllllllllllllllllllllllll! 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I BIIlI11N IIHI 111111111111111111111111,A .:IIIIIIIIIIIIIIIIIII�lllllllllllllllll�>N��Illllllllf111 F ,, IIIIIIII1111111111�IIIIIIIIIII111111111111111F�'Ill�` ,�Illl{IIIII!llllllll�l��l�lll��lllll����llllllrlllllll :y� �lfllllllflllillllllllllllllllllllllllllllll�:�� . MEMO: TO THE FILE RE : COUNCILMAN KUPCHUNOS' REQUEST AS TO WHETHER THE TOWN HAS AUTHORITY TO ENJOIN OFFENSIVE ODORS/ POLLUTION 1. The injunction authority is granted to the State DEP under Section 22a-180 of the General Statutes . This would pre-empt the Town bringing an injunction action for air polluti-<n as such. However, the Town can, under Sec. 22a-185 , adopt an ordinance for the control of air pollution . However , this must by done only with the approval of the Commissioner of DEP . At preseat , there is no such air pollution control ordinance in the Town of South Windsor. 2 . In view of State statutes giving the Commissioner power for injunction , it is clear that this injunctive power has . been pre- empted by the State on the sole issue of air pollution control at least until the Town enacts its own ordinance . 3 . However, Town ordinances do provide in Sections 5-300 through 5-310 for anti-nuisance and prohibits waste material to accumulate in a manner which is offensive or -detrimental to the general character of the adjacent neighborhood and to property values therein. Based upon that ordinance , and based upon the common law, it is possible for the Town -to seek an injunction ; o restrain LAW OFFICES RD M.RITTENBAND or prohibit the continuation of such a nuisance. The argument ' ELLINGTON ROAD might well be made that the State has pre -empted this , but I i WINDSUR,CT 06074 - believe in a common law action or an action under this ordinance , (203)644.2456 the Town would have a good likelihood of prevailing . ctowever , 1URISNO50412 essential to the success of an application for an injunction is to have evidence of the nuisance in detail with expert testimony as to its existence and origin. This would require. a, thorough study by an expert in the field who would then be willing to testify to convince a Superior Court judge to grant a restraining order because health and safety would be in immediate danger. With all of that , the Town could attempt to enjoin the offensive odors or pollution that exist . 1 4 H� Hl� Hand & y Harman Precious Metal Refining Division:300 Rye Street,South Windsor,CT 06074 Telephone;(203)282-0003•Fax:(203)282-7461 May 25, 1990 Mr. C. F. Shaw Assistant Director Public Works / Pollution Control Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 RE: South Windsor Metallurgical Odor Investigation Dear Mr. Shaw: Enclosed is a copy of the second phase odor investigation report prepared by TRC Environmental Consultants. As before, we have submitted this report today to the Connecticut Department of Environmental Protection (CDEP) . TRC found only trace amounts of a few compounds in the process exhaust. TRC then determined that the concentration of these chemicals are at least 100 times lower than the maximum allowable levels as determined by the State of Connecticut Hazardous Air Pollutant Regulations. This implies that these compounds do not present a health risk at the levels that were found. CDEP allowable levels are intended to protect the most exposed individual who, in theory, lives continuously at the downwind property line. Therefore, individuals who reside much further away and only occasionally downwind are even less exposed and still further protected. This report completes the TRC investigation of potential odorants at South Windsor Metallurgical. Nevertheless we would like to assure you that we will continue to investigate potential improvements in our processes and pollution control equipment, and indeed are currently examining ways to improve our scrubber efficiency. We intend to continue to be a responsible corporate citizen, ensuring that our operations are protective of health and the environment. If you have any questions concerning the report, please call. Very truly yours, Richard A. Kettle Manager-Refining Operations Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum group metals A CONTINUATION OF THE ODOR INVESTIGATION PROJECT SOUTH WINDSOR METALLURGICAL, INC. SOUTH WINDSOR, CONNECTICUT Prepared by: Karen E. Brown Environmental Scientist Samuel S. Cha Program Manager TRC Project No. 6850-M51-03 May 1990 TTC Environmental Consultants, Inc. 800 Connecticut Boulevard East Hartford, CT.06108. , (203) 289-8631 A TX Company t EXECUTIVE SUMMARY Previous odor study has shown that emissions from the process stacks at the South Windsor Metallurgical, Inc. 's facility in South Windsor have the potential of contributing odors to the residential area and the immediate adjacent area near the facility. Measurements and mathematical modeling indicates that the odor is not objectionable, either at the plant boundaries or the nearby residential areas. Nevertheless, because odorants are detectable on occasion under certain meteorological conditions, South Windsor Metallurgical requested further study to determine if any odorants could have adverse health effects. In March 1990, TRC collected samples from the Dry Pan exhaust stack and the furnace TR-10 exhaust stack. Subsequently, samples were analyzed for volatile organic compounds including ketone compounds. More than 35 compounds were screened, but only trace amounts of a total of six compounds were found in the samples. Further calculations were performed to determine if the compounds that were found are in compliance with the State of Connecticut Hazardous Air Pollutant Regulations. Calculation results show that the concentration of these compounds found in the stacks are at least 100 times lower than the maximum allowable stack concentrations. This implies that these compounds do not present a health risk at the levels that were found. Furthermore, the maximum allowable stack concentration calculations are based on very conservative assumptions, i.e. , the person continuously exposed to the emission near the fenceline at downwind direction. Because the wind direction varies, and no person actually stays at the fenceline all the time, the health risk is further minimized. -ii- TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION 1 1.1 Plant Operations . . . . . . . . . . . . . . . . 1 2.0 METHODOLOGY . . . . . . . . . . . . . . . . . . . . 2 2.1 Stank Exhaust Sampling . . . . . . . . . . . . . 2 2.2 Scrubber Water Sampling . . . . . . . . . . . . . 2 3.0 RESULTS . . . . . . . . . . . . . . . . . . . . . . 3 3.1 Stack Exhaust Emissions . . . . . . . . . . . . . 3 3.2 Scrubber Water Analysis . . . . . . . . . . . . . 7 4.0 CONCLUSIONS AND RECOMMENDATIONS . . . . . . . . . . g 4.1 Conclusions . . . . . . . . . . . . . . . . . g 4.2 Recommendations . . . . . . . . . . . . . . . . . g APPENDICES A LABORATORY RESULTS OF THE VOLATILE ORGANIC COMPOUNDS TESTING B CHEMICAL EMISSION RATE CALCULATIONS C INPUT PARAMETERS FOR THE MASK PROGRAM IN DETERMINING COMPLIANCE WITH STATE HAZARDOUS AIR POLLUTION . REGULATIONS LIST OF TABLES TABLE PAGE 3-1 A COMPARISON OF THE MAXIMUM ALLOWABLE STACK CONCENTRATIONS VERSUS THE ACTUAL STACK CONCENTRATIONS AND THE HLVs FOR THE HAZARDOUS AIR POLLUTANTS REPORTED AT SOUTH WINDSOR METALLURGICAL (DRY PAN) 5 3-2 A COMPARISON OF THE MAXIMUM ALLOWABLE STACK CONCENTRATIONS VERSUS THE ACTUAL STACK CONCENTRATIONS AND THE HLVs FOR THE HAZARDOUS AIR POLLUTANTS REPORTED AT SOUTH WINDSOR METALLURGICAL (TR-10 FURNACE) . . . . . . . . . . . . . . . . . . 6 -iii- 1.0 INTRODUCTION TRC Environmental Consultants, Inc. (TRC) was retained by South Windsor Metallurgical to provide continued assistance in the odor abatement project at the facility located in South Windsor, Connecticut. Previous investigation had suspected the presence of volatile organic compounds (VOCs) in the exhaust stacks. The primary objectives of the continued project were to determine the presence of VOCs in both the exhaust stacks and the scrubbing waters, and to determine if the VOC stack concentrations, if found, are in compliance with the State of Connecticut hazardous air pollution regulations. 1.1 Plant Operations South Windsor Metallurgical processes secondary materials for recovery of precious metals. Its processes include burning of electronic materials such as computer circuit boards and drying and evaporation of wet residues. These operations take place in several custom-built furnaces, specialized in accordance with the material to be processed. Furnace exhausts are processed through a number of pollution control devices, including secondary furnace chambers, caustic scrubbers and baghouses. All furnaces and pollution control equipment operated by South Windsor Metallurgical are considered to be state-of-the-art within its industry, and have been formally reviewed and approved by the Connecticut Department of Environmental Protection prior to their installation and operation. Processes at South Windsor Metallurgical should result in exhaust gases consisting primarily of carbon dioxide and water vapor. Pollution control systems at the facility should capture and control most potential odorants. Nevertheless, the possibility exists that odorants are being created which are not fully controlled by present systems. -1- 2.0 METHODOLOGY 2.1 Stack Exhaust Sampling Integrated air samples were collected at the furnace- TR-10 stack and the Dry Pan evaporative stack. Samples were collected onto absorbing tubes and subsequently submitted for analysis using gas chromatograph/mass spectrometry. Due to the high stack moisture content which may have a negative effect of collecting and analyzing ketone compounds, a different absorbing tube was used for collecting the ketone compounds and analyzed by gas chromatography flame ionization detector. Air sample volumes for all the trains were approximately ten liters. Duplicate 50-minute tests were performed at each stack in accordance with the National Institute of Occupational Safety and Health (NIOSH) Method 1003. Concurrent with the gas sampling, volumetric flow rates were measured at each stack location using pitot tubes and a manometer in accordance with EPA Source Testing Methods 1 and 2. 2.2 Scrubber Water Sampling Water and scrubber liquid samples were collected, with the assistance from South Windsor Metallurgical plant personnel, at the following locations: (1) plant water supply used as makeup water for the scrubbers, (2) furnace TR-10 scrubbing water from the recirculating tank, (3) Dry Pan scrubbing water from the recirculating tan}c, and (4) TRC DI water to serve as a field blank. Samples were collected and submitted for analysis for volatile organic , compounds using gas chromatograph/mass spectrometry. -2- 3.0 RESULTS The sampling of the exhaust stack and the scrubber water samples were performed on March 14, 1990. Subsequently, samples were analyzed. The results of the analysis are presented as the following. 3.1 Stack Exhaust Emissions Samples for gas chromatograph/mass spectrometry analysis shows that, among the 37 VOCs searched, five compounds were found in the Dry Pan exhaust, and six compounds were found in the furnace TR-10 exhaust. Laboratory reports can be found in Appendix A. The quantities of compound found were converted to emission rates which are presented in Appendix B. The calculations, which determine whether the concentration of the VOCs are in compliance with the State of Connecticut's hazardous air pollution regulations, were also performed utilizing a TRC designed MASK program. The MASK program was designed according to the Connecticut Hazardous Air Pollutant Regulation. The MASK program organizes a facility's emission data by stack or source. Each source contains a subcategory for each chemical that is emitted from a source. Several parameter values are input to the program which are used in the calculations of the Maximum Allowable Stack Concentration (MASC) and the Actual Stack Concentration (ASC) . These parameters include: • Source Identification • Source Name • Stack Height (m) • Property Line Distance (m) • Volumetric Flow Rate (m3/sec) • Chemical Name • Chemical Abstract Service Number (CAS) • Toxicity Group Number • Hazardous Limiting Value or HLV (µg/m3) • Uncontrolled Emission Rate (pg/sec) • Control Equipment Name • Control Efficiency Percentage -3- wV The MASC and the ASC are then compared to determine if the concentrations of the emitted chemicals are in compliance with the State of Connecticut hazardous air pollution regulations. The CAS, Toxicity Group Number, and the Hazardous Limiting Value (HLV) are taken directly from the "Regulations of the Connecticut Department of Environmental Protection Concerning Abatement of Air Pollution," 1988, Sec. 22a-174-29, Tables 29-1, 29-2, 29-3. The input parameters are listed in Appendix C. A summary of the results generated from the program are presented in Tables 3-1 and 3-2. A comparison of the calculated Maximum Allowable Stack Concentrations (MASC) and the Measured Actual Stack Concentrations (ASC) found in Tables 3-1 and 3-2 show that all ASCs are below the MASCs. The ASCs are at least two magnitudes lower than the MASCs, i.e. , at least one hundred times lower. This implies that the neighbors are not under health risk. Odor threshold values can also be found in Tables 3-1 and 3-2. These values were published from data cited from different literatures. A comparison was made to see if any of the chemical compound concentrations are above the odor threshold values. There are two cases where the stack concentrations are above the odor threshold values, which means that odor can be detected at the stack. In the Dry Pan trial no. 1, carbon disulfide concentration is above the odor threshold value, and in the TR-10 furnace trial no. 1, the acetone concentration is above the odor threshold value. We may conclude that these two compounds were odor causing compounds at the day of sampling. In addition, the acetone concentration at the Dry Pan Exhaust is in the same magnitude of the odor threshold value; this implies that someone with more sensitive sense of smell may be able to.'detect the acetone odor from the Dry Pan Exhaust. -4- t TABLE 3-1 A COMPARISON OF THE MAXIMUM ALLOWABLE STACK CONCENTRATIONS VERSUS THE ACTUAL STACK CONCENTRATIONS AND THE HLVs FOR THE HAZARDOUS AIR POLLUTANTS REPORTED AT SOUTH WINDSOR METALLURGICAL DRY PAN Measured Maximum Allowable Actual Stack Odor Toxicity HLVa Stack Concentration Concentrationb Threshold Chemical Found Trial No. Group No. (pg/m3) (µg/m3) (ug/m3) (ug/m3) Dichloromethane 1 3 7,000 5,032,319.32 33.96 3,980 2 28.94 Acetone 1 3 11,800 8,483,052.57 739.26 948 2 229.77 Carbon Disulfide 1 3 60 43,134.16 314.68 50 2 114.77 Benzene 1 1 150 107,835.41 1.49 2,487 2 7.98 Chloromethane 1 3 2,100 1,509,645.74 10.62 21,000 2 <LODc a Hazard Limiting Value for an 8-hour average time at the facility property line. Published in the "Regulations of the Connecticut Department of Environmental Protection Concerning Abatement of Air Pollution," 1988, Sec. 22a-174-29, Tables 29-1, 29-2, 29-3. They are the bases for calculating the maximum allowable stack concentrations. b This is the stack concentration measured during testing of the stack exhausts. c <LOD is less than the limit of detection. • f r TABLE 3-2 A COMPARISON OF THE MAXIMUM ALLOWABLE STACK CONCENTRATIONS VERSUS THE ACTUAL STACK CONCENTRATIONS AND THE HLV9--FOR THE HAZARDOUS AIR POLLUTANTS REPORTED AT SOUTH WINDSOR METALLURGICAL r�' ;•'� r,'ic TR-10 FURNACE Measured Maximum Allowable Actual Stack Odor Toxicity HLVa Stack Concentration Concentrationb Threshold Chemical Found Trial No. Group No. (µg/m3) (Pg/m3) (µg/m3) (µg/m3) Dichloromethane 1 3 7,000 805,496.03 86.50 3,980 2 17.22 Acetone 1 3 11,800 1,357,836.16 5,245.24 948 2 709.36 Carbon Disulfide 1 .3 60 6,904.25 3.93 50 2 11.50 Benzene 1 1 150 17,260.63 8.86 2,487 2 3.50 Toluene 1 3 7,500 863,031.46 5.91 79 2 5.00 1,1,1-Trichloroethane 1 3 38,000 4,372,692.73 3.93 87,131 2 <LODc a Hazard Limiting Value for an 8-hour average time at the facility property line. Published in the "Regulations of the Connecticut Department of Environmental Protection Concerning Abatement of Air Pollution," 1988, Sec. 22a-174-29, Tables 29-1, 29-2, 29-3. They are the bases for calculating the maximum allowable stack concentrations. b This is the stack concentration measured during ,testing of the stack exhausts. c <LOD is less than the limit of detection. 3.2 Scrubber Water Analysis The scrubber water analysis is shown in Appendix A. Thirty-nine (39) compounds were searched for all four samples. Only trace amounts of one or two compounds were found in each of the four samples. In the Dry Pan scrubber water, 1460 µg/Q of acetone and 3240 ug/Q of 2-butanone (i.e. , methyl ethyl ketone, MEK) were found. This seems to indicate that the scrubber is effective in removing MEK from the Dry Pan process emission. It should be noted that trace amounts of chemicals were found in the blank sample, the plant makeup water sample, as well as the TR-10 furnace scrubber water. In the trip blank (i.e. , deionized water from TRC's laboratory) , 30 µg/Q of carbon disulfide was found. In the plant makeup water, 20 µg/Q of chloroform was found. In the TR-10 furnace scrubber water, 15 µg/Q of bromoform was reported. This could be contributed to the uncertainty of quantification at these trace levels, the contamination during the sampling or analysis, or other unknown reasons. -7- 4.0 CONCLUSIONS Based on testing results presented, the following conclusions can be made: 1-) Both Dry Pan exhaust stack and the furnace TR-10 exhaust stack emit trace amounts of volatile organic compounds. However, the concentrations of these compounds are at least two orders of magnitude lower than the maximum allowable stack concentrations (MASC), which were calculated based on facility site measurements and the State limitations. It is concluded that no health risk will be caused by these compounds in the emission. 2) Some of the chemical compound concentrations are higher than or in the same magnitude of the odor threshold values of these compounds, and could cause detectable odors. 3) Acetone compounds were found in the exhaust, but not 2-butanone (i.e. , methyl ethyl ketone or MEK) . The Dry Pan scrubber water, 1460 pg/Q of acetone, and 3240 µg/Q of MEK were reported. This is the evidence that the scrubber is removing MEK effectively. -8- APPENDIX A LABORATORY RESULTS OF THE VOLATILE ORGANIC COMPOUNDS TESTING TABLE A-1 VOC SAMPLES Train-1 and Train-3 Furnace TR-10 Exhaust Samples Train-5 and Train-7 Dry Pan Exhaust Samples TABLE A-2 KETONE SAMPLES CT-2 and CT-4 Furnace TR-10 Exhaust Samples CT-6 and CT-8 Dry Pan Exhaust Samples TABLE A-3 WATER SAMPLES Water Samples NORTHEAST RESEARCH INSTITUTE,INC. 309 Farmington Avenue,Suite.A•100 Farmington,Connecticut06032-1943 Telephone (203)677.9666 I TABLE A-1 FAX (203)677.7008 LABORATORY ANALYSIS REPORT S. Windsor Metallurgical Analysis Number Customer Address 1026G TRC Environmental Cons. East Hartford, Connecticut Samples Sent By Date Received Date Reported Analyst S_ TRC STaff --[ 3/15/90 4/6/90 RLK Material Analyzed Charcoal Tubes Sample Number Test Results nanograms i I TRC05 I Blank T RDN TSiC06 TRC07 TRC09 9�ipd I Tubs Train- Train-3 Tra Trips I Chloromethane I 50 U 20 J 15 J 55 50 U Vinyl Chloride I 50 U 50 U 50 U 50 U 50 U Btomgoethane I 50 U 50 U 50 U 50 U 50 U Chlozvethans I 50 U 50 U 50 U 50 U 50 U 1,1-Dirhicroatium 25 U 2 J 25 U 25 U 25 U Tric hlorofluozomethane I 25 U 25 25 U 25 U 25 U Dichlorctethans J 25 U 175 865 340 290 1,2-Dichloroethens I 25 U 25 U 25 U 25 U 25 U 1,1-Dichl.oroethane I 25 U 25 U 25 U 25 U 25 U Chloroform I 25 U 25 U 25 U 25 U 25 U 1,2-Dichlosoethane I 25 U 25 U 25 U 25 U 25 U 1,1,1-rrridtloroothans I 25 U 40 25 U 25 U 25 U Carbon Tetrachloride I 25 U 25 U 25 U 25 U 25 U Benzene ( 10 J 90 35 15 J 80 Trichloroethene I 25 U 25 U 25 U 25 U 25 U 1,2-Dichloroprcpane I 25 U 25 U 25 U 25 U 25 U Btnoodichloramethane I 25 U 25 U 25 U 25 U 25 U Trans-1,3-Dichloroprvpens I 25 U 25 U 25 U 25 U 25 U Cis-1,3-Dichloroprcpene I 25 U 25 U 25 U 25 U 25 U 1,1,2-rrichloroethane J 25 U 25 U 25 U 25 U 25 U Dibraoodtlor methane I 25 U 25 U 25 U 25 U 25 U Toluene I 5 J 60 50 20 J 5 J Tetrachloroethene I 25 U 5 J 15 J 25 U 25 U Chlorcbenzwa I 25 U 15 J 25 U 25 U 25 U Ethylbwmerw I 25 U 25 U 25 U 25 U 25 U Braroform I 25 U 25 U 25 U 25 U 25 U 1,1,2,2-Petrachlorcethane I 25 U 25 U 25 U 25 U 25 U 1,2-DicYtlorobenzene i 25 U 25 U 25 U 25 U 25 U 1,4-Dichlorobermane I 25 U 25 U 25 U 25 U 25 U 1,2-Dichlorcbenzene I 25 U 25 U 25 U 25 U 25 U Acetone I N/A N/A N/A N/A N/A Carbon Disulfide I 25 U 40 12.5 31W 1150 2-Butanone I N/A N/A N/A N/A N/A Vinyl Acetate I N/A N/A N/A N/A N/A 4-Methyl-2-Feentanonit I N/A N/A N/A N/A N/A 2-HexarK= I N/A N/A N/A N/A N/A Styrene I 25 20 J 5 J 25 U 25 U Total Xylenes ( 25 U 5 J 10 J 25 U 25 U 2-Chlozoethyl Vinyl Ether I N/A N/A N/A N/A N/A Thermal Desozptien Cryo- jU-axWtected. Value is detection limit for that cartipotud. focused GC/M. All values I assume loot desorption IJ- Estimated Value. Value is below the cos pound detection efficiency. I limit. I t LMU026G (428) i - O NORTHEAST RESEARCH INSTITUTE,INC. 309 Farmington Avenue,Suite A-100 Farmington,Connecticut 06032-1943 Telephone (203)677-9666 TABLE A-2 FAX (203)677-7008 LABORATORY ANALYSIS REPORT Analysis Number Customer Address 0390-1026G TRC Environmental Consultants East Hartford, Connecticut Samples Sent By Date Received Date Reported Analyst Sam Cha 3-15-90 4-6-90 MAP Material Analyzed Jumbo Charcoal Tubes Sample Number Test Results Micrograms Acetone MEK MIBK 2-Pentanone CT-2 52.4 LT 0.4 LT 0.2 LT 0.2 CT-4 7.2 LT 0.4 LT 0.2 LT 0.2 CT-6 7.4 LT 0.4 LT 0.2 LT 0.2 CT-8 2.3 LT 0.4 LT 0.2 LT 0.2 Blank LT 1.6 LT 0.4 LT 0.2 LT 0.2 Analytical Methods Special Notes GC/FID MEK = Methyl ethyl ketone (NIOSH 1300) MIBK = Methyl isobutyl ketone LT = Less than O NORTHEAST RESEARCH INSTITUTE,INC. 309 Farmington Avenue.Sure 3 Farmington,Conaecticut06032-194.1943 FAX Telephone (203)677.7008 � TABLE A-3 LABORATORY ANALYSIS REPORT S. Windsor Metallurgical Analysis Number Customer Address 1026G TRC Environmental Cons. East Hartford, Connecticut Samples Sent By Date Received Date Reported Analyst TRC Staff 3/15/90 4/4/90 RLK Material Analyzed Waste Water Sample Number Test Results uR/L I I TRC00 TRC01 TRCO2 TRC03 4 ( =jp Bl c Make-C)o TR10-1 DP_l Chlortmethane I 10 U 10 U 10 U 10 U Vinyl Chloride I 10 U 10 u 10 U 10 U Chlorroetbane ( 10 U 10 U 10 U 10 U I 10 U 10 u 10 U 10 U 111-Dichloroethene I 5 U 5 U 5 U 5 U Trichlorofluoraaethane J 5 U 5 U 5 U 5 U Dichloromethane ) 5 U 1 J 1 J 2 J 1,2-Dichloroethene I 5 U 5 U 5 U 5 U 1,1-Dichloroethane I 5 U 5 U 5 U 5 U Chloroform I 5 U 20 5 U 2 J 1,2-Dichloxnethane I 5 U 5 U 5 U 5 U 1,1,1-Jrrichloznet2am I 5 U 5 U 5 U 5 U Carbon Tetrachloride I 5 U 5 U 5 U- 5 U Benzene J 5 U 5 U 5 U 5 U Trichloroethens i 5 U 5 U 5 U 1 J 1 r chl I 5 U 5 U 5 u 5 U I 5U 5U 5U 5 U Trans-1,3-Dichloroprcpene I 5 U 5 U 5 U 5 U Cis-1,3-DidAorcprupene I 5 U 5 U 5 U 5 U 1,1,2- richloroethans I 5 U 5 U 5 u 5 U Dibromoc hlornmethane { 5 U 5 U 5 U 5 U Toluene I 5 U 5 U 5 U 5 U Tetrachloroethene I 5 U 5 U 5 U 2 J Chlornbenzene I 5 U 5 U 5 U 5 U Ethylbenzena I 5 U 5 U 5 U 5 U Brtamoform I 5 U 5 U 15 5 U 1,1,2,2-Tetrachloroethane I 5 U 5 U 5 U 5 U 1,2-Dichlorobenner►e I 5 u 5 U 5 U 5 U 1,4-Dichlorobenzene I 5 U 5 U 5 U 5 U 1,2-Dichlorobenzene I 5 U 5 U 5 U 5 U Acetone I 100 U 100 U 100 U 1460 Carbon Disulfide i 30 5 U 5 U 5 U 2-Butanone I 100 U 100 U 100 U 3240 Vinyl Acetate ( 50 U 50 U 50 U 50 U 4-Methyl-2-Pentarnne I 50 U 50 U 50 U 50 U Styrene I 50 U 5 U 55 U 50 U 55 U Total Xylenes I 5U 5U 5U 5 U 2-O'doroathyl Vinyl Ether ; 10 U 10 U 10 U 10 U Analytical Hgt►g&: ISnecial A?otps- Pr/GC/M for 8240 Compounds JU-Undartected. Value is detection limit for that anpow,d. IJ-Estimated Value. Value is below the I limit. °�° detection i - 1 I UM026G (428) i 5 I APPENDIX B CHEMICAL EMISSION RATE CALCULATIONS TABLE B-1 CHEMICAL EMISSION RATE CALCULATIONS Uncontrolled Air Volume Concentration Flow Rate Emission Rate Chemical Found - Trial No. Mass (pg) Sampled (L) (pg/Q or mg/m3) (m3/sec) (Ng/sec) DRY PAN EXHAUST Dichloromethane 1 0.340 10.01 0.0340 1.93 65.55 2 0.290 10.02 0.0289 1.93 55.86 Acetone 1 7.400 10.01 0.7400 1.93 1,426.77 2 2.300 10.01 0.2298 1.93 443.46 Carbon Disulfide 1 3.150 10.01 0.3147 1.93 60,7.34 2 1.150 10.02 0.1148 1.93 221.51 Benzene 1 0.015 10.01 0.0015 1.93 2.89 2 0.080 10.02 0.0080 1.93 15.41 Chloromethane- 1 0.055 10.01 0.0055 1.93 10.62 FURNACE TR-10 EXHAUST Dichloromethane 1 0.175 10.16 0.0172 12.67 . 218.23 2 0.865 10.00 0.0865 12.67 1,095.95 Acetone 1 52.400 9.99 5.2452 12.67 66,457.26 2 7.200 10.15 0.7094 12.67 8,987.59 Benzene 1 0.090 10.16 0.0089 12.67 112.23 2 0.035 10.00 0.0035 12.67 44.34 Toluene 1 0.060 10.16 0.0059 12.67 74.82 2 0.050 10.00 0.0050 12.67 63.35 Carbon Disulfide 1 0.040 10.16 0.0039 12.67 49.88 2 0.115 10.00 0.0115 12.67 145.70 1,1,1-Trichloroethane 1 0.040 10.16 0.0039 12.67 49.88 APPENDIX C INPUT PARAMETERS FOR THE MASK PROGRAM IN DETERMINING COMPLIANCE WITH STATE HAZARDOUS AIR POLLUTION REGULATIONS a TABLE C-1 THE DRY PAN INPUT PARAMETERS FOR THE MASK PROGRAM Source Identification Dry Pan Source Name Evaporator System Stack Height (m) 24.4 Property Line Distance (m) 100 Volumetric Flow Rate (m3/sec) 1.93 Control Equipment None Control Efficiency (%) 0 Group Trial UER Chemical Name CASa No.b HLVc No. (pg/sec)d Dichloromethane 75-09-2 3 7,000 1 65.55 2 55.86 Acetone 67-64-1 3 11,800 1 1,426.77 2 443.46 Carbon Disulfide 75-15-0 3 60 1 607.34 2 221.51 Benzene 71-43-2 1 150 1 2.89 2 15.41 Chloromethane 74-87-3 3 2,100 1 10.62 a CAS = Chemical Abstract Service Number b Group No. = Toxicity Group Number C HLV = Hazardous Limiting Value d UER = Uncontrolled Emission Rate in micrograms per second, derived f rom measured actual stack concentration. See Appendix B. r ' ` TABLE C-2 THE TR-10 INPUT PARAMETERS FOR THE MASK PROGRAM Source Identification TR-10 Source Name Incinerator Stack Height (m) 24.4 Property Line Distance (m) 100 Volumetric Flow Rate (m3/sec) 12.67 Control Equipment None Control Efficiency (%) 0 Group Trial UER Chemical Name CASa No.b HLVc No. (pg/sec)d Dichloromethane 75-09-2 3 7,000 1 218.23 2 1,095.95 Acetone 67-64-1 3 11,800 1 66,457.26 2 8,987.59 Carbon Disulfide 75-15-0 3 60 1 49.88 2 145.70 Benzene 71-43-2 1 150 1 112.23 2 44.34 Toluene 108-88-3 3 7,500 1 74.82 2 63.35 1,1,1-Trichloroethane 71-55-6 3 38,000 1 49.88 a CAS = Chemical Abstract Service Number b Group No. = Toxicity Group Number C HLV = Hazardous Limiting Value d UER = Uncontrolled Emission Rate in micrograms per second, derived from measured actual stack concentration. See Appendix B. 1 ff #""-W`i"«iY bored through them caused the flats. me Tana near hhenipsit Lake that the trails A search of the'trail Thursday did not turn ,n trash-fee waiver The wood pieces,about 5 inches long,have traverse is owned in part by residents and by the up any more of the traps that Parker saw four nails on one side and two nails on the Connecticut Water Co., said Pozzato and Wil- Saturday,leading him to believe passing hikers The town council may waive a fee opposite side to anchor them in the ground.The liam Dunn, public information director for the or mountain bikers had thrown most of them off .r small-business trash collection side that points upward was painted black and Water company. the trail. ithout approval from the council's covered with leaves,Parker said. The water company, which sells water However, four square pieces of roofing es committee, Corporation Coun- "They put them on the other side of logs so 'from the lake to surrounding towns, does not with nails punched through them were found !I Kevin F.Rennie said Thursday. if we go over them, our tires are forced to hit allow mountain bikes or motorcycles on its near the trail's start. Rennie's comments, and his ac- them,"Parker said. property because of concerns that soil erosion Alan Skinner, a 17-year-old customer at impanying opinion, were made in During Saturday's 1%-hour ride—which or fuel leakage could harm the lake's watershed Cycle Center, said he has found similar traps sponse to a request by Debra M. included three stops to repair or replace tires— area,Dunn said. along an empty railroad bed behind his home. 3udette, a town council member, "we hit three,"he said. "They go right through Although the water company has"No-Tres Skinner said residents probably leave those ho challenged the right of the ordi- and just pop the tube and the tire." passing"signs posted along Ellington Road,it is . traps because motorcyclists make so much tnce committee to waive a fee. Parker and his friends took three of the unclear where the boundaries of water compa- noise running along the railbed right behind At issue is whether small business- spiked objects and gave one.to Cycle Center ny property begin and end. their homes. should pay a $35-a-week fee for Manager Geoff Jones. Jones called state De- In any case, Pozzato and others say, the But the trails near Shenipsit Forest wind unicipal trash collection,or wheth- partment of Environmental Protection officials area has been used without incident for years by away from any residences and into the woods. the fee should be waived. Gau- this week to tell them about the menace. motorcyclists and mountain bikers. "There's not really much you can do about tte supports the fee,saying a waiv- Officials from the department could not be I haven t heard of any objections at all," it,"Parker said."There's so many trails to go to would unfairly subsidize reached for comment Thursday. Pozzato said. "I don't know of any animosity you can just write this one off,which is too bad ,sinesses. among the neighbors there" toward mountain - because it's a pretty good trail." The town council levied the $35 a in January for businesses that nerate as many as eight barrels of ish a week.Businesses generating r w su )re than eight barrels must con ict privately for trash collection. Small-business owners com- • • lined about the fee. In June, the uncil's ordinance committee rec- Town to seek authorityto cite firm for Odor emended that the fee be waived businesses of a as square feet or three By LAURA EASTON , named b the DEP in June as the found that the too had noticed the The company's re ort of April 16 s that generate as many as three Y Y� p p ' rrels of trash a week. Courant Correspondent likely source of an odor that for the odor.He said his wife,Vicky,and the said plant emissions of carbon diox- 3audette, secretary of the fees past three years has been sporadi- couple's 6-year-old daughter had ide and water vapor did not exceed- SOUTH WINDSOR—The town is ` cally plaguing the neighborhood dry,scratchy throats and persistent ed allowable limits,Daniels said. nmittee and a supporter of the sh-collection fee, said the fees ' seeking permission from the state to near Rye and McGrath streets. coughs that summer several years nmittee — not the ordinance cite a metallurgical company sus- Theodor,described as"an acidic, ago. But after the DEP's investigation pected of emitting offensive odors chlorine,sulfer-type smell,"has sub- Neighbors worried that the emis- in June,the company made a second ether t e — should decide on into a neighborhood. sided in the past month, neighbors sions would cause health problems, investigation.It found that one of the ether to waive the fee. g p smokestack burners was 400 de- Town Attorney Richard Ritten- have said. he said.Lennie said the full council may band is reviewing'a resident's sug- George Daniels of Hightower In September 1989,town officials grees cooler than it should have rc the recommendation of a estion that the town been, which meant chemicals from r committee or neither. "It's a g petition the Drive suggested to the town council and residents met with Gary Rose, the stack did not rise as high the tter of policy,"Rennie said,rath- state Department of Enviromental in May that the DEP give the town state air-pollution control engineer. should have. g y ,han law. Protection for authority to take ac- authority to cite the company if the Since then, the DEP has been han- tion against South Windsor Metallur- odor occurs. dling complaints about the odor. Please see more East gical Co. near Farnham Estates if Residents in ;the neighborhood Four months ago, the metallurgi- Daniels said that if the state ,rtford news on the next the offensive odor returns,town offi- ,have complained to state and town cal company hired an East Hartford grants authority to the town, state ge' cials said. officials for years. firm, TRC Environmental Consult- and town officials can work together The metallurgical company was Daniels spoke with neighbors and ing Inc.,to do tests. on the problem. sty sale to raise money to hire director ` Manchester tween Hadley and his wife and Ax+ police news learned that Hadley had drugs there. Members of two squads, the Tri- administrative procedures or do not about other grants for which it has Town Narcotics Task Force, which have the time to devote to the his- applied. ■Three people were arrested on includes officers from Manchester, le lack of volunteers torical society. Also in 1987, the endowment was drug charges after police found co- Vernon and South Windsor, and the I �, , . "There are so manv Programs started and it now has$3,000,seeiety eaine at a home where there had Fast Hartford vice, intelligence and South Windsor H[ Metallurgical, Inc. A Handy&Harman Company 300 Rye Street, South Windsor, CT 06074•Telephone (203)282-0871 March 8, 1990 Mr. C. F.Shaw Assistant Director Public Works / Pollution Control Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Re: Odor Investigation Dear Mr. Shaw: This letter is in response to yours dated February 28, 1990, which was received on Monday, March 5, 1990. With regard to the odor complaint received by you on February 27, we have reviewed our operating records for that date. All process and pollution control equipment was operating correctly, and we know of no conditions which would have caused the odor complaint. It would assist us if such complaints could be transmitted immediately to - us, so that we could more promptly observe operating and meteorological conditions. With regard to the engineering report, we called our consulting engineers, TRC, for the status of the report. Samuel Cha, the chief consulting engineer, advises us that he has completed the underlying engineering studies, and that a report will be forthcoming this month. We will provide you with a copy. Mr. Cha also advises us that the meteorological station which we have asked him to install at the facility is now on site and should be completed soon. Sincerely, In Y Edward Kiser Chief Refining Engineer EK/mef Fabricators of precious metals, special metals and alloys• Refiners of silver, gold and platinum I t�wN Sf, y w r 71au� O- Sou L O O 1540 SULLIVAN AVENUE • SOUTH WINDSOR, CONN. 06074 SOR-CO AREA CODE 203/644-2511 April 17, 1990 Mr. Edward Kish, Chief Refining Engineer South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 RE: ODOR INVESTIGATION Dear Mr. Kish: Please advise the Town as to the status of TRC's final report concerning the alledged odors at the Rye Street facility. In your letter of March 8, 1990, it was indicated that the Town could expect a copy of said report in March, 1990 . Very truly yours, v� C. F. Shaw, Ass't. Director Public Works/Pollution Control CFS:bmr cc: Michael J. Gantick, Director of Public Works Robert Deptula, Environmental Health Officer Barry Wayne, Pres . , So. Windsor Metallurgical M S l rreaeric.B: Clark 1 ne zee issue will be reviewed by a the,Storrs core: Su guns `sInfur sui aao;aq III.Clark said the list of small busi- subcommittee headed by council bike after a cer( aasola Puu.rasola gUzllag S r nesses subject to the charge has Chairman Harry A. Egazarian, and -Palo, alels ,fyq,� •plus �a grown since the town started the fee. any changes would go to the town The $19,000 l -read 2uro2uo ue sr luaw He said he wants to know what crate- council for a vote. Egazarian could --soot;rpuoa magi of is ria are being used to determine who not be reached for comment. ..-, IL1►aos ui as zaaq p slaaaseui a must pay the fee. Courant Staff Writer Darr Haar con ;.► tatE sued a Clark said he believes small busi- tribrrted to this story. 1 , q `'�gotoga6sd uz gut =` nesses are being charged unneces- f sarily for small amounts of trash. East Hartford aiglssaaae aaoui '. PI of paluum a uz aid >-"If you have a small business a o igs an wog aH leg]uuq;aao zng taxes to the town for the property D nl�tln and the equipment in the business, _ }path to e. and he has one ba&f trash)a week TON'"Hall,Tao Main St.,289-2781.All how can you charge im$35 for that o hetrw se will held in town hall unless . ,*a dL�q,� one bag?"Clark asked. eommun� But Councilwoman Debra M Gau_ Public meetings this week• Today:Recycling task force,7 p.m,; By JOHN Bette said she favors retaining the inland wetlands commission,7:36 P. Courant { fee. , ''��� • • Wednesda . Wei is Pauusld s� a>tiq�a We should maybe make it less, '.commission public Planning 7 and m Zoning . MANCHESTEI ius�rlaJ at1J,of Iei� - s/ueuoA sw� work of bicycle tr • - q � its sporadic groh +for another sec state budget crun � '� � ' ;The state's buc fig* e�Z =,,:fit' a {': i"�'Y •:�:# �, - � n � Rjafit ,jt trans$750,000 to 'trail f not sou Mancheser Cor,Ce of odor , 'Plans call for :tt ,consultan ' r �� ,eventually to Char Cowntown. v �-�- a< y ,� <:`�r'" ;.� ✓ 1 ;State Sen.'Mict ". r1� : ;Glastonbury,chair By LISA RICHARDSON 't, i`sions were based on investigation m` Sri Assembly's tra � Courairt Staff Writer �r,the neighborhoods, -a les taken �mittee which bacl- VA. the plant's stacks and mathe bike trails benefit f � -SOUTH WINDSOR . A Rye is matical models of samples carried :horseback riders a Street company has filed a study_i4ownwind, :according to a letter jwheelchairs,in ad, With the state Department of Envi- from plant officials. . '.:.; ; -If approved, tr -� ronmental Protection saying that al `' ' `TRC did find, as the CDEP had would expand the though the plant does emit a mild . before,that some faint and unobjec :was outlined nearl• x. odor, it is not the source of an un- pleasant tionable odors are emitted by the ':by William D. O'14 pleasant smell plaguing the area ''Plant on some occasions,"the letter IFuss & O'Neill, a Residents have.complained fore Sys ' '�° ma's. } :�t ..s neerin consulting' `� Residents of Farnham 'Tn 1972,'O'Neill, years to'state and local officials ,'have said that on"weekday`after- works director,hei About the odor,but because it occurs ' intermittently, the source has been nouns they sometimes smell an odor .work of trails that difficult to pin down. : a Y,similar to chlorine. 1communities east "This ,-was to be one complete TRC Environmental Consultants cabling bicyclists ar,study, but because of the findings recommended that plant officials "'.without competini x which did not conclusively deter' ;continue testing to determine the ;trucks. �k � 4 -'.mine the"source of the odor, there specific chemical process that may "; :O'Neill said he w } f,will be a..second part to it Town be the source of the odor The com jtimistic about the in f - Manager Jean E.Zurbr>gen said Fri pany has said it will in the.state budget day..-bz > . . L t. g t # • , F-�� . i trails. y -In December,a state air pollution` South Windsor i'. "It's an idea the control engineer said South Windsor D !!11l�tin time coming,"-he s:Metallurgical Inc.emits acidic as O �zs an o a�g g pportunity to c es in the processes it uses to isolate �.• � 14: ,, __ ,investment_that`w: v s and recover precious metals from °'"na tt540 Sullivan Ave:; _ lexisting.trails.This i. circuit boards.State officials did not 2511. All meetings are held in town hall -ja good idea." r ±, l say then that the company was caul un ess otherwise noted In the odor i .; ' "y j,INhile the project Pubbc meetings this week 2 dsu • Today:,Veterans of Forei PPorters, money t S � g South Windsor.Me and `6.3o p.m.town council,7:30 p.m.;inla d `agshortsupply. 0 1pl fundted� :the DEP agreed that the company y would retain TRC Environmental Wetlands agency,7:30 p.m. Consulting, a private firm, to seek Vf mission,8 p.m. Recreation Director .• Tuesday: Planning and zoning com The ;trails most];, r the source of the odor. , a :.`backed on a ro ria.: . The study's Preliminaryeonclu- --commission,' Wednesday: Economic development PP P a p.m. p development project: 8 0661 'Cr,p�dV 'S(opuory 'IN ` Portions of the tra - 3_ [ y P OKI N G =, srs Townls )- Ad vert�st� i- z.' R J `~1. s�o. f .:.;.' •� - - Y`••... J ii The Journal inquirer M eta I f r mpar,t�a I ly- a drig Is 646-7767 k � a res onsib� I � loroddrs'5:7 -in SW ` f _ p _ Y ..DEP didn't name the 300 Rye St Rennie said today that TRC's ;-plant as the source, findin s substantiate complaints b ` By ANDREW NELSON P - g P Y Journal Inquirer Staff Witter `- The ery, meanwhile,"plans the neighbors,who claim the odor refin to'use the:firm that conducted tests has ;wafted _--through their; k SOUTH WINDSOR =.A ye =this winter,, TRC 'Environmental neighborhood periodically and an Street metal -refinery confirmed Consultants Inc.of East Hartford, differing concentrations for three suspicions of neighbors and find ;`to pinpoint the source.It:called the •years,mostly during workhours on ings of a 'state investigation by :report issued to the town Thursday weekdays 'admittin Thursday that its stacks �:an u dateon the ongoing testin . Y.. g Y p g g g Obviously, t seems that ' occasionally emit odors Into the ,In a letter to the town Thursday; something is there, `so residents ., area ,; , , ., a-refinery Manager Richard A. K ,il-have a Valid.mdomplaint,'-be said. s B u t t," South Windsor tier stated that TRC found . .no a will continue to pursuetlus to Metallurgical Inc:;long`suspected objectionable odors in the area of i s -thay to_Ionger have. eom- of producing'a chlorine odor.that,the plant or nearby neighborhoods „ 7 r . has wafted through the nearby (and)found no stack emission fromyplm°� r -Farnham Estates,called the odors any plant .:process ;which if tRennie, ho ,grew pup min, detected. during an environmental predicted would be objectionable�iFarnham Estates, added'that he study this winter"faint and unob- those neighborhoods." �,•i .A; continue to v�+ork with the DEP . Kettler said the refine made its to resolve"this nagging problem" Iectionable s ' - rY . , 'you and your child a ,;The investigation fast fall by the its determinations based on sampl- ,Neighbors complaints 'of the . We begin with a test ADepartment r of'Environmental `mp that TRC.took of air in.the odor have curtailed significantly s,their'develop a ,'._Protection;�equested by 'Rep`.Farnham'Estates rind'nearby area since;TRC startedtesti`ng n As of individual atten 'Kevin . F.- Rennie, R-South and from the stacks at the refinery. ,tea, - I r # r s���tugf Windsor;linked what it also called `-,The burned circuit boards emit , rTown £Manager dean ►a daring, •g = •� g unob'ectionable odors_in.the area trace amounts of chlorine,iodine Zurbn en;who called the"odors a learning skills and ; - iple of hours a week at _ .to burned computer circuit boards. .and brdmine into the area; the t source of concern and distress ;port cards a But even. though t ;DEP ,concluded during its :fall ' or local residents,"and other town _ I tiacknowledged .,that, the refnery investigation,adding that since the officials Ws., with the :-refinery ( t, �u _burns computer;boards as-part of _chemicals are in such low levels the officials late last year tQ dis�}iss the. I Ivan Learning Center° its Precious-metal refining, the refinery needs no permit n r' p Y ' coin Taints .x 1 4 �cz L l i S .•� iR.fi elping kids dobetcer �� n rs t� -4.� Y } Parents to dear childhood expert �� k s. s "j'.•+Sa�i34 ,. • WINDSOR 'fhe director of °parents that they can use to-better'-Early ChildhoodCentar.since the University"ofHartford Early iuiderstand their chidren and to She earned her doctorate,master's , .LS 'SIC 00L`READFNESS .Childhood Center"will speak to"the help"them deveIop." j � - > 'and. "bachelor's degree ant the " 3RA•;BEGINNING READING ;g arents of incoming Windsor ' pp 8 Among the undergraduate and University of Kansas � i�. 3 kindergartners May 3 from 71b 8 graduate-level .courses Miller Recenay,`-Miller was Knamed" �< ap.m in the auditorium"of the L.F caches"are: early childhood cur ��sdirector ;of Project 1;HEL P, a «i� Pry Wilson Center 4 on 7Vlatianuckculum,'educational environment rpartneiship_of--the Hartford'Public �< Avenue �:�s � , infants and toddlers, working Schools,the University of Hartford . �� Regina Miller will talk to parents 'with, Hof exceptional and the:Traveler's insurance Co: ' about preparing their children"for , children,`current models in da Pro ect IELP_is --workin t' ,kindergarten. 'She pP especially are and guiding young child improve -kindergarten-=mci lum a n interested in =the a lication of . < ry ,sand teacher-trainin in'Hartford. Y `t -educational theory to practical learning g situations and stresses ,that -'Miller has .written 'extensively "Parents must be.active partners , • 'approach in her.cla§ses.` and belongs 'to several organiza- in"their children's education,"- Carol 'MacMullen," assistant tions _including the National MacMullen said. "This talk "superintendent-for `instruction, `Assocation.for the-'Education of represents an opportunity for our said,"Dr. Miller is an outstanding Young Children and the American parents to become full and well- ' E, educator, well-recognized in her .Psychological Association 11' informed partners in the educa- �� field. She'll have much to tell ,<;She ,has been director of the tional process." - � g� �b': ✓z .Y�k � � ir.: r Earth Dv a isn't limited to public events _. _ day's activities at Nevers Road Chairman Betty Warren. By ANDREW NELSON Park,according to a town official. The .town-sponsored Lactivities Journal Inquirer staff water `''`4' They can pick up trash along begin at noon with the raising of roadsides.plant trees and bushes or the Earth Dav flag and addresses lk �H 19; 1990ew��or+scars,►•�:•s'�•w'watetlacatatrinuasuaxrt�•A:��•s't.+7ekrtea��.cuL�Y�'�s'�.�'f.�t:i%aittats:an'r�:era'�a:r'exw�r.r.�i.sx���s..►wr•«.w��i......«...-.-.. TOWNS Sale Y Odor report expected soon ,- , h a tail s ies for Your new pet. odor to residue from circuit boards at the refinery and measuring air By ANDREW NELSON burned at the refinery. quality in the area. Journal inquirer staff writer _ ' >Neighbors of the refinery have Despite its connection.between SOUTH WINDSOR — AJ complained of the odor for three the odor and the burned circuit !� report ordered by the state to years and decided last fall to con- boards,the DEP has said it has yet e`►. determine a Rye Street metal tact the town. to determine what it deemed an refinery is the source of a chlorine -' Soon after, Rep. Kevin F. Ren- objectionable odor in the area. odor detected in the area for three me, R-South Windsor, asked the I The residents, meanwhile, years should be completed in two DEP to look into the complaints. - speculate that the source of the weeks, according to Carl Pavetto, Reached Friday, `thg legislator odor has likely curtailed its opera- ;" chiof .of the Air Management said he looks forward to the report. tion in light of recent publicity. Bureau of the state Department of "We`re getting closer to a solu- The refinery does not need a Environmental Protection. ` non,._said Rennie,who grew up in permit to bum the circuit boards J� " -The report will come.from TRC the area. "Just getting some solid from which it_salvages precious Environmental Consultants Inc.,; .inforatation is a step forward. ., ;,petal .because -the resulting - -the East Hartford firm hired by the � he refinery maintains that it's emissions contains low levels of refinery, ;..South Windsor ;'not the source, but agreed to hire 'chlorine,iodine and bromine. r '=Metallurgical Inc., four months 'TRC after meeting with the town ,Town :Manager Jean 'E. ago to monitor the stacks at 300 and state � ' . Zurbrigen has called the odor a • Rye St. �.;The tests` include sampling "source of great concern and dis The DEP already has linked the emmissions from the smoke stacks tress for local residents" fit'•. :.j i F R ��zi�"o�p< x },. 2.e _ _ ~_ 1 NR MMH `�rant r e a e increase `\` \ "I&Q agreed to accept a123 percent Rockville'General Hospital in By EILEEN McNAMARA 'L' n increase 1 = a a:r ;�4:==r G ;Vernon also recently negotiated, Journal Inquirer Staff Writer 4 h� :;' Under >Ehe ;settlement the new rates with the commission that -- "`hospital's ,budget is set at $90.8 would allow the hospital to '_�''-MANCHESTER - 'State million, ,rou y Sl million less ` re u l a t o r s have ranted increase charges by 13 percent this .�. B g than originally.proposed }year. 1,1990 Manchester Memorial Hospital a Hospital spokesman Andrew A. Originally RGH had sought to '12.3 percent rate increase for this Beck :today said ,:.hospital g� y percent,w Meriden uare year, but the rate hike still is 1.1 'administrators aren t sun how the increase its char b 26 percent less than what MMH one of the highest hospital rate Lewis Ave.&Chamberlain H pe reduced rate order issued by the Meriden,Cr 064so administrators had sought. jcommission will affect hospital increase requests ill.the state, but s03 634 7900 � Manchester Memorial on 'nall services Y - � under an agreement with regulators 81 y _° `: "� <-` _ RGH administrators accepted a had asked fora 1.3.3 percent rate ; 'We are somehow going to try to increase for fiscal 1989-90 that live with this, Beck said. lower rate in return for increases it would have allowed the hospital to "Obviously:we"felt we needed the as granted in the thousands of -,-.-_increase its budget to$91.7 million. whole amount.But we are agroeing Individual services the hospital But the state's Commission on .with the settlement and are accept- offers.` �^°� t , -1.gh �- I Hospital's and Health Care,which 'ing the commission's decision." Hartford Hospital, which makes sets rates for Connecticut's 34 "'The ;rate order comes five more money than 'virtually any nensions! , acute-care hospitals, said MMH months into the hospital's new fis- 'other hospital in Connecticut, had could increase its charges only by -cal.year.State regulators,criticized sought a 35 percent rate hike only 11.1 percent. :: �.y_ by hospitals for moving too slowly to have the request cut to 14 per Manchester Memorial officials ;on the 1989-90 hospital rates, still cant by the hospital commission �u've failed at your appealed the decision and is a are pondering the budget requests Hartford Hospital is appealing recent settlement with the state of four other hospitals in the state. the decision. y tht loss attempts in the -. It's only because you '. not on a diet geared EH mu. " rder sus pect faces Tenn. ,trial :ifically towards.your 3bollsm and Individual ent needs. It did not 56, of East Hartford in Springfield after the burned i Into account .your By Journal Inquirer State - Springfield, authorities said Fri- remains of his car had been dis- Vie,your favorite foods, .Drifter David Allen Brimmer day. - - - covered earlier several miles teach you how to will not be returned to New But Brimmer has been charged away. ibine foods in the with first-degree murder in the A spokesman for the Hampden East Hart nal metabolic fuel mix. England rt ford man until he is the strangulation of an October strangulation 1� �'�lation of special- County, Mass.,district attorney's - also lacked the strong tried in another murder in Ten- education teacher Rodney Com- office could not be reached today vntinnni eiinnnrt vn,i .,-.,,,o- ,,,,.t,,.:. ;,, ,w,,. �+,+. nton in Loudon Countv. Tenn., to learn. Maccachusetts the issue would have to wait The mayor wouldn't speculate survival." to respond. til next year's budget considera on whether she thought Howell Police union President Michael ■Conversion to semiautomati ns. would change his mind about Fowich today agreed with the com- would standardize weapons an Cniep said she will discuss the semiautomatic weapons,after read- mittee's morale assessment. He ammunition used by the patrol all nmittee's report .with Howell ing the committee's report. The said only two officers in the 120- detective divisions. =z. en he returns from New York, .chief has-the final.say on the com- member union voted against adopt- ■ Semiautomatic pistols offer ere he has been taking computer mittee4r,findings. ing semiautomatic weapons. safety features not available with wit `' - Howell has indicated he would Fowich also said that Kniep's revolvers. go along with a recommendation suggestion of using the .officers' ■Semiautomatic handguns have F• by the town to adopt the weapons, clothing allowance to purchase a greater ammunition capacity, t n if additional monies beyond his semiautomatic pistols "certainly is reload faster, and are more com - department department budget were allocated. a possibility, abut it hasn't been pact and concealable than The committee of residents and discussed. revolvers. --police officers was established by' ,.The union brought the clothing ■ Reliability and maintainabili- 't+, Howell last summer and said 'in allowance issue into early contract . ty of 9mm. semiautomatics is September it,would. recommend 'negotiations last spring, but the superior to revolvers and the semiautomatic handguns for patrol town rejected it, Fowich noted. weapons wear better. officers. Fowich said using the clothing \E Semiautomatic weapons are o ts e Howell,who has said he is open- allowance would be "better than about 40 percent -more accurate minded, remained unconvinced by nothing" :and added that many than revolvers. the committee's reasons for moving officers have already used up their ■ A semiautomatic pistol will :to increased firepower.He said last allowance for this fiscal year.• cost, on average, $400, as opposed month that the group had confined :Other.:co- nclusions of the to $200 for a'revolver without the great^year. its studies to "obvious" areas and semiautomatic weapons committee features of a semiautomatic A and.. _�� ,Patti,Carol Ann, � � TRC re N ort due in �J anua . o n odor Aston,Chris&Joan p_ _ >. r A- . . M . refinery. "��• - :quality in the .area; according to r�aCfl�lrlT ?: :. � �'> REW NELSON , Already,the state has said that a TRC engineer Robert Tyler. . �By AND w through hlorine sme ll that wafted th o .::.0 Ipr<' >' - •': ourn•l Inquirer staff writer 1 g � Also, TRC will obtain weather ' the area one day two weeks ago Y g information to determine if winds { SOUTH WINDSOR — 'The came from burned circuit boards at blew from the precious-metal 3tdx,Paul Mitchell and Redken environmental firm .testing 'the refinery.That odor was similar refinery toward a nearby Stocking Stulfers► s,• emissions from South Windsor _.to the smell that nearby Farnham neighborhood during 'those days Metallurgical Inc. plans to reveal Estates residents have complained op&Shop Plaza when `complaints were lodged, early next month if the precious- -of for three years, but the DEP nue, Enfield •745-3015 Tyler said adding that he expects .metal refinery is producing a wouldn't link the two odors. " mysterious odor in this corner of L,,The refinery maintains that it's .to submit a'report to the refinery > r n the second week in v>: :> :::::::::::' town. t .-.not the source, but agreed to hire no late than�> k ''"" TRC Environmental Consul n -TRC after meeting with the town January WAY TABLEt tants Inc of East Hartford will and state. C h s c o n d u c,,TR a ted ...::. •make its determination at the con __ The tests include, sampling environmental tests at some I00 elusion of_a series of tests it began emissions from the smoke stacks at 'industries in the area to the past 10 } this week at the 300 Rye St. the refinery and measuring air .years,according to Tyler. <`>> ALL UPPERDECK SPECIALS INS TOCKs*tals exp.` 2-17-89 s• Football Sets 79 To Present Basketball Sets 73 To Present `Hockey Sets 68 To Present Baseball Sets 78 To Present ,.f Hoops Basketball In Stock :ALL Pro Set 1n Stock .<..; o. ` COINS STAMPS & SUPPLIES IN STOCK l ayawayf:F°r xmas ;i 1989 Upperdeck 1989 Upperdeck _1989 1989 ore . 1989 Seer1989 1989 Factory Set Update Set Topps Set Idaster Sets ' Basketball Sets Hoops Set Hockey Set : f,._ ; $ =1275 =12 s27 $22 1989 Score 1989 Donruss 1989 Floor 1989 Topps 1987 Topps 1987 Seer 1989 Score t< is Update Update . Update ::Update Set Factory Set Football Set s17 ==25 $18 $12 - ::25 :80 =16 1987 Topps _ Binder ._ Autograph 20%OFF 1984.85 Topps 1986 Donruss 1989 { Wax Box +50 Pages Photos&Balls All Hockey Set Rookie Set Score Set :ate s32 $12 10% OFF Comics .. : _ $21 $44 $1 g :. ier-•y 0 - _ 435 Hartford Tnpk. ktE ^non• 872-0547 G .�{ County Road ` :ks.CT 627-8665 • • • • • • • • _ o �y� Handy&Harman Precious Metal Refining Division:300 Rye Street,South Windsor,CT 06074 Telephone:(203)282-0003•Fax:(203)282-7461 July 26, 1989 Mr. Fred Shaw . Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Mr. Shaw: This letter will confirm our discussion of Thursday, July 20, 1989 concerning the odor complaint received by your office earlier in the week. We do not believe that we were the source of the odor in question. We know of no incident that would have caused an odor outside of our facilities. As discussed, we did experience a mechanical malfunction in one of our processing units on Tuesday afternoon, July 18, 1989. The equipment was immediately shutdown in preparation for repair. During this time all pollution control equipment operated normally. Late in the afternoon after the equipment had cooled, an inspection plate was opened in order to begin repairs. It is possible that this caused a faint residual odor to be released within our building. We do not believe the odor escaped our building; however, we do concede. it is possible. In the future, should any similar situation arise, we will contact your office immediately. Should you have any questions, please don't hesitate to call. Sincerely, Edward Kish Chief Refining Engineer EK/mef r r abric6tors of precious metals,special metals and 6lfoys Refiners of sitver;`gold and platlrx�r t`grcup irietC�is � �' :)n, according to Sen. disabled to school. Hospital in Vernon. The program, mem more cost-eriective, ne said. Meotti, co-chairman of "In Governor,.Weicker's budget, which serves people living as far Initially, it would require the �rtation Committee. road-construction clearly won out away as Enfield, .was ;originally Department of Transportation to Glastonbury,said that over special transportation needs," slated to receive$55,000 next year- coordinate all state-provided ;er's:budget would use, the senator said.,;., The governor wants to elm_ mate all special _transportation 1 as , `de- r-gallon increase in the .But he said he doubted Weicker of.ahe funding _`.., tion projects in at least two monstra ive towns and cities an' did that on purpose IVleotti contends that funding of of the state's regional transit'dis- '� I,can't believe he'd consciously special transportation is 4+ulnerable, tricts. By next Feb. 1, 'the DOT decide,_Lets s fix 50 bridges rather because�itj zts .distributed 'among would have p ;report on its • ! than :.transport.;50 people..",for several agencies.aroughout 'the progress toward making'the "re-' dialysis treatment.". budges`,That scattering also en- organization statewide ast HartfordPA�.cn eckin ::out , com an • •�-Deluxe " s:� g -comp an y ft iKi. Cloth in ,000 poyp s of airy•.of pounds inf198? Itul. , % WBSh By KEVIN MAYHOOD �30""ch micals that''regdire €ederal rMetallurgicat officials did,noire- nnt�coupon �Journa!lnquirer,Staff Writer �. = reporting in its `metals ;recovery turn phone.calls today to eomment t rY procsses �J Reg Y r xs x-( ;, � he EPA„ eetton SOUTH WINDSOR' The "- {y After leadly>>poisonous gas '1'liose xcompanigs l that exceed Y ti Offer expires 28 t� UµS Environmental Protection leak from a Union Carbide pi the threshold of reporting limits - ,Agency wwas inspecting :South =Bhopal,1ndta in�1984, theafederat are.;�upposed to file a Iist of toxic VVfndsor=Metallurggcal.Inc• today °government adopted.the;Emergen chemicalsused and zeleased into Ito end out if the2ye Street metals cy Planning and<:Comitiunity:Right the"environment with the'EPA in ' �} refineryhasomplied ,v✓ith to KtiowAct,avhich notifies acoin - t e g q Washington and with the state emissions Fe rt�n re uirements Friunttynil.its emergency`medical : DEP. t ••_ during the last three years,an EPA personnelkof the-ieheniicaIs. used The state however",lacks an 1 .official in Boston said ss 'and released by local businesses.:r � Y _. ;IVletallurgical,whichrecentlXwas �". Ivietallurgica[ recovers ; recious enforcement authority and t A kited ;and fined.by the'.Occupa- -rnetals t-froom 6omputer and in therefore called tn`'EPA �r tional.;Safety 3,and -Heilth Ad- -dustrial equipment and toxic Clam ManniW£`said f. any"violations .- , >: ministration for exposing workers enable,.'and ,,poisonous us, industrial ar`e found? it takes a few months, to,`excessive revels of airborne_lead wastes and byproducts.,.,. at east, lefore `any'Yenforcement and;copper, re'ported ji.nIiting-a .+;;Although i-reporting,;require action is taken" smaIl.amount of copper into the air .me'nts .have.become.stricter_since 'f ri the meantime'; DEP is`conti- in =1987. But it.has not re orted -1987 :l`;the:;coin an Y' ' p p y,..:may ,_have �nuing to investigate Metallurgical. t emissions since _ t " dropped- below,,tlie threshold for Residents,of Farnham.Estates,who The EPA has been called�in by reporting" since filing ;its:report :live less.than a half mile from`the the state Department' of En :.that year,:Marinilli said'.,. plant, have blamed the`company - i i vironmental Prote'ction,which is in .—She--•explained—that, •-when .for.a..chtorine4ike'_odor'ahat _has t vestigating the company'in`light of Metallurgical -.-reported.,a 1987 occasionally pervaded " their ` '.the"OSHA'findings to,find out if emission'of a.,small;airiount of 'neighborhood�`fori the Mast five a t airborne toxins may have escaped copper, companieswere`�iequired years , from the plant. ': to'reporiIt-ee[easeofoxms of ¢ 'The DEP cited the company for We are inspecting Today the' more that 75,000 pounds of any an`odor Yiolation'in December. L= Y< coin an s. mvento rocessin chemtca[were�used manufactur} The town, Warting i ofi farmer t.,.. P Y_.g a rya P� g g g, . ',. � `4z �_ . ,. and usa a ,'records Linda m or rocessin weather, is'4planning o=test the - M'iinilii, EPA enforcement ::-the eight limit ; fnggers�round surrounding the'i aqt and ' coordinator m Boston said�> = toxic re ease reporting was reduced,}in Farnham estates to find out if j. 's ";EPA is'reviewin records to find to.1 50,000� urids a ear: 88. Metallur scat ma` Have" eleased id weather out If the company annually used and re u d further, 0 25,O00 kpollutants outside tWh he der a - m � Students rase oneyfor �r11 e ��ct�ms [ r r a R i}�S' i` ?$" ya��r' r Yeah :,v-E 4 wR:..�i -: Y : , Y' find new housmg, Enckson$aidra cause of the blaze that struck herbox By Journal Inquirer Staff- Donrhons will;becce7. pted at +hen no one was home No one r the„school she added ` was-hurt. " ,t-EAST HARTFORD As fire O&left�eight,ieop a home he' 65-year old house a was marshals seek the`source of the fire less and destroyed most of ltieir owned by Todd and Tune Bisson- ly • 05 that destr oyed a'three-family house ossessions°�'p _ �,.: nette of Marlborough, who:have on the cornea"of South Prospect °,Fire 'I�Iarshal Richard-Metcalf spent the past seven years;fixing it rt` _and ,Chapel streets;Tuesday, stu was at the scene today "searching .up. < . - -dents and teachers at the Silver - ` : . Lane Elementary School are rais Proposed, ordinance alarms residents fng money for one of the'three ` families that lived there. SOUTH WINDSOR The the`regstratton," Edward,Argo of ' The school have raised $1;000 Tdwn Council is'reconsidering its Andmar Lane.told the council this for:Joyce Sullivan_ and her children, proposed ordinanance`--to`require week. "I know you need money. Eric and Leigha,"who lived on the registration of home alarm systems ..But my .God, $100 for":a ho 2. first floor of the 108-110 Chapel' after residents said the $100 re- ;meonwer who is trying to protect St. according to'principal of the .gistrati ri fee would penalize peo- himself school,' Paula `Erickson: And the 1'p1e trying`ao protect-;their homes r` _ • from burglaries and fire. Argo said he has no objection to` school gave Leigha a surprise party r n for her sixth birthday Wednesday., The town after finding that 12 fining ,those who have excessive ``It was tou h" Erickson said r.. p g false alarms Y ' a ter one. } ' S percent of. olice cads`are to false r- Town.Mana "waking up m a hotel on your alarms, has proposed id fine those b get`Jean Zurbrlg; ` birthday. whose alarm cries wolf more than explained., he registration, 'h surprise party at" 11 a.m. five times: N would be required every^ Metal compan' ya' grees to con?pY p1 with ollution rule' By Marc Silvestrini agencies in a series of cases dating Windsor Metallurgical to seek and was subsequently ordered by the company," Blumenthal said. Ql back to. 1991. _ obtain permits for activities relating DEP to produce a plan to reduce only will Handy & Harman imps Journal Inquirer I 7Fa., In addition to signing, the com-" to' emissions and wastes at its emissions. It was also cited for 22 ment a rigorous program to moni, SOUTH WINDSOR =` The pliance agreement, the firm has. precious metals reclamation plant, violations of the federal Occupa- and comply with Connecticut lav parent company of a local metal agreed to pay the state $250,000 - located at 300 Rye St.` tional Safety and Health Act and but the state will gain access processing firm has signed an which will be used to benefit en`c"' The",local-subsidiary processes forced to pay $7,000 in fines. important information necessar% agreement with Attorney General vironmental projects,`'Blumenthal.-and recycles various,,metal wastes Three years later, in April 1994, understand what kind of wastes Richard Blumenthal and state En-' said. Specifically, the:money:will: that contain traces of precious the company agreed to pay a being handled at the facilities." vironmental Protection Com= go toward`enhancing state parks';`• metals, ` including gold, .silver, $29,835 penalty after being cited Holbrook added that he p , l It willroalso Jun Islas nd1 la�num�ess for releasing'and. by the U.S. Environmental federal pleased with the agreement and I' missioner Sidney J. Holbrook to helping p g p po ensure compliance with.. en- '.Sound. 1:': p g tion Agency for violating. federal �. >:t • ' public benefits it will produce. vironmental laws. _vironmental, programs reclaiming•the,precious metals m=,,requirements on reporting chemical. ,� The agreement between the state schools;across thestate .. eludes exposing the waste metal to:.-.emissions." i Handy & Harman is now and Waterbury-based Handy""&4° " `The' agreement is.'�one of_the' high"temperatures, an eodvity that":i The South Windsor plant is one dered A'to take the necess,l Harman — the parent company of, largest ever struck in advance of prod emissions.-�The coi•'t of `two?'operated in the state by measures to address shortcomin; South Windsor Metallurgical' Inc. formal environmental enforcement sent"0=rkur s;:'tbe.company to' Handy."& `Harman. ' The other, in their management of wastes," I — outlines specific steps the com- action by the state-Department of test its en'issrons'-' d to_take ap-i which rs also subject to the terms of said. They must also take steps pany has agreed to take in the Environmental Protection or a.re- propriate ':steps'".to''ensure thati, the agreement, is located in Fair- improve their efforts within handling of wastes and materials ferral to the:attorney 'general'for nothing harmful is released into the.' field. '" permitting process for air and wa that contribute to air pollution, court action,'according tv`a state atmosphere.';,x r' "This agreement will bring these emissions. These efforts will wo, Blumenthal announced today.' ment prepared'by. .Blumenthal's of The company admitted exposing; facilities up to the standard necess- to prevent releases that are harmf The plant has been cited by the fice. `rt a employees to high levels of air ary to ensure that no environmental to both human health and the c federal and state environmental I consent order requues South porn lead and copper in 1991 and damage is being caused by thin viron rent. ' IT'S BLUEBERRY AND RASPBERRY TIME! t. a ` PICK YOUR . O,WN _.11 GOING ON r DZEN BLUEBERRY HILL V"A C"A T I O N Barber Hill Road, ;South Windsor: Order a Vacation Pak and we'll Mon.-Fri., 8 a.m.-Noon • 4 Am.-8 Am. •-Sat. Sun.,'8 a.m.!-Noon ' deliver your newspapers on your return. Wholesale Blueberries Avai/able'- 644996 - Bones Just Follow These Directions- We'II put your name into a special VacPak drawing for a From Windsor t.ocks East Winds, cruise for 2 to the Bahamas to be drawn on Sept. 9, 1996. JExit 44 From tla / EIIMgtngton m `9 3 Bonus! We'll extend the length of your subscription one day for DZEN STRAW ERR BLUEBERRY every day that you're gone. (min. 1 week, max. 4 weeks.) N HILL# llt., "ILL TREE *DZEN. onus! ' y FARM RASPBERRY* HILL ! We'll enter your carrier's name in a separate drawing for a fabulous bicycle! 9 In Wind r To order vour V6cPn1t_ and tnke �rt1 Han dy& Harman Fairfield Plant:1770 Kings Highway,P.O.Box 610,Fairfield,CT 06430•Telephone:(203)259-8321 November 22, 1989 Mr. C. F. Shaw Assistant Director Public Works/Pollution Control Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074- Re: Odor Complaints Dear Mr. Shaw: This letter is in response to yours of November 13, 1989 addressed to Ed Kish, and confirming our meeting of November 17. South Windsor Metallurgical Company has investigated its operations on November 13, 1989 and October 16, 1989, and has found no circumstances which would have caused an objectionable odor. All furnaces and pollution control equipment were operating properly, and there were no objectionable odors at the plant. Our pollution control system_ is very extensive, and is intended to neutralize and capture virtually all potential contaminant emissions. Burning is . conducted in dual chamber furnaces at high temperature to assure maximum hydrocarbon combustion. Acid emissions are captured and neutralized in caustic scrubbers, and particulate matter is collected in baghouses. All equipment was subject to review by the Connecticut Department of Environmental Protection prior to installation and operation. Gary Rose of the CDEP has recently reviewed CDEP files regarding our system, and has confirmed to me that it should, if operating correctly, prevent objectionable odor-causing emissions. We constantly monitor our equipment to ensure that it is operating correctly, because our business depends upon efficient operation and collection of residual material. Material-s collected in our system, including those collected in scrubbers and baghouses, are profitably sold to other companies, and South Windsor Metallurgical therefore has no incentive to operate when Pollution control is ineffective or �Eo` bypass the system. Mr. Rose and other CDEP personnel have made numerous visits to South Windsor Metallurgical in 1988 and 1989 in response to odor complaints to the north and north-northeast of the plant. CDEP files indicate that no objectionable odor arising from the plant has ever been detected. Thus both CDEP evaluation of plant equipment and operations and on-site CDEP investigations have Fabricators of precious metals,special metals and alloys•Refiners of silver,gold,and platinum Executive and General Offices:850 Third Avenue•New York,NY 10022 Mr. C. F. Shaw November 22, 1989 Page 2 indicated that South Windsor Metallurgical is not the source of the complained-of odors. We are nevertheless undertaking further investigation. We have employed a consulting engineer to perform the following steps: 1) Survey odors in and around the plant and surrounding areas, including the area where odor complaints have arisen. 2) Capture and analyze plant emissions to detect objectionable odors, if any. 3) Install a permanent wind direction and velocity meter, with continuous recording. This investigation should be undertaken during December, and we will report its results to you. We understand that odor complaints, if any, will be made to you or to Mr. Deptula. We would appreciate your providing South Windsor Metallurgical with information regarding such complaints, in as timely a manner as possible, so that we may appropriately coordinate them into our investigation. Please call me if. you have any questions. jv y trul yours, n C. Bullock ironmental Counsel cc: Gary Rose Barry Wayne Rick Kettler George Ekern �tOWM Sf�<� - e r Tiov O-P Bain V&zd4ot c � � U . : , � 1540 SULLIVAN AVENUE • SOUTH WINDSOR, CONN. 06074 'IOSOR,co� AREA CODE 203/644-2511 November 21 , 1989 Mr . Barry Wayne, President South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 Dear Mr . Wayne: As follow—up to our meeting of Friday, November 17, 1989 , attended by yourself, Mr . Kish, Mr . Kettler , and Mr . Bullock from South Windsor Metallurgical , and the Town' s Environmental Health Officer Mr. Deptula and myself--we were pleased to learn that .South Windsor Metallurgical has taken the initiative and will soon ( 11/21/89) be signing a contract with TRC--Environmental Consultants, Inc. . The purpose of this study, as I understand it, will be to review manufacturing processes, and the operation of existing pollution control equipment, and to perform tests of stack emissions in order to affirm the safety of area residents, and that there are no nuisance odors associated with the operation of the facility. I encourage South Windsor Metallurgical to work closely with the State DEP in resolution of this matter. Please copy the Town on all correspondence concerning this subject. The Town shall continue to work closely with South Windsor Metallurgical , and will promptly report any area odor complaints received at the Town Hall. Very truly yours, 6 C. F. Shaw, Ass ' t. Director Public Works/Pollution Control CFS :bmr cc: Jean E. Zurbrigen, Town Manager Robert Deptula, Environmental Health Officers Michael J. Gantick , Director of Public Works i dip S 0-4 St., O D c a 1540 SULLIVAN AVENUE SOUTH WINDSOR. CONN. 06074 R-CO AREA CODE 203/644-2511 November 20 ,. 1989 Mr. Edward Kish Chief Refining Engineer South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 Dear Mr . Kish: I wish to express our appreciation for your cooperative efforts to date in resolving the odor problems reported by area residents living on McGrath and High Tower Roads . Our meeting at the Town Hall on Tuesday, November 14, 1989 attended by yourself, Mr. Fischer, and Mr . Kettler from South Windsor Metallurgical , and by the Town ' s Environmental Health Officer Mr. Deptula and myself was informative and productive. During this meeting, the Town shared information concerning these dates on which odor complaints were received by the Town. Subsequent to said meeting, the Town obtained a listing from D .E.P. of previous complaints made by the residents on the following dates--July 18 , 1989 , August 28, 1989 , September 1 , 1989 , October 11 , 1989 , October 12 , 1989 , October 16 , 1989, October 23 , 1989 , October 30 , 1989, November 7, 1989 , November 10 and November 13 , 1989 . Mr. Kettler indicated that South Windsor Metallurgical would voluntarily conduct stack testing; he indicated that he could not think of a source at the South Windsor facility for the "chlorine-like" odors . The Town suggested that a possible source might be the caustic soda solution used during the processing operations at the facility; trace amounts of sodium chloride ( <1 . 0%) and sodium chlorate ( <0 .2%) are ingredients of the caustic soda solution. The Town also recommended that South Windsor Metallurgical work cooperatively with the State D.E .P. to resolve the odor problem. Furthermore, it was suggested--that.- the D.E.P. may have testing equipment that can be used for the stack testings. It was stated that the D .E .P. will be reviewing the permits of all manufacturing facilities in the area of the Rye Street and Sullivan Avenue intersection. Mr. Edward Kish Chief Refining Engineer So. Windsor Metallurgical , Inc. November 20, 1989 Page 2 South Windsor Metallurgical requested that the Town notify them immediately upon receiving any more odor complaints . Thank you again, -for your help in this matter, and feel free to contact this office if South Windsor Metallurgical has any further questions . Very truly yours, C.-F . Shaw, Asst. Director Public Works/Pollution Control CFS:bmr cc: Jean E. Zurbrigen, Town Manager Michael J. Gantick, Director of Public Works Robert Deptula, Environmental Health Officer✓ Who,runs ....` ,a. _ program • TOWNS THER at issue BESI By LISA RICHARDSON, s i d e n t S worry Courant Staff Writer SOUTH WINDSOR — The que's-.. tion of who will administer the i ref n e ry t O X'n s town's'nascent moderate housing program may draw more debate said, referring to a DEP odor cita- than the project itself did. ,pp Lion delivered to metallurgical in The housing authority believes it writer December. "I hope they do get it should administer the program, but the town manager believes her of- cleaned up." fice should determine who will run D S O R — Another neighbor, George it. idents.hope a Daniels, said "We've had some environmental complaints recently about odors." Town Manager Jean E.Zurbrigen ssued Friday "I'm glad they're finally doing recommended to the housing task ietals refinery �' force that her office appoint an ad- something about it — it's been a `� ministrator for the ro ram. t occasional „ P g ey've suffered problem for a multitude of years, Daniels continued. "But after the Housing authority members, who but they also OSHA findings, we want to know �'u+''�' learned of her recommendation by or other toxic more about lead."- reading the housing task force min- ' a released by utes,were upset with the recommen- He and other neighbors are con- .Screen dation. )r our health cerned:that the investigations ap- specially when pear to lack coordination. (or Equal V Housing authority members say ,ees were ex- After four years,.during which Sale Ends6 the planned moderately priced hous- the building." the neighborhood complained of ing should be in their purview, as IcGrath Road occasional odors that ranged from Come in was the Flax Hill senior citizen resi. tbout the odor. mild to stifling, the DEP cited Now! Bence. Housing authority members Metallurgical Metallurgical for an odor violation complained to the town council this week of the town manager's prop9s- y by the DEP in December. al,saying that she should have ndili- idmitted to ex- The company was cited for 22 fied the authority of her recommen- high levels of workplace Hazards by OSHA in dation . ,. d copper, in February: But OSHA did not in- "Quality i vestigate emissions of lead or-other . Authority members at the town council meeting c d Metallurgical toxic materials because it has no t g complained that the ious fumes and jurisdiction outside the workplace. we re' town manager made reeommenda- tions to another group about a pro- with-a.plan.to The DEP took. another look at -riday, but did the plant a r-nd when it found that Posal they authored. : . - its order. The the company, may have violated I �i CyC "It just strikes us that this is a f it is the cause emissions reporting standards, it most inappropriate way to conduct has 30 days to referred the matter to the EPA, n Q n_,S town business,"said Frank Ahearn, ie state order. which has the authority to in director of.the housing authority. federal En- vestigate and impose penalties for In ry u'r Zurbrigen;however,said that her Lion Agency is reporting violations. "t recommendations were made to the ' )mpany to find According to the federal housing task force because the group comply 'with Emergency Planning and Com- sought her advice. •ting regula- munity Right ,to Know Act, all "1 was responding to the concerns sor Sanitarian companies that use more than of the housing task force, and my, A he will begin 25,000 pounds of any of a list of recommendations were exactly that hund the plant 230 potentially harmful chemicals, to �� recommendations," Zurbrigen ham Estates must report the use to the 'state said. toxic pollutants DEP and to EPA. Mayor Lincoln H. Streeter told Metalurgical, which incinerates Ahearn that the council could not iody finally put and recovers precious metals from respond to his concerns at the time don't know how computer and industrial equipment help. rurant because it had no background infor- ailed about the and toxic industrial wastes and mation on the issue. lowe said. She byproducts,reported the emission If Ahearn and other members,of DEP emissions of copper in 1987 but has not. • ASSemblt; the housing authority ask to be put on HA lead orders reported since. • Solid oal._ a future council agenda,the council health hazards EPA officials are investigating will try to resolve the matter, nts and the whether the company's use and • Attractivt Streeter said. emission ofchemicals is below re- y In other business p more skeptical. porting standards or if the com • Cap acit ,Robert De tula 1 before," Flagg pany failed to comply with the law. c from the state Department of Health • F.d'd,,96n Me Services told the council that his an Phan,Tam Duach,` office was taking soil samples from Juliette Rice; around South Windsor Metallurgical heleaRomano, ,Carlos to'see whether there were substan- :Romano,Benjamin tial amounts of' in the round. `;Satrohan,Lourdes g Skoglund,Michael Stark, Last month the state occupational s,Hu Kaleb Sykes, safety and health agency cited the "t,Dominic Tierinni, company for having high levels of e,Mai Ann Vu,Jason lead inside the building,•which pre- isa Zaleski. cipitated the state's testing. - High honors Also, the residents near South Windsor Metallurgical have com- Allison Cook,Kathie plained for years of a chlorinelike 'Ann Jaworski,Stephanie smell ll, which they say comes from lc"ptnme, 8tricia Limeres;John Oliveri, the company. .i path Luiselle Rivera,Marc Seta, Kieu Vo. ly Willard,Karen "The theory is that if there is an ?!mm"ea rrrn., excessive amount of lead in the soil, that may be an indicator'of some Freshmen —Honors airborne lead,"Deptula said: Monica Albert,Michelle Assid,Jody :ker,Melissa Baker,Amy Bandy, ire Brewer,Beverly Broadnax, South Windsor',; haei Burns,Ruben Canales Jr.,John Hews notes og�Jesse Chamberlain,Henry Jesus Htlather Clavette,Jennifer rr oy�fertnlf" MCgranJennifer Cormier,Adam Cote, c.��,_eaW___� a SATURDAY,`OCTOBER 21, 1989 ZL( Residents complain Df Odor .Ab To � U Atafting chlorine Data �`��g Time -al-led '9-to-5 smell' WHILE YOU W RE OUT 4 ANDREW NELSON vernal Inquirer Staff Writer SOUTH WINDSOR Residents of of I4rnham Estates call it "the 9-to-5 Phone Area Code Number Extension nell." PLEASE CALL ,,It's a random chlorine odor that wafts TELEPHONED trough the neighborhood during work- WiLLCALLAGAIN kg hours,Monday through Friday. CALLED TO SEE YOU Residents like Paula Rowley notice--it WANTS TO SEE YOU URGENT my when.they walk outside during the ,eek to.wait with their children for the RETURNED YOUR CALL ;hool bus or collect the mail. 1 •� W � , ,.But despite the elusiveness of the odor, message :owley and the other residents want to rid out what it is. e -"I'm concerned about the children, .0 �>°`, owIey said Friday. :,Down the street, Linda Wilson xplained that she wants to know what er family is inhaling. "If it's dangerous, !e have a right to know," she said •o.,, ,hday. r for No smell permeated the damp .air. aside her house Friday amid the rain. at Rowley and Wilson hope the PAD 23-021 zoo SE, dghborhood reeks Monday at 2:30 ' EFFIC ENCY® 23-421- epRBONLFS8 That's,when officials from the state ofs] nvi.ronmental__Protec- on are due to arrive here to meet'with neighbors. �At Town Hall;Environmental Health "cerRobert Deptula said he hopes the wP can locate the source. "We're not %re where it's coming from;we're trying track it down, he said, adding that ie.sources of odors are difficult to. Cate. 'Farnham Estates is located off Rye Ereet just east of the Scantic River.and Os ihan,half a mile south of the East 6ndsor town line. Rows of single-fami- houses line the network of streets. No To tdustry is located close by, but Sullivan ^c o-5 venue - where most industry in this ®ate V iwn is located runs about amile Time Guth.; Tracking the odor — which Deptula WHILE YOU ERE OUT as smelled is all residents there can � eor �n`�.. 5 for now.Once they determine a con- f. stent time for the odor, they can call in of �.SLSLv e ate officials. DEP officials to come Phone Officials from the DEP's air-com- Area Code Number Extension fiance unit agreed to come at the TELEPHONED PLEASE CALL ,quest of Rep. Kevin F. Rennie, R- Guth Windsor. CALLED TO SEE YOU WILL CALL AGAIN Rennie said residents called him 'WANTS TO SEE YOU URGENT :cause after two years they've begun to orry. RETURNED YOUR CALL Wilson uses her school-age son as an ,ample. Leaving for school last week,he Message ood outside for a few moments then ime inside and said he couldn't breathe. %� -} �8'tt l�4 �°�'Q Lqq 1 ' hat,same morning, 'Rowley decided to 7ve her daughter to school because of e powerful stench. Usually, though, the chlorine smell is r ;titer, just a mild annoyance, Rowley id. "It's not so overpowering that it socks you off your feet,"she said. `Rowley and Wilson say their husbands operator ldom smell the 9-to-5 odor. because ey're at work during the day. Paul AnnPeao 23-oz1.2oo sets ifwley, though, caught it once. EFFICIENCY® 23-421-400SUS CARBONLESB R3H!tff)!•i! l.a'v'r�i'i�L �1�����/C� - 1 10VEMBER 17, 1989 ` MS •TREES st..rude'8 Novena VTOWNS - May the sacred Heart of Jesus be ndS t0 ChOOSE from adored, glorified, loved and pre- - served throughout the world now Odor , '. .ClJfi Of DIgLafi@ f 1 &forever,amen.SacredHear ofJesus,pray for us.St.Jude worker O I a I d ,t O burnin ►GON SHED of miracles pray for.us.St.Jude helper of the hopeless,pray for us. ■ - `IURSERY Say this prayer 9 times a day,by ,of`. _ . Computer circuits_ ffin Rd., South WIndSOr - the 8th day your prayer will be an- swered- Say it for 9 days. It has o n - fi A G N. O W ! never been known to fail.Publica- Pavetto said. a).Me St.to Grnng Rd.•289.7356 lion must be promised. Thank By ANDREW NELSON Once the. DEP identifies the You,St.Jude. P.H.Z. Journal Inquirer Staff Writer source, it could take enforcement SOUTH WINDSOR—Residue action, according to state regula- from burned computer equipment lions. D P E NIN is the source of the mysterious odor . The odor has been dubbed the that has plagued residents of the to-5 smell because neighbors detect Farnham Estates subdivision for it only during weekday work hours. more than two years,a state official Because of the time, when-most 7TH THRU DECEMBER 17TH Said today, people. there work, residents But Carl Pavetto,chief of the Air "realized only recently that others in ' NTH Gvo� Management Bureau of the the neighborhood had also noticed a Department of-Environmental the odor. - Protection,said his department has _.;:.One neighbor said recently that SOR yet to identify exactly who is burn- he smell sometimes becomes �' EXPRES ing the equipment,-identified as `powerful. She said her child was - computer' 6'4d���/� t; computer circuit boards. ` -`waiting outside for a'schoolbus one 4 _ _■ T =`The `nearest business to-'the day when the stench became so neighborhood, South Windsor great that.he lost his breath.-On South • • Metallurgical,Inc.,is working with 'decided same•day, another neighbor the DEP to see if it is causing the -decided to drive her .children to odor.. But a spokesman there said E E D RAW1 N G TO WI N y "we've school because of the overwhelm- toda that yet to have any ing smell. ' proof that we are"the source of the ;_ Usually; 9though,`th odor is —• �—� ° "1me11;described by the DEP as a lighter. Sometimes they can't smell I;ra., Pr- chlorine odor. - it. 'The spokesman who asked "Rennie ..became involved last • " 3�� �. ;` �;} '.. � A. that.he not be identified -would month and asked the DEP ..to e n■ ■ not comment, however, =when monitor the air. Olin' ' I Y 1 I n I Rab"b' askedif the precious-metal refinery Today; Rennie said he's glad the Cat- company burned computer circuit DEP has made progress in the case. boards. He added that "we don't "Considering that the problem has r Y4= ti use chlorineere.h " - `' • = .-been going on for three years In a report filed last.yearwiththe .think the :;people in the Hamilton Beach Toaster Broiler DEP, the company estimated that neighborhood will be _openly .,` ly, it released only one toxic chemical satisfied,"he sand. r 4 Hartford_Whaler tickets into the air :up to 1,000 pounds At Town Hall, Environmental of copper. Aealth Officer Robert Deptula said 2 UCONN'Basketball Tickets K The DEP' at the request of Rep: today that the DEP had yet to evin F. Rennie, .R-South contact him. Deptula said the town ` " Windsor, has monitored Ithe air in .is- interested in knowing what the area for a few weeks now to chemicals, -if any, have been identify the source. - _ released into-the air as a result of a "We have smelled the smell, the burning computer equipment. tay 'Li itnesses Say .: Ireland (whiler.seSuppliesLast) • joked of killingwo man 10 Worth that one of the other men should a ByJournal Inquirer Staff : have choked Pelky with . a ";telephone cord because it would A Manchester .'man and two have been less bloody. others -forced 'a Wallingford "They said they had gone in to oroc woman to have oral sex with them get sex from the lady who worked -ice Oil • ' a before raping and killing her,. two there," Flaher said, referring to , witnesses testified in New Haven Ireland and his companion,a Wall- t • �' " Superior Court Wednesday. ingford man named Lee Magoon ' " The testimony came in the week- who drowned in a Middlefield lake old trial of Kevin F. Ireland, a 19- in 1987. � ,, ; year-old Manchester resident The couple also testified that�,Lather offer accused of sexually assultinQ and Ireland and Maonn., ,,.i,a o.,.... ., O Cc 2� • a,( e� �ovr is ZONING OR WETLANDS VIOLATION/COMPLAINT TOWN OF SOUTH WINDSOR (Please fill in as much as possible, must included signature) DateL- Name of Complainant .�'�' .z Address & re, Phone Signature Name of Violator za Address Phone Owner of Property Violation/Complaint - (Please clear, b t brief) cr c a (office use) Complaint Verified: Date Time Section of Regulation Violated Violator Notified: Date Time Letter Phone Is this a repeat violaLion? Notes: DIM� fit, .1:3sor 1G .NE Js AGGNQ Final Action: ��;s ,,v c ess►_ March 1, 1991 MEMORANDUM TO: Jean E. Zurbrigen, Town Manager RE: South Windsor Metallurgical In response to the Journal Inquirer February 26, 1991 article (copy attached) regarding South Windsor Metallurgical, this Department is in the process of setting up a soil sampling program in the Farnham Estates area. This program will be aimed toward collecting soil samples to be tested for lead content, the result of which may give some indication as to whether or not air borne lead is discharged to this area. You will be informed once the program is organized and ready to begin. Robert Deptu a, R.S. Environmental Health Officer RD: jh r 66 — Ga G k 2- ol o 6019 OS 4A o � "'�aaNww�aaay��, Cl� V 12 col I ----------- ---------- s ---- � L1 I 7' I. -- n ----------------------------- _�,�T-��, zoo GERTS TO BE A TRUE COPY TICUT DEPARTM&ff OF PRtTl STATE. OF CONNECTICUT SUPERIOR COURT Ll NE11 : MEc To: The Commissioner of Environmental Protection of the State of Connecticut, his employees, agents, representatives, consultants and assistants, any employee or agent of the United States Environmental Protection Agency assisting the -Commissioner, and any state police officer or police officer of a regularly organized police departments The appended Application for Administrative Search Warrant II and attached affidavits of Ross Bunnell, David Stokes and Dwight I� Chernauskas, having been presented to and been considered by the �I undersigned, a Judge of the 'Superior Court, the undersigned (a) , i� is satisfied therefrom that grounds exist for said Application, ) I� and b finds that said affidavits establish probable cause to believe that there have been and are violations of Conn. Gen. Stat. § 22a-449 (c) because of violations of: {I 1. Regulations of Connecticut State - Agencies § 22a-449 (c) -5 2 Regulations of Connecticut State Agencies § 22a-449 (c) -7 3 . Regulations ., of Connecticut State Agencies § 22a-449 (c) --23 I 4 . Regulations of Connecticut State Agencies § 22a-449 (c) -24 i 5. Regulations of Connecticut State Agencies § 22a-449 (c) -25 - i 6. Regulations of Connecticut State Agencies ji § 22a-449 (c) -26 7. Regulations of Connecticut . .State Agencies § 22a-449 (c) -33 ti�0 Part 1 of 5 Parts/ Page 1 of 10 l i 8. Regulations of Connecticut State Agencies I § 22a-449 (c) -101, incorporating 40 CFR 261.2 (f) I 9. Regulations of Connecticut State Agencies �I § 22a-449 (c) -101 (c) (2) 10. Regulations of Connecticut State Agencies - § 22a-449 (c)-101(c) (3) (A) 11. Regulations of Connecticut State Agencies 2.2a-449 (c) -102, incorporating 40 CFR 262. 11 ' 12 . Regulations of Connecticut State Agencies j § 22a-449 (c) -102, incorporating 40 CFR 262 .20 - 262 .23 13 . Regulations of Connecticut State Agencies I 22a-449 (c) -102, incorporating 40 CFR 262 .30 - 262 . 34 I 14 . Regulations of Connecticut State Agencies § 22a-449 (c) -102 , incorporating 40 CFR 262 . 34, 265. 15 15. Regulations of Connecticut State Agencies i § 22a-449 (c) -102 , incorporating 40 CFR 262 . 34, 265. 15, (� 265. 16, 265.50 - 265_. 56 16. Regulations of Connecticut State Agencies j Ii § 22a-449 (c)-102, incorporating 40 CFR 262 . 34, 265. 50 - 265.56 17. Regulations of Connecticut State Agencies § 22a-449 (c) -102 (a) (1) , incorporating 40 CFR 262 Subparts B, D, and E 18 . Regulations of Connecticut State Agencies § 22a-449 (c) -105, incorporating 40. CFR 265. 13 19 . Regulations of Connecticut State Agencies i, § 22a-449 (c) -105, incorporating 40 CFR 265. 15 i; 20. Regulations of Connecticut State Agencies § 22a-449 (c) =105, incorporating 40 CFR 265.30 - 265.37 21. Regulations of Connecticut State Agencies ! § 22a-449 (c) -1.05, incorporating 40 CFR 265.50 - 265.56 22 . Regulations of Connecticut State Agencies ! § 22a-449 (c) -105, incorporating 40 CFR 265.73 !� 23 . Regulations of Connecticut State. Agencies i j § 22a-449 (c) -105, incorporating 40 CFR 265. 112 , 265. 142 , 265.143, 265.147 ! I� 24. Regulations of Connecticut . .State Agencies J § 22a-449 (c) -105, incorporating 40 CFR 265. 170 - 265. 177 /• Part 1 of S .Parts/ Page 2 of 10 �f I 25. Regulations ---- of -Connecticut State Agencies § 22a-449 (c) -106, incorporating 40 CFR 266.70 26. Regulations of Connecticut State Agencies § 22a-449(c)-108, incorporating 40 CFR 268 .7 27. Regulations of Connecticut State Agencies § 22a-449 (c) -108(a) (1) , incorporating 40 CFR 268 on each of the premises to be inspected specified below, and I reasonable grounds to believe that the Commissioner of ! Environmental Protection has a legitimate regulatory purpose in obtaining the desired warrant, under the conditions and circumstances set forth in the foregoing Application, with attached affidavits, that Conn. Gen. Stat. §§ 22a-6 (a) (5) , 22a-336 authorize the desired entry and warrant, and that therefore an Administrative Search Warrant should issue, NOW THEREFORE, 2T IS ORDERED, ADJUDGED AND DECREED that the Commissioner of Environmental Protection of the State of Connecticut, his employees, agents, representatives, consultants and assistants any employee- or agent of the United States Environmental Protection Agency assisting the Commissioner, andl I) any state police officer or police officer of a regularly ' organized police department assisting the Commissioner, arel i entitled and authorized to enter upon certain premises, to wit: I, !! 1. Property known as 1770 Kings Highway, Fairfield, H Connecticut, which property is identified in a deed recorded at Volume 285, Page 346 of the Fairfield land records. I j 2 . Property known as 300 - Rye Street, . South Windsor, II Connecticut which property is identified in a deed recorded at Volume 373 , Page 316 of the South Windsor land records. i Part 1 of 5 Parts/ Page 3 of 10 I' i l and inspect said premises to determine compliance with the Connecticut General Statutes, and with regulations of the Department of Environmental Protection, by doing the following: A. As to the Fairfield site: 1. Enter the premises for the purposes of conducting the ` actions authorized by this warrant, and in particular entering the following portions of the premises, along with such other portions of the. premises as are necessary to gain access to the areas to be searched: "(a) main building; (b) the chemical- products process area located to the north of the main building; (c) the main hazardous waste storage building (former hangar) II located to the north of the chemical products process area; (d) the laboratory building located to the east of the main building; (e) any portable buildings located on the ,property; (f) the paved surfaces around and between the -buildings referenced above; (h) the facility parking lot. - - _ I 2 . Take samples as follows (a) Samples of the contents of any containers or tanks of any sort which are or may be involved in waste generating processes or used for the storage of waste products in any of the areas to be searched. (b) Samples of any baghouse dust, slag, floor sweepings, filter cake, or dust captured in air pollution control equipment in any of the areas to be searched. (c) Samples of any waste water, cooling water discharges, iwater soluble oil, waste oil, waste solvent wipes, rags, or other spent absorbents, solvent still bottoms, spent deionizing beads, or laboratory wastes in any of the areas to be searched. (d) Samples of anywastes, rinses, sludges, cleaning baths, or spent degreasing. solvent contained in or generated from any of the industrial processes or machines in any if of the areas to be searched. i II (e) Samples of any oils,. sludges or waste materials in any sumps, trenches or other drainage structures in any of the areas to be searched. j'; 3 . Any samples taken may be analyzed in accordance with i the methods deemed appropriate by the Commissioner to determine the constituents of the samples. Part 1 of 5 Parts/ Page 4 of 10 �! 4 . In any portion of the premises for which entry is ! authorized by this warrant, take photographs and videotapes of the containers, storage, processing and waste treatment equipment, storage areas, and air pollution control equipment described above, and within those portions of the premises, to take photographs and videotapes of any other equipment or portions of the facility which may' be related to .compliance with Ii hazardous waste regulations. ! 5. From the office areas located in the main building and j i in the laboratory building, or in any portable buildings at the Fairfield site, take: (1) any records which document the origin, sources, nature, contents, II or -chemical constituents of the materials to be sampled, including but not necessarily limited to any invoices or bills of lading, any lot records' or printouts of computer databases used to document - this information, any Material Safety Data Sheets (MSDSs) j. ! prepared for the materials or the raw products which comprise them, any chemical analyses conducted by the Fairfield facility or. by outside, independent laboratories of the materials to be sampled, and any i correspondence from the Fairfield facility to the !! facilities at which the materials are reclaimed which I document this information, including the so called "advises" which may be required for wastes sent to the South Windsor facility; and, (2) any hazardous waste ►� compliance documentation, including any manifests, waste analysis plans, inspection schedules or logs, contingency plans, training records, and any documents relating to the requirements of Regulations of Connecticut State Agencies § 22a-449 (c) -105 (a) (1) , incorporating 40 CFR ' 265 Subpart C concerning preparedness and prevention requirements. ! 6. Bring onto the premises to be searched any and all I !! vehicles and equipment useful, potentially useful, or j necessary to conduct the search and take the samples described above, including, but not limited to, the following: electronic monitoring equipment, sampling equipment, decontamination equipment, personnel , j protective gear -(such as gloves, safety glasses and I! respirators) , a cooler in which the samples may be j stored after being collected, sufficient sample containers to contain and transport the samples, along i! with such equipment (such as cameras, camcorders, photocopying equipment) as is necessary to document the ji search under this warrant. i B. As to the South Windsor site: j �I 1. Enter the premises for the purposes. of conducting the actions authorized by this warrant, and in particular entering the following portions of the premises, along Part 1 of 5 Parts/ Page 5 of 10 i with such other portions of the premises as are necessary to gain access to the areas to be .searched: (a) the shipping and receiving area located in the western portion of the main building; (b) the container receiving storage area at the rear - (southern) portion of the main building; (c) the ovens designated TR-2, TR-5, and TR-10, located in the central portion of the main building; (d) the Dry Pan Evaporator unit located in the central portion of the main building; -(e) the air pollution control equipment located in the vicinity of the Dry Pan Evaporator in the main building, along with any ancillary systems associated with this air i pollution control equipment; (f) the approximately twelve ball mills located in the central portion of the main building; (g) the pre-settlement container storage iI area in the eastern portion of the main building; (h) the post-settlement container storage area in the eastern portion of the main building; and, (i). the office area in the northern portion of the building. 2 . Take samples as follows: (a) Samples of the contents of any containers or tanks of any , sort which are or may be involved in waste generating processes or used for the storage of waste products in any of the areas to be searched. li i (b) Samples of any baghouse dust, slag, floor sweepings, filter cake, dust captured in air pollution control equipment, or ash generated in the ovens or Dry Pan Evaporator in any of the areas to be searched. (c) Samples of any materials being milled in any ball mills within the area to be searched, or containers awaiting i milling or storing materials which have been milled. (d) Samples of any wastes, rinses, sludges, ash, cleaning baths, or spent degreasing solvent contained in or generated from any of the industrial processes or machines in any of the areas to be searched. (e) Samples of any oils, sludges or waste materials in any sumps, trenches or other drainage structures in any of the areas to be searched. 0 . Any samples taken may be analyzed in accordance with the methods deemed appropriate by the Commissioner to determine the constituents of the samples. I� I 4. In any portion of the premises for which entry is f authorized by this warrant, take photographs and I videotapes of the containers, storage, processing and ji waste treatment equipment, storage— areas, and air I! pollution control equipment described above, and within those portions of the premises, to take photographs and J Part 1 of 5 Parts/ Page 6 of 10 �I ; ! videotapes of any other equipment or portions of the facility which may be related to compliance with hazardous waste regulations. 5. From the office areas located in the main building take: (1) any records which document the origin, sources, nature, contents, or chemical constituents of the materials to. be sampled, including . but not necessarily limited to -:any invoices or 'bilis of lading, any lot records or printouts of computer databases used to document this information, any Material Safety Data Sheets (MSDSs) prepared for the materials or the raw products which comprise them, any chemical analyses conducted by the South Windsor facility, its customers, �j or by outside, independent laboratories of the I� materials to be sampled, and any correspondence from customers which document this information, including the so called "advises" which may be required, for wastes sent to the South Windsor facility; and, (2) any hazardous waste compliance documentation, including any I manifests, waste analysis plans, inspection schedules i or logs, contingency plans, training records, and any documents relating to the requirements of Regulations of Connecticut State Agencies § 22a-449 (c) -102 (a) , incorporating 40 CFR 262 . 34, referring to 40 CFR 265 { Subpart C concerning preparedness and prevention requirements. 6. - Bring onto the premises to be searched any and all vehicles and equipment useful, potentially useful, or necessary to conduct the search and take the samples described above, including, but not limited to, the -following: -electronic monitoring equipment, sampling equipment, decontamination equipment, personnel protective gear (such as gloves, safety glasses and I respirators) , a cooler in which the samples may be stored after being collected, sufficient sample containers to contain and transport the samples, along with such equipment (such as cameras, camcorders, photocopying equipment) as is necessary to document the i search under this warrant. i that said inspection and investigation will be conducted in a ' !� reasonable manner; that the inspection and investigation shall be ` ii conducted in accordance with the following timetable: (I ' i A. As to the Fairfield site: I I I 1. The actions authorized under this warrant may commence as early as 6: 00 a.m. on Wednesday, September 29, 1993 . Part 1 of 5 Parts/ - Page 7 of 10 I. 2. The actions authorized under this warrant may continue until they are concluded, but in any event shall be concluded no later than 6:00 p.m. on Friday, October 1, 1993 . 1 B. As to the South Windsor site: 1. The actions authorized under this warrant. may commence as early as 6:00 a.m. on Wednesday, September 29, 1993 . 2 . The actions authorized under this warrant may continue until they are concluded, but in any event shall be concluded no later than 6: 00 p.m. on Friday, October 1, 1993 . that during the course of the actions authorized by this warrant the Commissioner of Environmental Protection, his employees, agents, representatives, consultants and assistants, including any employee of the United .States Environmental Protection Agency 1 � assisting the Commissioner, or any state police officer orl officer of a regularly organized police department assisting the Commissioner, are authorized to make repeated entries upon the site as necessary to accomplish the work set forth in thisf� warrant. Service of this warrant and the appended application and flaffidavits shall be made by the Commissioner of Environmental . lProtection or his employees, agents, representatives, consultants i and assistants, or any state police officer or police officer of �j a regularly organized police department assisting they , �! Commissioner, upon the person or persons in charge of each of the : �I (I premises subject to the warrant at the time execution commences, liif any, and any other person arriving at the premises subject to ; the warrant claiming to have any authority. over the premises. Ini Part 1 of 5 Parts/ Page 8 of 10 a ► i' II — I ji addition, service may be made by the Commissioner of Environmental Protection, or his employees, agents, representatives, consultants and assistants, or any state police 1 officer or police officer of a regularly organized police department assisting the Commissioner, upon- any other person who is on or claims authority over the premises. Service shall bel made by leaving a true and attested copy of the warrant, and appended application and affidavits, with andin the hands of the person to be served, or an agent of the entity to be served, or Iat. the usual place of abode of the person to be served, or in some other manner reasonably calculated to give the person to be Ii served actual notice of*--the warrant. No person shall delay, interfere with, or hinder in any way any person with appropriate I; identification engaged in any aspect of service of this administrative search warrant. The Commissioner of Environmental Protection, or his employees, agents, representatives, consultants and assistants I� shall file with the .Superior Court for the Judicial District of Hartford New Britain at Hartford a return of the service andl execution of this warrant no later than November 1, 1993 , li indicating all persons served with the warrant, and appendedi application and affidavits, and all doings on the warrant. The , i! i iportions of the return concerning service on persons shall state ; ji the date of service, person served, name and title of the person ; .I I lj 1 serving the warrant, and the manner of service.- "'The portions ofl I the return concerning the doings on the -warrant shall contain ai I n Part 1 of 5 Parts/ Page 9 of 10 i� IIi �i narrative or other summary of what actions were taken on what (i dates. Signed at - Hartford, Connecticut, this theday of September, 1993 . 6-15d*-tr A Judge of t Superior Court I' � .�—fi��� '►vim-�. � �-�e ...�.�. ����..�t is i i �I,,�� Part 1 of 5 Parts/ Page 10 of 10 STATE OF CONNECTICUT �I SUPERIOR COURT i The Commissioner of Environmental Protection of the State of Connecticut hereby represents that there is probable cause to I believe that there have been and are violations of Conn. Gen. iStat. § 22a-449 (c) because of violations of: 11. Regulations of Connecticut State Agencies § 22a-449 (c) -5 2 . Regulations of Connecticut State Agencies § 22a-449 (c) -7 3.. Regulations of Connecticut State Agencies § 22a-449 (c) -23 4 . Regulations of Connecticut State Agencies § 22a-449 (c) -24 5. Regulations of Connecticut State Agencies § 22a-449 (c)-25 6. Regulations of Connecticut State Agencies § 22a-449 (c) -26 7 . Regulations of Connecticut. State Agencies § 22a-449 (c) -33 8 . Regulations of Connecticut State Agencies § 22a-449 (c) -101, incorporating 40 CFR 261.2 (f) 9 . Regulations of Connecticut State Agencies 22a-449 (c) -iol (c) (2) I 10. Regulations of Connecticut State Agencies § 22a-449 (c) -101 (c) (3) (A) I� 11. Regulations of Connecticut _ Stage Agencies I� § 22a-449 (c) -102 , incorporating 40 CFR 262 . 11 12 . Regulations of Connecticut State Agencies § 22a-449 (c) -102, incorporating 40 CFR -262 :20 - 262 .23 �I 13 . Regulations of Connecticut -State Agencies 22a-449 (c) -102 , incorporating 40 CFR 262 . 30 - 262 . 34 Part 2 of 5 Parts/ Page 1 of 8 I� 14 Regulations of Connecticut State Agencies 22a-449 (c) -102, incorporating 40 CFR 262. 34, 265. 15 �i 15. Regulations of Connecticut State Agencies § 22a-449 (c) -102, incorporating 40 CFR 262 . 34, 265. 15, 265. 16, 265.50 - 265.56 16. Regulations of Connecticut State Agencies § 22a-449 (c) -102, incorporating 40 CFR 262. 34, -265. 50 - 265. 56 I� 17. Regulations of Connecticut State Agencies 22a-449 (c) -102 (a) (1) , incorporating 40 CFR 262 , Subparts B, D & E 18 . Regulations of Connecticut State Agencies 22a-449 (c) -105, incorporating 40 CFR 265. 13 19 . Regulations of Connecticut State Agencies § 22a-449 (c) -105, incorporating 40 CFR 265. 15 I -20. Regulations of Connecticut State Agencies i § 22a-449 (c) -105, incorporating 40 CFR 265. 30 - 265. 37 21. Regulations of Connecticut State Agencies - I �I § 22a-449 (c)-105, incorporating 40 CFR 265. 50 - 265.56 22 . Regulations g of Connecticut State Agencies § 22a-449 (c) -105, incorporating 40 CFR 265.73 I 23 . Regulations of Connecticut State Agencies S 22a-449 (c) -105, incorporating 40 CFR 265. 112, 265.142, 265. 143 , 265. 147 24 . Regulations of Connecticut State Agencies i § 22a-449 (c) -105, incorporating 40 CFR 265. 170 265. 177 ! 25. Regulations of Connecticut State Agencies f 22a-449 (c) -106, incorporating 40 CFR 266. 70 i 26. Regulations of Connecticut State Agencies § 22a-449 (c) -108, incorporating 40 CFR 268.7 i 27 . Regulations of Connecticut State Agencies i 22a-449 (c) -108 (a) (1) , incorporating 40 CFR 268 I on each of the premises to be inspected specified below, and j reasonable grounds to believe that the = 'Commissioner ofi i Environmental Protection has a legitimate. regulatory purpose in i ,� Part 2 of 5 Parts/ Page 2 of 8 I I I� obtaining the desired warrant, under the conditions and circumstances set forth in the foregoing Application, with 1 attached affidavits, that Conn. Gen. Stat. - §§ - 22a-6 (a) (5) , i j 22a-336 authorize the desired entry and warrant, - and that !y therefore an Administrative Search Warrant- should be issued to #i � permit the Commissioner of Environmental Protection of the State i !' of Connecticut, his employees, agents, representatives, I !j consultants and assistants, any employee or agent of the United States Environmental Protection Agency assisting the Commissioner, and any state police officer or police officer of a regularly organized police department assisting the 'Commissioner, II to enter upon certain premises, to wit: I! !! 10 Property known as 1770 Kings Highway, Fairfield, Connecticut, which property is identified in a deed �j recorded at Volume 285, Page 346 of the Fairfield land . �j records. (I 2 . Property known as 300 Rye Street, South Windsor, I Connecticut which property is identified in a deed i recorded at Volume 373 , Page 316 of the South Windsor land records. i and inspect said premises to determine compliance with thel Connecticut General Statutes, and with regulations of thel Department of Environmental Protection, by doing the following: i A. As to the Fairfield site: i �. Enter the premises for the purposes of conducting the f I�' actions authorized by this warrant, and in particular entering the following portions of the premises, along with such other portions of the premises as are necessary to gain access to the areas to be searched: (a) main building; (b) the chemical products process area located to the north of the main building; (c) the main hazardous waste storage building. (former hangar) ' located to the north ,of the chemical products process Q Part 2 of 5 Parts/ Page 3 of 8 i' ! I area; (d) the laboratory building located to the east of the main building; (e) any portable buildings located on the property; (f) the paved surfaces around and between the buildings referenced above; (h) the facility parking lot. 2 . Take samples as follows: I I (a) Samples of the contents of any containers• or tanks of ! any sort which are or may be involved in waste generating processes or used for the storage of waste products in any of the areas to be searched. �I (b) Samples of any baghouse :dust, slag, floor sweepings, filter cake, or dust captured in air pollution control I equipment in any of the areas to be searched. Ij (c) Samples of any waste water, cooling water discharges, water soluble oil, waste oil, waste solvent wipes, rags, or other spent absorbents, solvent still bottoms, spent deionizing beads, or laboratory wastes in any of j the areas to be searched. II (d) Samples of any wastes, rinses, sludges, cleaning baths, or spent degreasing solvent contained in or generated from any of the industrial processes or machines in any of the areas to be searched. II (e) Samples of any oils, sludges or waste materials in any ! sumps, trenches or other drainage structures in any of the areas to be searched. 3 . Any samples taken may be- analyzed in accordance with j the methods deemed appropriate by the commissioner to determine the constituents of the samples. I` 4 . In any portion of the premises for which entry is jl authorized by this warrant,- take photographs and videotapes of the containers, storage, processing and 11 waste treatment equipment, storage areas, and air pollution control equipment described above, and within those portions of the premises, to take photographs and ? videotapes of any other equipment or portions of the if facility which may be related to compliance with ' hazardous waste regulations. �'I 5. From the office areas located in the main building and j in the laboratory building, or in any portable I buildings at the Fairfield site, take: (1) any records which document the origin, sources, nature, contents, or chemical constituents of the materials to be sampled, including but not necessarily limited to any ' invoices or bills of lading, any. - lot records or printouts of computer databases used to document this Part 2 of 5 Parts/ Page 4 of 8 a I! �I I! information, any Material Safety Data . Sheets (MSDSs) prepared for the materials or the raw products which comprise them, any chemical analyses conducted by the Fairfield facility or by outside, independent laboratories of the- materials to be sampled, and any correspondence from the Fairfield facility to the facilities at which the materials are reclaimed which document this information, including . the so called "advises" which may be required for wastes sent to the South Windsor facility; and, (2) any hazardous waste compliance documentation, including any manifests, waste analysis plans, inspection schedules or logs, contingency plans, training records, and any documents relating to the requirements of Regulations of �{ Connecticut State Agencies § 22a-449 (c) -105 (a) (1) , incorporating 40 CFR 265 Subpart C concerning preparedness and prevention requirements. 6. Bring onto the premises to be searched any and all vehicles and equipment useful; potentially useful, or necessary to conduct the search and take the samples described above, including, but not limited to, the following: electronic monitoring equipment, sampling equipment, decontamination equipment, personnel protective gear (such as gloves, safety glasses and respirators) , a cooler in which the samples may be !' stored after being collected, sufficient sample containers to contain and transport the samples, along with such equipment (such as cameras, camcorders, photocopying equipment) as is necessary to document the search under this warrant. B. As to the South Windsor site: 1. Enter the premises for the purposes of conducting the actions authorized by this warrant, and in particular entering the following portions of the premises, along with such other portions of the premises as are necessary to gain access to the areas to be searched: (a) the shipping and receiving area located in the western portion of the main building; (b) the container receiving storage area at the rear (southern) portion of the main building; (c) the ovens designated TR-2 , I TR-5, and TR-10, located in the central portion of the j main building; (d) the Dry Pan Evaporator unit located i in the central portion of the main building; (e) the air pollution control equipment located in the vicinity of the Dry Pan Evaporator in the main building, along with any ancillary systems associated with this air pollution control equipment; (f) the approximately twelve ball mills located in the central portion of the jj main building; (g) the pre-settlement container storage area in the eastern portion of the -main building; (h) �I the post-settlement container storage area in the I ii Part 2 of 5 Parts/ Page 5 of 8 eastern portion of the main building;') P g; and, (i) the office area in the northern portion of the building. 2 . Take samples as follows: (a) Samples of the contents of any containers or tanks of any sort which are or may be involved in waste generating processes" or used for the storage of waste i I products in any of the areas to .be searched. b Samples of an ba house dust s( ) p y g lag, floor sweepings, filter cake, dust captured in air pollution control equipment, or ash generated in the ovens or Dry Pan Evaporator in any of the areas to be searched. (c) Samples of any materials being milled in any ball mills within the area to be searched, or containers awaiting milling or storing materials which have been milled. (d) Samples of any wastes, 'rinses, sludges, ash, cleaning baths, or spent degreasing solvent contained in or generated from any of the industrial processes or machines in any of the areas to be searched. (e) Samples of any oils, sludges or waste materials in-" any sumps, trenches or other drainage structures in any of the areas to be searched. 3 . Any samples taken may be analyzed in accordance with the methods deemed appropriate by the Commissioner to determine the constituents of the samples. 4 . In any portion of the premises for which entry is authorized by this warrant, take photographs and (l videotapes of the containers, storage, processing and waste treatment equipment, storage areas, and air pollution control equipment described above, and within i those portions of the premises, to take photographs and videotapes of any other equipment or portions of the facility which may be related to compliance with hazardous waste regulations. I I � 5. From the office areas located in the main building take: (1) any records which document the origin, sources, nature, contents, or chemical constituents of the materials to be sampled, including but not !; necessarily limited to any invoices or bills of lading, j j any lot records or printouts of computer databases used to document this information, any Material Safety Data Sheets (MSDSs) prepared for the materials or the raw products which comprise them, any chemical analyses I� conducted by the South Windsor facility, its customers, or by outside, independent laboratories of the materials to be sampled, and any correspondence from Part 2 of 5 Parts/ Page 6 of 8 9 qfv� ��/ " ;I � l 1 i i customers which document this information, • including the so called "advises" which may be required for wastes sent to the South Windsor facility; and, (2) any hazardous waste compliance documentation, including any manifests, waste analysis plans, inspection schedules or logs, contingency plans, training records, and any documents relating to the requirements of Regulations of Connecticut State Agencies § 22.a-4:49 (c) -102 (a) , incorporating 40 CFR 262 . 34, referring to 40 CFR 265 Subpart C . concerning preparedness and prevention requirements. 6. Bring onto the premises to be searched any and all vehicles and equipment useful, potentially useful, or necessary to conduct the search and take the samples described above, including, but not limited to, the I following: electronic monitoring -equipment, sampling equipment, decontamination equipment, personnel protective gear (such as gloves, safety glasses and respirators) , a cooler in which the samples may be I stored after being collected, sufficient sample containers to contain and transport the samples, along with such equipment (such as cameras, camcorders, photocopying equipment) as is necessary to document the i search under this warrant. I. j I j !j i li I; j� II 'j Part 2 of 5 Parts/ Page 7 of 8 // v i WHEREFORE, the Commissioner of Environmental Protection of the State of Connecticut applies to the Su - pp Superior Court for the issuance of an administrative search warrant for the purposes set forth above. Signed at Hartford, Connecticut, this .the 24th day of i� September, 1993 j !� TIMOTHY It. E. RE EY COMMISSIONER OF ENVIRONMENTAL PROTECTION, STATE OF CONNECTICUT BY: RICHARD BLUMENTHAL ATTORNEY GENERAL obert B. Teitelman Assistant Attorney General P.D. Box 120 Hartford, CT 06141-0120 (203) 566-2090 II f STATE OF CONNECTICUT ) ) : ss. - Hartford, CT September 24, 199 COUNTY' OF HARTFORD ) i Subscribed and sworn to by Timothy R. E. Keeney, Commissioner I� of Environmental Protection, and by Robert B. Teitelman, i r Assistant Attorney -General, before me, this the 24th day of i September, 1993 . Kifaberly P. Massicotte Commissioner of the Superior Court li I Part 2 of 5 Parts/ Page 8 of 8i�� UI suing been duly sworn, deposes and says: 1. That I _am over eighteen years of age _and understand the-,meaning of an oath. 2. That I am employed as _a Senior Sanitary Engineer by the Department of Environmental Protection (DEP) of the State of Connecticut. I received a B.S. degree in Chemical Engineering from Johns Hopkins University in 1984. Pollowing that, I worked for several companies in hazardous waste management and other related environmental capacities for four years before being hired by DEP's Hazardous Waste Management Section in 1988. My present duties include reviewing inspection reports prepared by field staff from DEP or the ' Environmental Protection Agency (EPA) to determine if there. :are any violations of the Regulations of Connecticut -State Agencies pertaining to the management of solid and hazardous wastes. My duties also include preparing administrative enforcement actions in response to such violations, reviewing analytical test results and other documents for compliance participating in meetings, conducting site visits and otherwise overseeing the compliance measures taken by the recipients of these enforcement actions. My duties also include preparing civil and/.or criminal referrals for litigation, when appropriate, and assisting in the preparation, negotiation, and settlement of these cases. 3. That I have personal knowledge of the facts and circumstances hereinafter related, as the result of my own investigative efforts and those of fellow employees of the DEP, as well as from written reports prepared by employees of DEP. 4. That this .affidavit will address several issues. In summary, these issues are: 1. ) that the corporation which is the subject of this affidavit �- Q Part 3 of 5 Parts/Page 1 of 20 n manages materials which fall within -several listed categories of hazardous waste ("listed" categories :are -types of wastes which, by regulatory definition, are "hazardous"under State and Federal law) ; 2.) that this corporation claims certain exemptions from hazardous waste laws; 3.) that this corporation has not documented to DEP during inspections, or in correspondence submitted pursuant to State orders issued to it, that these exemptions appropriately apply; 4.) that, in the absence of such documentation, the corporation must fully comply with all applicable hazardous waste regulations for the materials it manages; 3. ) that DEP's inspections have revealed that this corporation does not comply with .all of these applicable regulations; 6.) notwithstanding .the fact that the exemptions may indeed .apply to some of the materials handled by this corporation, there are certain requirements which must nevertheless be complied with (such as hazardous waste determinations, documentation of claims that a material is not a solid waste or is subject to reduced regulation, use of hazardous waste manifests, :and retention of records to document that materials are not stored for more than .a year) , with which requirements this company has repeatedly failed to comply over several years; and, 7. ) that, as a result of the above, the corporation which is 'the subject of this affidavit has demonstrated a persistent pattern of non-compliance with regulations that clearly apply to it. These issues will be elaborated upon in more detail below. 5. That, based upon paragraphs 4 and 7 of the affidavit of. Dwight Chernauskas, on documents on file at DEP and on discussions by DEP personnel with representatives of the firm, Handy & Harman, is a company incorporated in the State of New York, which owns and operates two facilities in Connecticut. 6. That the aforementioned two facilities are registered as corporations with the Secretary of State in Connecticut as follows: a. ) South Windsor � .Part 3 of 5 Parts/Page 2 of 20 GN A a Metallurgical, Inc. , located at the property known as 300 Rye Street, South Windsor, Connecticut which property is identified in a deed recorded at volume 373, Page 316, of the South Windsor land records (hereinafter referred to as "the South Windsor facility") , and b.) Handy & Harman, located at the property known as 1770 King's Highway, Fairfield, Connecticut which property is identified in a deed recorded at Volume 285, Page 346, of the Fairfield land records (hereinafter referred to as "the Fairfield facility") . 7. That, based upon the affidavits of David Stokes and Dwight J. Dhernauskas, on documents on file at DEP, and on inspections conducted by 'DEP personnel on October 28, 1987, December 21, 1988, January 4, 1989, and May 19, 1992, the last of these in which I personally participated, the South Windsor facility operates in the following manner: a.) the South Windsor facility receives solid and hazardous wastes and other materials from customers and from other, off-site facilities owned by Handy &Harman, b. ) -these customers and off-site Handy & Harman facilities send these materials requesting that they be processed for precious metal recovery c. ) these materials are incinerated and/or evaporated in flame combustion units, producing an ash-like residue which is screened, segregated, and processed to produce: 1.) a metallic ingot, which is sent off-site for refining of precious metal values, and 2. ) a variety of secondary materials referred to by Handy & Harman as "sweeps" which are sent off-site for further precious metal recovery; d.) said sweeps include - spent ash, air pollution control equipment sludges, wastewater treatment sludges, floor sweepings, maintenance and other clean-up residues, and other waste materials. 8. That, based upon the affidavit of David Stokes, on documents on file at DEP, and on inspections conducted by DEP personnel on April 22, 1987, September 29, 1989, November 14, 1990, and March 16, 1992, the Fairfield facility i UJ Part 3 of 5 Parts/Page 3 of 20 conducts a variety of manufacturing operations involving precious metals which produce numerous wastes which are stored on-site, and subsequently sent off-site to other Handy -& Harman facilities (including the South Windsor facility) .for precious metal reclamation. These wastes include ..air pollution control equipment sludges, wastewater treatment sludges, process sludges and wastes, still bottoms sludges, used rags contaminated with chemicals, ' floor sweepings, maintenance and other clean-up residues, and other materials that conform to commonly recognized trade waste categories. Although it sends these wastes off-site for precious metal reclamation, the Fairfield facility does not itself engage in precious metal reclamation. 9. That, based upon documents on file at DEP, on inspections conducted by DEP personnel, and on claims made to DEP by representatives of Handy & Harman either in -person or in writing, the South Windsor facility and the Fairfield facility claim to operate in part under regulatory exclusions from the hazardous waste regulations. More specifically, the facilities claim regulatory exclusions pursuant to Regulations of Connecticut State Agencies ("RCSA") Section 22a-449(c)-101(a) (1) , incorporating 40 CFR 261..2(c) (3) and 40 CFR 261.6(a) (2) (iv), and RCSA ' Section 22a-449(c)-106(a) (1) , incorporating 40 CFR 266, Subpart F. These sections allow reduced regulation for certain hazardous waste sludges, by-products and commercial chemical products that are reclaimed, and for hazardous wastes that .are reclaimed to recover economically significant amounts of certain precious metals. 10. That on April 27, 1989, the South -Windsor facility was issued Administrative Order number HM-606 by DEP. Order number HM-606 required the South Windsor facility to, among other things, a. ) bring all hazardous waste handling procedures and facilities . into compliance with all applicable Connecticut Hazardous Waste Management Regulations; b. )� retain a. qualified Part 3 of 5 Parts/Page 4 of 20 ,u� OC J . consultant or demonstrate in-house expertise to perform the necessary studies under the above requirement; c.) submit to the Commissioner of DEP for review and approval a detailed report providing an inventory and hazardous waste determination and/or precious metal declaration for all wastes and/or recyclable materials stored on-site; d. ) submit to .the Commissioner of DEP for review and approval a detailed report providing the" management procedures necessary to comply with Connecticut's Hazardous Waste Management Regulations, including, at a minimum, container management procedures, record-keeping "requirements to document that materials are not accumulated speculatively, ' and a demonstration that materials are legitimately recycled; e. ) submit to the Commissioner of DEP for review and approval a report detailing hazardous waste manifesting procedures; f. ) verify to the Commissioner of DEP that all hazardous wastes identified pursuant to item c above have been removed and disposed of properly; g.) verify to the Commissioner of DEP that the remedial measures approved pursuant to item d above have been implemented; and, h. ) verify to the Commissioner of DEP that the hazardous waste manifesting procedures approved pursuant to item a above have been implemented. 11. That no hearing was requested concerning Order number HM-606, and it was not timely appealed. Accordingly, Order number HM-606 became a final Order. 12. That on or about November 10, 1991, I was assigned oversight of Administrative Order number HM-606. 13. That Z have read and am familiar with the affidavits of David Stokes and Dwight J. Chernauskas of DEP regarding the South Windsor facility, and that pursuant to the facts contained therein, the South Windsor facility has failed to comply with Order number HM-606. More specifically, based upon the violations set forth _in paragraphs 13 and 14 of David Stokes' affidavit, and in Part 3 of 5 Parts/Page 5 of 20 6K �/ , d 4�e my Wgt paragraphs 9 through 17 of Dwight J. Chernauskas' affidavit, the South Windsor facility has failed to comply with at least item -a identified in paragraph 10 above, in that by 'so Violating the referenced sections of the RCSA, they have failed to bring all -hazardous `waste handling procedures and facilities into compliance with the applicable Hazardous Waste _Management Regulations, as required by the Order, 14. That the South Windsor facility submitted documents in response to Order number HM-606 on June 7, 1989, August 2, 1989, August 9, 1989, and - February 28, 1990, and that DEP responded in writing concerning the Order on January 30, 1990. Furthermore, that these are the only correspondence on file at DES' regarding Order number HM-606. 15. That, based upon my review of the documents identified in the previous paragraph, the South Windsor facility had not complied with Order number Hid-606. More specifically, the South Windsor facility's responses did not adequately document their precious metal declaration as required in item c in paragraph 10 above, and did not adequately demonstrate that materials are legitimately recycled as required in item d •in paragraph 10 above. 16. That on October 8, 1987, the Fairfield facility was issued Administrative Order number HM-459 by DEP_. Order number HM-459 required the Fairfield facility to, among other things: a.) bring all waste handling procedures and facilities into compliance with Connecticut' s Hazardous Waste Management Regulations; b. ) provide adequate secondary containment systems for all container storage areas where hazardous wastes containing free liquids are stored; c. ) retain a qualified consultant or demonstrate in-house expertise to prepare the required documents and perform the necessary studies required by items a and b above; d. ) submit to the Commissioner of DEP for review and approval, plans and specifications for secondary containment systems for Part 3 of 5 Parts/Page 6 of 20 �,4e �6 5*44 container storage areas in accordance with subparagraph b. -above; e.) verify to the Commissioner of DEP that construction of secondary containment systems approved pursuant to item d above has been completed; :and, f.) submit to the Commissioner of DEP a report which details the remedial measures necessary to achieve compliance with all applicable hazardous waste regulations, including manifesting procedures, an updated contingency plan, personnel training records, an inspection schedule and log, a waste analysis plan, preparedness and prevention, container management, management procedures for recyclable materials containing precious metals, and a detailed description of hazardous waste management procedures to be implemented pursuant to item a above. 17. That no hearing was requested concerning Order number HM-459, and it was not .appealed. Accordingly, it became a final Order. 18. That on or about May 1, 1992, I was assigned oversight of Administrative Order number "HM-459. 19. That I have read and am familiar with the affidavit of David Stokes regarding the Fairfield facility, and that pursuant to the facts contained therein, the Fairfield facility has failed to comply with Order number HM-459. More specifically, based upon the violations set forth in paragraphs 4 through 11 and 15 of David Stokes' affidavit, the Fairfield facility has failed to comply with at least item a identified in paragraph 16 above, in that by so violating the referenced sections of the RCSA, they have failed to bring all waste handling procedures and facilities into compliance with Connecticut's Hazardous Waste Management Regulations, as required by the Order. 20. That, based upon my review of DEP files, the Fairfield facility submitted documents regarding the regulatory status of the facility and its precious-metal-containing recyclable wastes on November 15, 1985, June 19, 1987, September 23, 1987, September 28, 1987, October 12, 1987, January 29, Part 3 -of 5 Parts/Page 7 of 20 �—!� DAn,,��j He 1988, June 3, 1991, and May 26, 1992, and DEP responded in writing on July 17, 1985, December 2, 1985, August 19, 1987, and January 6, 1989. Furthermore, that these are the only correspondence on file at DEP regarding the regulatory status of the Fairfield facility and its precious-metal-containing recyclable wastes. In addition, based upon my discussions with David Stokes, who conducted the last three inspections at the Fairfield facility, exit interviews were conducted in which Mr. Stokes reiterated to management at the Fairfield facility (i.e. Richard Dieble, Larry Reina, Richard Ragiani, and Barbara McWhirter) DEP's positions regarding compliance status and compliance efforts at the Fairfield facility. 21. That, based on my review of the correspondence identified in the previous paragraph, and based upon my review of the correspondence identified in paragraph 14-above, the Fairfield facility and the South Windsor facility have consistently claimed that the wastes at the sites are not hazardous wastes or are exempt from hazardous waste regulation by virtue of their being recycled for precious metal values. However, these claims are not sufficiently documented as required by 40 CFR 261.2(f) for any person wishing to make such a claim, in that the company retains insufficient chemical analysis data and/or chemical data derived from process knowledge about how the waste was generated. As a result the company cannot, without further documentation, demonstrate to DEP that these claims are legitimate. Therefore, based upon my review of these correspondences as compared to the regulations, policies and guidance relevant to these matters, as well as the facts identified in the affidavits of David Stokes and Dwight J. Chernauskas, these claims are inconsistent with the requirements of RCSA Section 2.2a-449(c)-101(a) (1) , incorporating 40 CFR 261.2(b) (3) and 261.2(f), and RCSA Section 22a-449(e)-106(a) (1) , incorporating 40 CFR 266.70. ' , Part 3 of 5 Parts/Page 8 of 20 �67�/43 22. That, as reflected in DEP's responses identified in paragraph 14 and 20 above, DEP has expressed to Handy_ & Harman its disagreement with its claims concerning the Fairfield facility and the South Windsor facility and has requested further documentation, but this has not resulted in the'aubmittal of adequate documentation as requested. This has left DEP with ,no recourse other than to conduct the sampling itself, in order to ascertain the compliance status at the South Windsor facility and the Fairfield facility. 23. That, on or about February 1, 1993, I called the South Windsor facility, posing as a potential customer. I was transferred to an individual who was identified to me as Don Walsh, a sales representative. I inquired as to what sampling and other requirements would have to be met in order to send waste to the facility. Mr. Walsh informed me that no sampling would be required, either by the generator of the waste or by_the South Windsor facility, stating that "it's not really needed" and "we don't test ourselves.'" I said that, in addition to some high-value precious metal plating sludges, I also had some filters and wipes which I expect to be of low precious metal value. I inquired as to whether I could take wastes with low precious metal value, mix them in with the higher value wastes, and send them to the South Windsor facility for processing. Mr. Walsh indicated that this was an acceptable practice .and stated that "it's legal." Lastly, I asked whether the South Windsor facility could take 1,1,1-trichloroethane degreaser sludge, a chlorinated solvent, for precious metal reclaim. He stated . that the South Windsor facility could not take this waste. 24. That, as pointed out in paragraph 17 of the affidavit of Dwight J. Chernauskas, during a May 19, 1993 inspection by DEP of Vitramon, Incorporated of Monroe Connecticut, Mr. Chernauskas noted that the South Windsor facility has received chlorinated solvent sludges on several -occasions for -precious 4 Part 3 of 5 Parts/Page 9 of 20 metal reclamation. This is further confirmed in hazardous waste manifests dated January 8, 1992, February 5, 1992, March 6, 1992, and April 12, 1993, which were filed with DEP by Vitramon, Incorporated (manifest numbers - CTCO214691, CTCO214693, CTCO214695, . and CTF0129177, - respectively) . Consequently, notwithstanding what was .stated by Mr. Walsh as set forth in the previous paragraph, the South Windsor facility indeed accepted these materials. This discrepancy illustrates the lack of knowledge on -the part of the South Windsor facility regarding the waste it receives, and the resulting failure of the South Windsor facility to effectively screen or sample incoming wastes. 25. That the practice of intentionally mixing wastes in order to support arguments that one is not regulated under hazardous waste laws, as suggested by Mr. Walsh in paragraph 23 above, is not legal. This is because such practices improperly employ the recycling exemptions of 40 CFR 266 Subpart F in order to facilitate the low-cost disposal of materials which otherwise would not be considered practically or economically recyclable. 26. That due to the failure of the South Windsor facility and the Fairfield facility to properly screen and sample wastes sent for precious .metal reclamation, there is no way to determine at the receiving facility if the materials may be safely and appropriately processed -at the facility, if they contain legitimately recyclable amounts of precious metals, or even if they are the materials which they are claimed to be. 27. That, during a May 19, 1992 inspection at the South Windsor facility, Matthew Fischer, the Plant Manager of the facility, when asked why customers would utilize their facility rather than a permitted treatment, storage or disposal facility, stated to me that his facility is significantly less expensive. lY � Part 3 of 5, Parts/Page 10 of 20 28. That, based upon the affidavits of David Stokes and Dwight J. Chernauskas, on- inspections conducted by DEP of the -South Windsor facility and the Fairfield facility, and on other documents on file at DEP, certain types of hazardous wastes are accepted at the South .Windsor facility. • Furthermore, due to my review of the affidavits and otherdocuments on file referred to at the beginning of this paragraph, and through previous experience with other sites, 1 am familiar with these types of wastes. Therefore, based upon the types of wastes which are handled by the South Windsor facility and the constituents which typically comprise these types of wastes, there are numerous metallic and hydrocarbon-based hazardous :or toxic constituents in the wastes accepted by the South Windsor facility. 29. That, as set forth in paragraph 7 above, these wastes, along with the hazardous or toxic constituents 'described in the previous paragraph, are evaporated and/or incinerated in flame combustion units at the South Windsor facility, 30. That the incineration as described in the previous paragraph presents the possibility of air pollution if waste's or waste constituents which are incompatible with that facility' s equipment or otherwise technically inappropriate for treatment go undetected, and are accepted and processed. Furthermore, without adequate sampling and analysis of these wastes, there is no way to know what the fate is of the numerous toxic or hazardous constituents which are incinerated in these units (i.e. , whether they are destroyed, captured in the air pollution control equipment, remain in the ash, or are released to the ambient air) 31. That those constituents which are not destroyed or released to the ambient air as set forth in the previous paragraph will nevertheless remain in the ash, air pollution control wastes and other so-called "sweeps" which are Part 3 of 5 Parts/Page 11 of 20 �� sent off-site for further precious metal reclamation. Furthermore, that there is no way to know what the °fate of these toxic or hazardous constituents are, since they are not reclaimed at these off-site facilities. Therefore, sampling and _ a hazardous waste determination are_ necessary to determinewhether any toxic or hazardous constituents which are not reclaimed remain in these materials, to determine their regulatory status and, as a result, whether, or not the applicable hazardous waste handling requirements are being complied with. 32. That, based on paragraph 12 of David Stokes' affidavit, upon paragraph 5 of Dwight Chernauskas' affidavit, and upon.my inspection of the South 'Windsor facility on May 19, 1992, the South Windsor facility and the Fairfield facility maintain very strict security at their sites. In particular, both sites are sUrrounded- by high, chain-link fences and are monitored with security cameras. Security guards are posted at numerous locations and monitor the facilities. In' addition. all persons are thoroughly searched before exiting the facilities, to determine if they may be attempting to remove precious metal materials. There are also strict accounting and record-:keeping procedures in effect at the South Windsor facility for each quantity of customers' material which is slated for precious metal recovery. Therefore, as demonstrated by these ,procedures, Handy & Harman affirmatively and actively disallows removal of these materials from the two sites 33, That any sampling by DEP at the South Windsor facility and at the Fairfield facility will inherently require removal of small amounts of wastes slated for precious metal recovery, and/or materials derived from these wastes which may contain a portion of this precious metal value. Part 3 of 5 Parts/Page 12 •of 20 �� 34. That, based on paragraphs 32 and 33 above, the South Windsor facility and the. Fairfield facility will not allow DEP to take samples of its own for analysis. 35. That, based upon the failure of-the South Windsor facility and the 1 Fairfield facility to provide the needed information as described in paragraphs 20 through 34 above, it .is necessary to have access to the South Windsor facility and the Fairfield facility to take samples of any in-coming wastes, out-going wastes, in-process materials involved in either waste management or waste -generation, process residues (including but not necessarily limited to wastewaters, wastewater treatment residues and sludges, baghouse dusts, and floor sweepings), materials referred to by these companies as "sweeps, " and any other materials being stored pending shipment off-site for precious metal reclamation. 36. That, without such samples, it is not possible for DEP to determine the exact regulatory status of many of the above materials at the South Windsor facility and at the Fairfield facility. As a result, it is also not possible to determine compliance with Sections 22a-449(c)-100 through -110, inclusive, and 22a-449(c)-11 of the Regulations of Connecticut State Agencies for these materials, and for the operations in which they are processed. 37. That the sampling inspection described above should be an unannounced inspection, in order to ensure that the samples taken are truly representative of the materials which are typically generated, stored, or processed at the South Windsor facility and the Fairfield facility. 38. -That a warrant is necessary to obtain such access, due to the reasons enumerated in paragraphs 34 through 37 above. 39. That the Fairfield facility has a posted "no photography" policy. Ve �lihj�] Part 3 of 5 Parts/Page 13 of 20 40. That it is appropriate to take photographs and/or videotape any containers, storage, processing and waste treatment equipment, storage areas, and ' safety equipment in order to determine compliance with Sections 22a-449(c)-100 through -110, inclusive, and 22a-449(c)-ll of the Regulations of Connecticut State Agencies. Such photographs and or video recordings will be used for the subsequent identification of the materials which are sampled, to document :any distinguishing characteristics (such as type, size, or color) of any containers or equipment sampled or otherwise inspected, to document the presence or absence of any labels, lot numbers or other markings on "any containers sampled, and to document the location of containers -and equipment in relation to other objects at each facility., for future identification purposes. 41. a. 'That, in order to determine compliance with Sections 22a-449(c)-100 through -110, inclusive, and 22a-449(c)-il of the Regulations of Connecticut State Agencies, it will be necessary to review and take the following documents from the office area in the main building at the South Windsor site: 1.) any records which document the origin, source, nature, contents, or -chemical donstituents of the materials to be sampled, including but not necessarily limited to any invoices .or bills of lading, any lot records or printouts of -computer databases used to document this information, any Material .Safety Data Sheets (MSDSs) prepared for the materials or the raw products which comprise them, any chemical analyses conducted by the South Windsor facility, its customers, or outside, independent laboratories of the materials to be sampled, and any correspondence from customers which document this information, including the so called "advises" which may be required for wastes sent to the South Windsor facility; and 2. ) any hazardous waste compliance documentation (including any manifests, waste -analysis ;plans, inspection schedules or nQ `��f� Part 3 of 5 Parts/Page 14 of 20 logs, contingency plans, training records, and any documents relating to -the requirements of RCSA Section 102(a) (1) , incorporating 40 CFR 262.34, referring to 40 CFR 265 Subpart C, concerning preparedness and prevention requirements) . b. That, in order to determine compliance with Sections 22a-449(c)-100 through -110, inclusive, and - 22a-449(c)-il of the Regulations of Connecticut State Agencies, it will be necessary to review and take the following documents from the office areas located in the main building, the laboratory building, or in any portable buildings at the Fairfield site: 1.) any records which document the origin, source, nature, _ contents, -or chemical constituents of the materials to be sampled, including but not necessarily limited to any invoices or bills of lading, any lot records or printouts of computer databases used to document this information, any Material Safety Data Sheets (MSDSs) prepared for the materials or the raw products which comprise them, any chemical analyses conducted by the Fairfield facility or by outside, independent laboratories of the materials to be sampled, and any correspondence from the Fairfield facility to the facilites at -which the materials are reclaimed which document this information, including the so called "advises" which may be required for wastes sent to the South Windsor facility; and 2.) any hazardous waste compliance documentation (including any manifests, waste analysis .plans, inspection schedules or logs, contingency plans, training records, and any documents relating to the requirements of RCSA Section 105(a)(1) , incorporating 40 CFR 265 Subpart C, concerning preparedness and prevention requirements) . c. That the documents identified in subparagraphs a.l. and b.l. above are necessary in selecting which materials to sample, and in the subsequent �g Part 3 of 5 Parts/Page 15 ..of 20 identification of the materials which are sampled. More specifically, invoices or bills of lading provide information on where wastes come from or are sent, thereby providing an indication of the waste generation processes they were derived from, the likely constituents they may contain, ti and how they are subsequently handled; lot records or printouts of databases may document information on where the waste came from, when and how it was processed, and what its ultimate disposition was, all of which are important in determining if the proper waste management requirements were met at each step of the process; MSDSs contain chemical data on wastes and on the raw materials which comprise them; chemical analyses may document concentrations of regulated toxic or hazardous constituents; certain correspondence and in particular-. "advises" may describe the wastes handled, their constituents, or the processes from which they came, all of which are important facts which could affect sampling and parameter selection. d. That the documents identified in subparagraph a.2. and b.2. above are necessary in order to determine compliance with RCSA Section 22a-449(c)-102, incorporating 40 CFR 262 Subparts B, C, and D, and RCSA Section 22a-449(c)-105, incorporating 40 CFR 265 -Subparts B, C, and D, which require the preparation and maintenance of these documents. 42. That, based on the number of samples which must be taken, the time required to take these samples (including the time to decontaminate sampling equipment between sampling rounds and record the necessary chain-of-custody data) , the time required to take the required photographs, the time required to review the facility records, and the experience of DEP personnel in conducting these kinds of inspections, up to three days will be required to conduct the inspection described above. Part 3 of 5 Parts/Page 16 of 22 ¢aA ' 3 7� all 43. That a team of about six persons are necessary to serve the warrant, conduct the sampling, take photographs and/or videotape, and review and collect records and documents at each of the two sites. 44. That certain equipment will have to be brought in and taken out with 4 each sampling team_ in order to conduct the sampling at the South Windsor facility and the Fairfield facility. This equipment includes electronic monitoring equipment, sampling equipment, decontamination equipment, personnel protective gear (i.e. , gloves, safety glasses, respirators, etc. ), chain of custody sheets, notes and other documentation related to the taking of 'the samples, a cooler in which the _samples may be stored after being collected, and sufficient sample containers in order to contain and transport the samples to the designated analytical laboratories. 45. That, in order to fully and properly assess compliance at the South Windsor facility, it will be necessary to search the areas identified in paragraph 19 of Dwight Chernauskas' affidavit. 46. That, in order to fully and properly assess compliance at the South Windsor facility, it will be necessary to take the following at the South Windsor facility: a. Samples of the contents of any containers or tanks of any sort which are or may be involved in waste generating processes or used for the storage of waste products in any of the areas to be searched. Based on my experience and training, materials such as these in industrial plants frequently contain wastes or are involved in processes that generate waste. It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. b. Samples of any baghouse dust, slag, floor sweepings, filter cake, dust captured in air pollution control equipment, or ash generated in the g Part `V►\� � 3 of 5 Parts/Page 17 of 22 1 ovens or Dry Pan Evaporator in any of the areas to be searched. These materials are either sent off-site for reclamation or are processed and then sent off—site for reclamation, without having first performed hazardous waste determinations, as. required by RCSA Section 102(a) (1) incorporating 40 CFR .262.11, and RCSA Section 101(a) (1) incorporating 40' CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. c. Samples of any materials being milled in any ball mills within the area to be searched, or containers awaiting milling or storing materials which have been milled. These materials are either sent off-site for reclamation or are processed and then sent off-site for reclamation, without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a) (1) incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. d. Samples of any wastes, rinses, sludges, ash, cleaning baths, or spent degreasing solvent contained in or generated from any of the industrial processes or machines in any of the areas to be searched. These materials are -either sent off-site for reclamation or are processed and then sent off-site for reclamation, without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 4.0 CFR 262.11, and RCSA :Section 101(a) (1) incorporating 40 CFR 261.2(f) : It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. e. Samples of any oils, sludges or waste materials in any sumps, trenches or other drainage structures in any of the areas to be searched. j(,t Part 3 of 5 Parts/Page 18 of 22 4e- These materials are either sent off-site for reclamation or are processed and then sent off-site for reclamation, without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a) (1)• incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. 47. That, in order to fully and properly assess compliance at the Fairfield facility, it will be necessary to search the :areas identified in paragraph 16 -of David Stokes' affidavit. 48. That, in order to fully and properly -assess compliance at the Fairfield facility, it will be necessary to take the following at the Fairfield facility: ..Samp.les_._of...._the....contents __of-__any_. containe.r.&. _or...tanks_...of...any sort which are or may be involved in waste generating processes or used for the storage of waste products in any of the areas to be searched. Based on my experience and training, materials such as these in industrial plants frequently contain wastes or are involved in processes that generate waste. It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. b. Samples of any baghouse dust, slag, floor sweepings, filter cake, or—dust capture in air pollution control equipment in any of the areas to be searched. These materials are sent off-site for reclamation without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a) (1) incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. Part 3 of 5 Parts/Page 19 of 22 C '� c. Samples of any wastewaters, cooling water discharges, water soluble oil, waste oil, waste solvent wipes, rags, or other spent :absorbents, solvent still bottoms, spent deionizing beads, or laboratory . wastes in any of the areas to be searched.. These materials are sent off-site for reclamation, without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a) (1) incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. d. Samples of any wastes, rinses, sludges, cleaning baths, or spent degreasing solvent contained in or generated from any of the industrial processes or machines in any of the areas to be searched. These materials- are sent off-site for reclamation, without having first performed hazardous waste determinations, as required by RCSA Section 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a)(1) incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. e. Samples of any oils, sludges or waste materials in any sumps., trenches or other drainage structures in any of the areas to be searched. These materials are sent off-site for reclamation, without having first perrfor eed�iazarTous waste et rrminations�- —as- require d_-5y--RCSA Sec n 102(a) (1) incorporating 40 CFR 262.11, and RCSA Section 101(a) (1) incorporating 40 CFR 261.2(f) . It is necessary to sample these materials to determine the constituents of the wastes from these processes or waste streams. 49. That the samples identified in paragraphs 46 and 48 above will have to be taken to an analytical laboratory and analyzed in accordance with the test Part 3 of 5 Parts/Page 20 of 22 C A(f .� methods deemed appropriate by the sampling team at the time of the inspection to determine the constituents of the samples. The analytical methods so required for any given sample could include any of the following parameters: 1. ) Toxicity Characteristic Leaching Procedure ("TCLP") , by EPA.-method number 1311; 2. ) precious metal -content, by flame ionization and EPA method numbers 272.1 (for silver) , 231.1 (for gold) , 253.1 (for palladium) , and 255.1 (for platinum)`, or by another equivalent method; 3.) pH, by EPA method 9040, 9041, or 9045; 4.) flash point by EPA method 1010 or 1020; 5. ) reactive cyanide by EPA method 9010; and 6.) volatile organic compounds ("VOCs") , by EPA method 8240; or, other methods determined appropriate for particular samples collected. 50. That, in order to conduct the test methods selected for each sample, up to four ounces may have to be taken for .any liquid sampled, and up to one quart for any solid sampled. 51. That, since DEP lacks certain specialized sampling experience and analytical capabilities, assistance from the Environmental Protection Agency (EPA) Regional Office will be necessary to 'conduct the inspections at the two sites. More specifically, at least one person from EPA is needed in the team at each site specified above. 52. That, due to the large number of DEP and EPA staff required to conduct -_ tFiese inspections, a�ri3-due to the extreme Z cu3ti se tat are associated with re-scheduling such an inspection, that the inspections must be conducted on the dates currently scheduled, which are September 29, 30, and October 1, 1993. Ross Bunnell(411 - B �3 Part 3 of 5 Parts/Page 21 of 22 State of Connecticut) s.s. Hartford September ZT 1993 County of Hartford 4 On this the 1i�/ flay of September, 1993 before me, Robert B. Teitelman, the undersigned official, personally appeared Ross Bunnell, known to me, who subscribed the within instrument and swore to truth of the statements contained in said instrument. zz�,,O,�4 Robert B. Teitelman Commissioner of the Superior Court Part 3 of 5 Parts/Page 22 of 22 �. ^ I13 having been duly sworn, deposes and says: 1. That I am, over eighteen years of age and understand -the..meaning of an oath. 2. That I am employed as a Senior Field Inspector by the Department of Environmental Protection, Waste Engineering and Enforcement Division (DEPWEED) of the State of Connecticut. I have been employed by the DEPWEED (formerly DEP Hazardous Materials Management Unit) since April 1988. My duties include inspections and investigations relating to the generation, management, treatment and disposal of hazardous waste (HW) . The investigations and inspections . are done to .determine compliance with the State and Federal HW ' regulations as defined in Regulations of Connecticut State Agencies (RCSA) Sections 22a-449(c)-100 through -110 and 22a-449(c)-il (prior to July 17, 1990, RCSA Sections 22a-449(c)-1 through -43), and 40 CFR Parts 260 through 270. Prior to my employment with the DEP, I was employed by the U.S. Department of Defense, as an Industrial Hygienist for nine- years. 3. That I have ' personal knowledge of the facts and circumstances hereinafter related, as the result of my own investigative efforts and those of fellow employees of the DEP. 4. That on 29 Sept 1989 Margret- Cochran (Enforcement Engineer with the DEPWEED) and I visited Handy & Harman which is located at 1770 Kings Highway, Fairfield, Connecticut (hereinafter "the Fairfield site") . This visit was done to determine the site' s compliance with RCSA Sections 22a-449(c)-1 through -43, and in particular, RCSA Sections 22a-449(c)-6 through -9, and -18 through -40, which pertain to Treatment, Storage, Disposal Facilities (TSDFs). Richard Dieble and Larry Reins, and Richard Ragaini, employees of Handy & Harman, were �� Part 4 of 5 Parts/Page 1 of 18 "N ql W fi f 4 present during this inspection and provided information relating to the Fairfield site's hazardous waste management practices. These employees stated they were responsible for managingthe Fairfield site's hazardous waste grogram. John Bullock, Handy & Harman Corporate Attorney, -was.. also present during parts of this inspection. This inspection was also conducted to determine compliance with Order number HM-459 dated 8 Oct 1987, which required the Fairfield site to; a. bring all waste handling procedures and facilities into compliance with the State's hazardous waste management regulations. b. -provide adequate secondary containment for all areas storing hazardous waste containing free liquids. C. retain a qualified consultant or demonstrate in-house expertise exists to prepare the required documents and studies required by this order. This was to be accomplished on or before 31 Oct 1987. d. submit for review and approval, plans and specifications for secondary containment systems. _ This was to be submitted on or before 30 Nov 1987. e. verify that construction of secondary containment systems has been completed. This was to be accomplished on or before 31 Jan 1988. f. submit a report which details the remedial measures necessary to achieve compliance with all applicable hazardous waste regulations including: manifesting procedures, updated contingency plan, personnel gaining, inspection schedule and log, waste analysis plan, preparedness and prevention, container management, management procedures for recyclable materials containing precious metals, and a detailed description of hazardous waste management procedures to be implemented. This was to be accomplished on or before 31 Jan 1988. �3 C` Part 4 of 5 Parts/Page 2 of 18j.---ll , 5. That, based upon documents on file at DEP, the site provided written notification to the State DEP and the Federal EPA of its intentions to operate as a permitted Hazardous Waste Treatment, Storage, and Disposal Facility. This notification was in the form of a Part A interim status.- operating permit application form, which was dated 18 Nov 1980. The Fairfield facility stated in this Part A form that it would be operating as a Large Quantity Generator and a Storage Facility authorized to store hazardous waste for greater than 90 days. Four drum storage areas were identified in the Part A form. 6. During the Sept 1989 visit the following numerous deficiencies were noted in the areas of container management and storage area requirements, preparedness and prevention, hazardous waste determinations, inspection schedule and log, waste analysis plan, operating record, personnel training, contingency plan, use of hazardous waste manifests, closure plans, and financial documentation. Based upon the foregoing, . the -Fairfield site was in violation of RCSA Sections 22a-449(c)-5, -7, -8, -21., -23, -24, -25, -26, -27, -29, -30, -32, and -33. 7. That the violations observed during the 29 Sept 1989 inspection were repeat violations of :those identified in Order #HM-459. Consequently, as a result of these violations, Order #HM 459 was out of compliance. 8. That on 14 Nov 1990 Margret Cochran (Enforcement Engineer with the DEPWEED) and I visited the Fairfield site to conduct an inspection to determine their compliance with those sections of the regulations governing TSDF activities and to determine compliance with order HM-459. Richard Deible and Larry Reins, employees of -Fairfield Handy & Harman, were present during this inspection and provided information relating to the Fairfield site's hazardous waste management practices. John Bullock, corporate attorney for Handy & Barman was available during parts of this inspection, to provide additional Part 4 of 5 Parts/Page 3 of 18 �g Alf information relating to hazardous waste management practices. During the 14 Nov 1990 inspection the following was -noted for the Fairfield site: a. Container management/storage area requirements: During ,a walk-through of the facility and grounds I -observed evidence of spilled' and leaking materials from drums containing waste. There were 37 containers of waste that were open and there were four drums marked ,hazardous waste" which were not being stored in the hazardous waste storage area. These four drums were lacking secondary containment and no warning signs were posted in this area. Based on the drums' -accumulation dates, these drums were stored greater than 90 days. There was a 55 gallon drum of hazardous waste Lr- the designated hazardous waste storage area which was corroded -and leaking. The drum was lacking a label to identify its contents. When r. (s) Deible and Reins, were asked to identify the leaking materials, they coeld not. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.30-34, and RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.170-177. b. Preparedness and prevention: I observed waste containers being stored which lacked sufficient aisle space. In .particular, there was not enought space between many of the drums for me to gain access to and inspect each container. The outside storage areas were lacking warning signs. There were no alarm or communications devices immediately accessible to the outside storage areas. Based upon the foregoing, the Fairfield site was in <r c-la tion of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.34, and RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.30-37. c. Pre-transport requirements: I observed the following in the designated hazardous waste storage area: there were 15 containers lacking proper packaging; all containers holding solid waste materials were lacking labels Part 4 of 5 Parts/Page 4 of 18 so ( � i to identify their content and the same containers were lacking 'the words "hazardous waste; " three 55 gal drums were lacking accumulation dates and there were four 15 gallon containers which were bunched together making viewing of the accumulation dates impossible. Based upon the foregoing, ti the Fairfield site was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.30-34 d. Hazardous waste determinations: Ms. Cochran and I .asked Mr. (s) Dieble and Reins. to provide hazardous waste determinations for several waste types and individual containers observed during the course of this inspection. They did not provide them. In explaining this lack of waste determinations, Mr. (s) Deible and Reina said many of the wastes in question were exempt from hazardous waste regulations because they were being recycled for their precious metal content. Ms. Cochran and I asked that this be demonstrated .either in the form of analysis, assays or documented process knowledge. Mr. (s) Deible -and Reina said those materials going for reclaim are considered to contain precious metals because silver is the primary product produced at the Fairfield site. Mr. (s) Deible and Reina stated their belief that if a drum contains a waste that is visually solid in appearance, that material is not a hazardous waste. Consequently, no analyses, assays, or documented process knowledge were provided. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.11, RCSA Section 22a-449(c)-101 incorporating 40 CFR 261.2(f) , and RCSA Section 22a-449(c)-106 incorporating 40 CFR 266.70. e. Inspection schedule and log: Ms. Cochran and I asked Mr. (s) Deible and Reina to produce an inspection schedule and inspection log. They provided an inspection log for the waste water treatment plant, but did not have one I,/� (C�g, Part 4 of 5 Parts/Page 5 of 18 - 1 A J for the hazardous waste storage areas. They could not verify that weekly inspections of the hazardous waste storage areas were being done. Based on the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.15. 4 f. Vaste analysis plan: Ms. 'Cochran and I asked. Mr. (s) Deible and Reina to provide a waste analysis plan for DEP review. According to Mr.(s) Deible and Reina there has been no plan developed. They stated that if they encounter a container of a unknown material they check for pH only.. However, by only checking for pH, the Fairfield site would overlook wastes which might be hazardous due to other properties (e.g. by being ignitable, reactive, toxic, or from certain listed hazardous waste generating processes) . Indeed, during my inspection, many of the waste materials I observed contained components which could exhibit many of these other properties. Therefore, based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.13. g. Operating Record: Ms. Cochran and I asked Mr. (s) Deible and Reina to produce an operating record. As stated during the 1989 inspection, no operating record has been developed and none was provided for me. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.73. h. Training program and documentation of training received: Ms. Cochran -and I asked Mr. (s) Deible and Reina to provide records documenting workers names, job titles and position descriptions for those workers with emergency response duties and hazardous waste handling duties. We also asked them to provide a description of the type of training received and dates of last training provided. They did not have or develop the requested records and documentation. Larry -Reina had been trained y < , Part 4 of 5 Parts/Page 6 of 18 %� -A I2 q3 �(� L- "Lyons" but this training did not cover the Fairfield site's contingency plan. There were no job descriptions, job titles or list of names for those employees having emergency response and hazardous waste handling duties. According to Mr. (s) Deible and Reina, none of- these have been developed. Based upon the foregoing,. the , Fairfield site -was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262'.34 and 265.15: i. Contingency plan: Ms. Cochran and I asked Mr. (s) Deible and Reina to produce a contingency plan for DEP review. They said they could not find a copy of the plan and said they were not sure .if it had been updated since the 1989 inspection. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-102 .incorporating 40 CFR 262.34 and 265.50-56. j Manifest requirements: Ms Cochran and I asked Mr. (s) Deible and Reina to provide copies of manifests and land disposal restriction documents for off-site shipments of hazardous waste including those hazardous wastes which are shipped to South Windsor Metallurgical and Handy & Harman Attleboro Mass. for recovery of precious metals. They stated that any waste that is solid in nature and/or being shipped off-site for precious metal reclaim does not require the use of manifests or land disposal restriction documentation. Mr. (s) Deible and Reina said there are no manifests or land disposal restriction documents for the waste shipped off site that is solid in nature and contains precious metals. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.20-23, and RCSA Section 22a-449(c)-108 incorporating 40 CFR 268.7. k. Closure plan and financial documentation: Ms. Cochran and I asked Mr. (s) Deible and Reina for a copy of the site's closure plan, updated ew Part 4 of 5 Parts/Page 7 of 18 �x V�L i closure cost estimate and closure cost assurance mechanism, and *a copy of the site's liability insurance. Mr. (s) Deiblew and Reina provided _a copy of a closure plan dated 1987. This plan addressed closure of only one drum storage area. The plan did not describe the steps and methods to be used 4 to ensure the storage area was adequately cleaned and decontaminated. We reviewed a closure cost ,estimate document which was dated 1987. We asked for a current cost estimate, but Mr. (s) Deible and Reina did not know if a updated copy existed. Mr. (s) Deible and Reina were asked for a recent copy of the site's liability insurance. Mr. (s) Deible and Reina said they .did not have a copy. Attorney John Bullock said .the Fairfield site has closure cost assurance and insurance with the Bank of Boston and he would send that information to our office. I reminded them that they had promised to fax that same information during the 1989 inspection and I still had not received it. As of the :date of this affidavit, I have still not received this information. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.112, 265.142, 265.143 and 40 CFR 265.147. 9. That those violations observed during the Nov 1990 inspection were repeat violations of many of those identified from the Sept 1989 inspection. Consequently, Order IHM459 was still out of compliance. 10 That on 16 Mar 1992 Robert Garbauskas (field inspector with the DEPWEEED) and I inspected the Fairfield site to determine its compliance with those regulations governing TSDF' s and for compliance with Order number HW-459. Richard Deibel, Larry Reina and Barbara McWhirter (Handy & Harman Environmental Counsel) , all employees of Handy & Harman, were present during this inspection. They provided information relating to hazardous waste �� Part 4 of 5 Parts/Page 8 of 18 management practices. During the 16 Mar 1992 inspection,- the following -was noted for the Fairfield site: a. Container management/storage area requirements: During a walk-through of the facility and grounds I observed waste materials stored outside several of the buildings, in the outside covered storage pad, inside the process areas and in the designated hazardous waste storage area. I observed ten open drums . containing waste materials, four containers of hazardous waste that were lacking accumulation dates, two containers of hazardous waste that were not labelled with the words "hazardous waste,'" and three containers of hazardous waste that were lacking labels which described their contents. I also observed one container which had been labelled "Axothane, " a brand name for 1,1,1-Trichloroethane, but which, according to Mr. (s) Deible and Reina, actually contained methylene chloride, a different chemical. There were over 100 containers scattered throughout the facility and grounds that Mr. (s) Deible and Reina, and Ms. McWhirter said were wastes with precious metal content. Many of these were open, most were lacking labels and the -words "hazardous waste, " most were Tacking .accumulation dates, and with the exception of those containers in the designated hazardous waste .storage area, none of the other containers had secondary containment, warning signs posted or an alarm or communications system immediately accessible. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-102 incorporating 40 CFR 262.30-34, and RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.170-177. b. Hazardous .waste determinations: Through the course of the inspection, I asked Mr. (s) Deible and Reina, and Ms. McWhirter to provide hazardous waste determinations for several waste types, but they could not adequately Part 4 of 5 Parts/Page 9 of 18 !Z 2- 41�3 do this, as explained below. They stated that the wastes in question were exempt from hazardous waste regulation because they were being recycled for their precious metal content. Many of the waste types were only referred to as "containing some amounts of precious metals. " -I requested they demonstrate this in the form of analytical data or knowledge of process. Some of the wastes had been assayed for precious metal values or had been tested for lead, cadmium, or chromium, but this data was not sufficient to thoroughly assess the waste types, since these limited tests would not detect any other toxic or hazardous constituents which might be present. Many did not have data which was sufficient to completely identify the weete types. As a result, no adequate analyses or documented knowledge of Process were provided for these wastes. Based upon the foregoing, the Fairfield site was in violation of RCSA - Section 22a-449(c)-102 incorporating 40 CFR '262.11'. RCSA Section 22a-449(c)-101 incorporating 40 CUR 261.2(f) , and RCSA Section 22a-449(c)-106 incorporating 40 CFR 266.70. C. Inspection schedule and inspection log: I asked Mr. (s) Deible and R.ein&, and Ms. McWhirter to produce' inspection records for all the hazardous waste storage areas. An inspection record was provided for the designated hazardous waste storage area only. The other :areas storing hazardous waste are not inspected according the Mr. (s) Deible and Reina, and Ms. McWhirter, this being because they feel these materials are not :hazardous waste based on the precious metal -exemptions. As noted in the previous subparagraph, however, insufficient hazardous waste determinations existed for these materials upon which to rest these claims. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.15. Part 4 of 5 Parts/Page 10 of 18 � � �� d. Contingency plan: I asked Mr. (s) Deible and Reina, and Ms. McWhirter to produce a contingency plan for my review. An updated plan was provided, however this plan still failed to include the capabilities of the emergency equipment. Based upon the foregoing, the Fairfield site' was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.50-56. e. Waste analysis plan: I asked Mr. (s) Deible and Reina, and Ms. McWhirter to provide a copy of the waste analysis plan for my review. A partial plan was provided that addressed .some of the waste types generated. However, the plan failed to include parameters, test methods and sampling methods for most of the waste types generated, items which are necessary for any waste analysis plan. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating .40 CFR 265.13. f. Operating record: I asked Mr. (s) Deible and Reina, and Ms. McWhirter to provide a copy of the operating record for my review. The site contacts said they do not consider the Fairfield site to be a TSDF, so an operating record has never been developed and accordingly none was provided to me. However, as set forth in paragraph 5 above, the Fairfield facility is in fact a TSDF, and must therefore maintain these documents which are required by regulation. Based upon the foregoing, the Fairfield site was in violation of RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.73. g. Closure plan and financial documentation: I asked Mr. (s) Deible and Reina, and Ms. McWhirter for a copy of the hazardous waste storage area(s) closure plan, closure cost estimates and cost assurance documentation, and a copy of the site's liability insurance. The closure plan provided to me failed to include all areas noted as having stored hazardous waste. The plan also failed to address the steps and methods to follow to ensure the Part 4 of 5 Parts/Page 11 of 18 PGX 56� 4"' �� storage areas were -adequately cleaned and decontaminated. The cost estimate was still the one from 1987 and they said the cost estimate had not been updated since that date. There was no closure cost assurance or liability insurance available. -Mr. (s) Deible and Reina, $nd•.Ms. McWhirter said they would fax these documents, however they have never been received. Based upon the foregoing, the Fairfield site was in violationof RCSA Section 22a-449(c)-105 incorporating 40 CFR 265.112, 265.142, 265.143, and 265.147. 11. That the violations noted at the Fairfield site during the Mar 1992 inspection are repeat violations of many of the violations observed during the 1989 and 1990 inspections. Consequently, the Fairfield site was found to still be out of compliance with Order number HM-459. 12. That strict security is maintained at the Fairfield site. In particular, the Fairfield site is surrounded by a high, chain-link fence and is monitored with security cameras. Security guards are posted at numerous locations and monitor the facility. In addition, all persons are thoroughly searched before exiting the facility, to determine if they may be attempting to remove precious metal materials. 13. That on 21 Dec 1988 and 4 Jan 1989 I conducted an inspection at South Windsor Metallurgical (a Handy & Harman Facility) , located at 300 Rye St, South Windsor, Connecticut (hereafter the S. Windsor site) . This inspection was done to determine the site's compliance with the Large -quantity Generator requirements set forth in State and Federal HW regulations. Ed Kish, Matthew Fischer and Bob Fuller, employees of South Windsor Metallurgical, were present during this inspection. They provided information concerning the South Windsor site's waste management practices. Handy & Harman Corporate Attorney, John 1 C?71, Part 4 of 5 Parts/Page 12 of 18 )11:3 PW �� Bullock was present during a follow-up visit in which DEP employees, Paul Franson, Paul Hassler and Sheila Sullivan accompanied me. 14. That the site notified the State DEP and the Federal EPA of its intentions to operate as a Large Quantity Generator as defined in 40 CFR sections 261 and 262. This notification indicated that the S. Windsor site would be generating greater than 1000 kilograms of hazardous waste per month and that this waste would be stored on-site for less than 90 days. Following an inspection done on 10-28-87 the company requested a status change to a Non-handler of hazardous waste. During this inspection the following observations were made: a. Container management/storage area requirements: During a walk-through of the S. Windsor site I observed several drums of waste scrubber water and a 55 gallon drum of waste solvent, all of which were open. There was no secondary containment for the hazardous waste stored in these areas. There were several 55 gallon drums containing a solid chemical salt like material, these drums were very corroded, did not have labels attached identifying their contents, the drums were lacking the words "hazardous waste, " and none of the drums had accumulation dates. Based upon the foregoing, the S. Windsor site was in violation of RCSA Sections 22a-449(c)-7, 22a-449(c)-25, and 22a-449(c)-33. b. Preparedness and Prevention: During a walk-through of the drum storage and handling areas I noted that there was insufficient aisle space for me to adequately inspect most of the drums of waste.- In the drum storage area for the Handy & Harman generated waste, there was no space between drums for me to enter and inspect them. Based upon the foregoing, the S. Windsor site was in violation of RCSA Sections 22a-449(c)-7 and 22a-449(c)-25. Part 4 of 5 Parts/Page 13 of 18 K ��J 3 c. Hazardous Waste Determinations: I asked Mr. (s) Kish, Fischer and Fuller to provide hazardous waste determinations for the scrubber water and scrubber system sludges, and other wastes which are considered to be S. Windsor's own ;generated waste, including floor sweeps from process areas and degreasing solvents from maintenance activities. Mr. (s) Kish, Fischer and Fuller said these wastes contain varied amounts of precious metals which were going to. be reclaimed. I requested assays of these waste to verify they actually did contain significant quantities of precious metals. Mr. (s) Kish, Fischer and Fuller said they do not assay their own generated waste., that because of the nature of their business, they assume the waste c-ontains significant quantities of precious metals. However, based on my observations, it appeared that several of. these materials may in fact c.ontairl very little precious metal value, in that the processes from which they are :generated involve very little contact with precious metals in a form which is likely to add significant precious metal value to the waste. Such an approach also does not address the possible presence of other toxic or b.ozardous constituents which might be present which might render the material a regulated hazardous waste. Based upon the foregoing, the S. Windsor site was in violation of RCSA Section 22a-449(c)-7. d. Inspection schedule and inspection log: I asked Mr. (s) Kish, Fischer and Fuller for copies of their inspection records for my review. According to Mr. k1s) Kish, Fischer and Fuller, no inspections were documented prior to �w 1988. The inspection logs presented for my review failed to address all requirements in that they lacked the time of inspection and separation of :Uic ompatibles, failed to include the emergency response equipment and did riot specify which areas were being inspected. According to Mr. (s) Kish, Fischer and Fuller, the inspection logs only applied to the areas Part 4 of 5 Pasts/Page 14 of 18 g 9 � � 1 where customer waste were stored prior to reclaim. Areas where the S. Windsor site stores their own generated waste was not being inspected, according to Mr. (s) Kish, Fischer and Fuller. Based upon the foregoing, the S. Windsor site was in violation of RCSA Sections 22a-449(c)-7, 22a-449(c)-23, and 22a-449(c)-33. e. Training program and annual training: I asked Mr. (s) Kish, Fischer and Fuller to provide a copy of the training program, a list of employees who have duties relating to emergency response and hazardous waste management, and with those names, to provide a job title and position description. I also asked to see records verifying those workers had received annual training. The training program provided for my review failed to include emergency response for incidents involving acids and cyanides. Mr. (s) Kish, Fischer and Fuller provided .a list of the worker's with emergency response duties and/or hazardous waste management responsibilities, however there was no documentation of the workers' job titles and position descriptions. Based upon the foregoing, the S. -Windsor site was in violation of RCSA Sections 22a-449(c)-7 :and 22a-449(c)-24. f. Contingency plan: I asked Mr. (s) Kish, Fischer and Fuller to provide me with a copy of the S. Windsor site's contingency plan. The contingency plan provided for my review failed to identify the current site's emergency coordinator and phone number, did not have a description of the capabilities of the on-site emergency equipment, and failed to include a description of the emergency response/evacuation alarm. I asked Mr. (s) Kish, Fischer, and Fuller what arrangements they had made . with local authorities, as required by the hazardous waste regulations. They responded that, with the exception of SARA Title III reporting (i.e., reporting required pursuant to Chapter 4461 of the Connecticut General \ , Part 4 of 5 Parts/Page 15 of 18 q/ 3 �� Statutes, which is a different requirement) , there had been no emergency response arrangements made with the local town authorities. In addition, the facility map and the contingency plan did not include locations where emergency response equipment was stored. Based upon the 'foregoing, the S. Windsor site was in violation of RCSA Sections 22a-449(c)-7 and 22a-449(c)-26. g. Manifest requirements: I asked Mr. (s) Kish, Fischer and Fuller for copies of manifests for wastes shipped off-site. The contacts said that manifests were not used for materials shipped off-site because these materials contained precious metals and anything shipped off-site was going Iron precious metal recovery. However, as set forth in subparagraph c r above, these claims regarding precious metal values were not documented. 1-r -A dition, the S. Windsor site receives hazardous waste from off-site ererators and stores this material prior to further off-site shipment to other Handy & Harman facilities. I asked Mr. (s) Kish, Fischer and Fuller whether or not manifests were being prepared for these waste shipments when they left the facility, as required by regulation. They responded that manifests were not being prepared but instead the shipments were being sent out under the original manifest. I also examined the manifests on file at the facility and confirmed that manifests were not being prepared for these shipments. Based upon the foregoing, the S. Windsor site was in violation of RCSA Section 22a-449(c)-5. 15. That on or about 9 Sept 1993 I received a phone call from Arnold Robbins, employed by EPA Region 9. Mr. Robbins said he had been referred to me by Mr. Podgurski who is -employed by EPA Region 1. Mr. Robbins said he had recently inspected a Handy & Harman facility in Arizona and he was interested in how DEP was interpreting the federal hazardous waste regulations wit e013 Part 4 of 5 Parts/Page 16 of 184 � `C 0_ respect to precious metal recovery facilities. Upon discussion with Mr. Robbins, it was noted that the Arizona facility had many of the same violations that DEP has noted in Handy & Harman's two Connecticut facilities (i.e. the Fairfield site and the, S. Windsor site) . More specifically, "he had noted violations relating to the lack of adequate testing and sampling programs to ensure the waste received from customers actually contained significant quantities of precious metal, and the lack of documentation to verify that Handy & Harman's own generated wastes contained significant quantities of precious metal. He also shared my concern that the residues generated after the recovery of the precious metal may be disposed of without being properly treated to remove the hazardous constituents which may still remain within that waste. We both agreed that these sites, as a result of these deficiencies, are - fully regulated under 40 CFR 261, 262, 263,--and 265, for those facilities which - - submitted a Part A notification. We also agreed that until a facility can demonstrate that the waste they are treating actually contains significant quantities of precious metal,` that these waste are hazardous waste and are fully regulated as hazardous waste. 16. The items identified in paragraphs 4 through 12 of this affidavit were observed by me in the following areas of the Fairfield site: a. ) the main building; b. ) the chemical products process area located to the north of the main building; c.) the main hazardous waste storage building (former hangar) located to. the north of the chemical products process area; d. ) the laboratory building located to the east of the main building; e. ) several portable buildings located in the general vicinity of the laboratory building, which were being used to store records, and other materials; f. ) the paved surfaces around and between the buildings referenced above, which were being used to Part 4 of 5 Parts/Page 17 of 18 �i/� 3 W store waste containers; and, h.) the facility park lot. David Stokes State of Connecticut) s.s. Hartford September N 1993 County of Hartford ) On this the 2tq�-day of September, 1993 before me, Robert B. Teitelman, the undersigned official, personally appeared David Stokes, known to me, who subscribed the within instrument and swore to the truth of the statements contained in said instrument. Robert B. Teitelman 'Commissioner of the .Superior Court \ Part 4 of 5 Parts/Page 18 of 18 9 1 a aving been duly sworn, deposes and says: 1.` That I am over eighteen years of age and understand the meaning of an oath. 2. That I am employed as a Field Inspector 3 by the Department of Environmental Protection (DEP) of the State of Connecticut. I am a geo-ecologist and have a B.S. degree in Environmental Science - Geology/Ecology. I have been employed by DEP since April 1988. My present duties include conducting hazardous waste, inspections at hazardous waste generators, .. treatment, storage, disposal, and reclamation facilities, complaint investigations in response to allegations of mishandling of waste materials, collection, handling, submittal, and interpretation of samples taken during inspections, reviewing field data collected during site visits to generate reports which detail conditions encountered during the inspections, coordination with other DEP units, the U.S. Environmental Protection Agency, and the State Attorney General's office in the enforcement of environmental regulations. 3. That I have personal knowledge of the facts and circumstances hereinafter related, as the result of my own investigative efforts and those of fellow employees of the DEP as well as from written reports prepared by employees and agents of the DEP. 4. That on May 19, 1992 I visited the site presently known as South Windsor Metallurgical, Inc. which is located at 300 Rye St. , South Windsor, Connecticut (hereinafter "the site") , along with Ross Bunnell from the DEP. The present owner of the site is Handy and Harman according to the Town of South Windsor land records. j Part 5 of 5 Parts/Page 1 of 8 5. That on this date I was designated the State of Connecticut representative for the purpose of conducting a Resource Conservation Recovery Act, Comprehensive Evaluation Inspection (RCRA, CEI) . The purpose of the inspection is to assess and evaluate. the site's compliance -with section • ti 22a-449(c)-100 through -110 and 22a-449(c)-11 of the Regulations of Connecticut State Agencies ("RCSA") , incorporating 40 CFR Parts 260 through 270. These regulations set forth procedures and protocols that must be followed by companies involved in hazardous waste management. 6. That during this inspection I observed that the site contains one main building in which processing takes place, and several outbuildings. The Gilts: 1,6- entirely surrounded by a chain link fence topped by razor tape with Petry controlled by a security guard who controls the main gate.. Exit from the r ite IF. achieved by passing through . a_ metal detection device which is controlled by a security guard. While touring the site I observed the shipping and receiving department where solid and hazardous wastes are received and shipped, the storage areas where wastes are stored prior to processing and .here processed wastes are stored pending off-site shipment for further processing, and the processing areas which contain numerous_ pieces of equipment used to process the incoming wastes. 7. That on this date, I met and toured the facility with Edward Kish, Manager of Engineering, and Matthew Fischer, Plant Manager. I asked them who sends them wastes that they process at the site. They responded that they receive wastes from their own customers, but also from numerous Handy & Harman facilities, since they are themselves a Handy & Harman company. 8. That, based on documents on file at DEP, the site notified DEP that, they were a large quantity generator of hazardous waste on January 13., 1986. Furthermore, based on additional documents on file at DEP, the site Part 5 of 5 Parts/Page 2 of 8 � a: rl , 9 3 Ow - 7�C *I, (V subsequently requested a change in their notified status on May 3, 1990, claiming that they were no longer generating hazardous waste. 9. That despite the site's claim regarding the generation of hazardous waste asset forth in the previous paragraph, on• the date of the inspection, I observed numerous containers of hazardous waste at the site. Furthermore, I also observed that the wastes in these containers were derived from various industrial processes at the site, based on :my inspection of the site' s waste tracking system and the lot numbers marked on these containers. 'Therefore, based upon these observations, the claim that the facility was no longer generating hazardous waste was not accurate. 10. That on this date I asked Mr. Kish and Mr. Fischer for a hazardous waste contingency plan, personnel training documents, and inspection schedule and log, items which are required of large quantity generators, in order to ensure hazardous wastes are properly managed, and to protect workers and the community from ,exposures which could be harmful to their health. Mr. Fischer statedthat these documents were not required for the site by virtue of the precious metals exemption of 40 CFR 266.70. Consequently, no such documents were provided to me. For a large quantity generator not to have the aforementioned documents is a violation of Regulations of Connecticut State Agencies (RCSA) Section 102, incorporating 40 CFR 262.34, 40 CFR 265.15, 265.16, and 265.50 through 56. 11. That, based on documents on file at_ DEP, the site has not .filed 'a recycling registration form with the .DEP to register this activity. Based upon the foregoing, the site was in violation of RCSA Section 22a-449(c)-101(c) (3) (A) . 12. That, during this inspection, I witnessed certain manifests in the facility records, which indicated to me that some of the hazardous wastes Part 5 of 5 Parts/Page 3 of 8 G 93 received at the facility are so called "listed" wastes of 40 CFR 261 Subpart D. Furthermore, that numerous documents on file at DEP include annual manifest summaries and previous inspection reports pertaining to the site. Said documents indicate that hazardous wastes with waste codes F001•; F002, F003, F006, F007, F008, F009, P098, and P104 have been regularly received at the site. Said waste codes correspond with the table of "listed" hazardous wastes at 40 CFR 261.31 through 261.33. According to 40 CFR 261.3(c) and (d), these "listed" wastes continue to be hazardous wastes even after treatment, and even if they are mixed or diluted with other wastes. However during the May ' 19, 1992 inspection, I observed that the facility was not tracking these "listed" waste and complying with the applicable hazardous -waste requirements for them. 13. That, during the May 19, 1992 inspection, I asked Mr. Fischer and Mr., Kish whether or not manifests were used for off-site shipments of processed wastes. They responded that these materials were not regulated due to precious metal recycling exemptions, and so no manifests were required. I further inquired whether or not the land disposal restriction requirements of 40 CFR 266 were complied with for _these wastes, and if the company complied with the hazardous waste export requirements for the materials they ship overseas for further processing. They again responded that these materials were not regulated due to precious metal recycling exemptions, and so did not follow land disposal restriction or export requirements for these materials. However, even precious metal recyclable wastes must be manifested under the precious WeLal exemptions. Furthermore, with regard to compliance with the land disposal restrictions and export requirements, the site's failure to demonstrate that all of the materials -contained significant quantities of precious metals (as set forth in paragraph 15 below) rendered invalid any Clsims that the materials were not regulated. Based upon the forgoing, and -/ Part 5 of 5 Parts/Page 4 of 8 upon the facts set forth in _paragraphs 9 and 12 above, the site was in violation of RCSA Section 102(a) (1) , incorporating 40 CFR 262 Subparts B, D, and E, and RCSA Section 108(a) (1), incorporating 40 CFR 268. 14. That, when I asked if incoming wastes are ,sampled; Mr. Fischer stated that the only form of analysis on an inbound quantity of solid waste is to perform an assay to determine its worth. This involves treating the entire batch of rmaterial and extracting the recoverable metals without first confirming that the material is what it was claimed by the generator to be, whether or not it may be safely and appropriately handled at the facility, *and whether or not it contains recoverable amounts of precious metals. The site instead relies on its clients to provide them with a letter or "advise" describing the materials' properties and handling procedures, and. considers this adequate for screening incoming wastes. Mr. Fischer also claimed that certain liquid wastes are sampled when they are received, but only for precious metal value, not for other purposes. As a result of these procedures, the company could not demonstrate to me that all the materials received were what they were claimed to be and were all legitimately recyclable. Based upon the foregoing, the site was in violation of RCSA Section 22a-449(c)-106, incorporating 40 CFR 266.70, and RCSA Section 101(a) (1), incorporating 40 CFR 261.2(f) . 15. That during the inspection performed on May 19, 1992 I observed hundreds of containers which were described by Mr. Fischer and Mr. Kish as precious metal recyclable materials which had been 'received from off-site and processed to recover the majority of the precious metals, but that were being stored pending shipment overseas for further precious metal reclamation. I requested hazardous waste determinations on these materials since they had been generated at the site. They responded by claiming that the wastes were in the Part 5 of 5 Parts/Page 5 of 8 g l� 9 3e-----l�j process of being reclaimed for precious metals, and were -therefore not regulated. However, even if being reclaimed for precious metal values, these materials were nevertheless wastes, and are therefore regulated. Furthermore, 40 CFR 261.2(f) requires that anyone wishing to claim a -material is not hazardous waste or is exempt from regulation,- must document these claims, which the site had not done. Based upon the foregoing, .and upon the facts as set forth in paragraph 12 above, the site was in violation of RCSA Section 22a-449(c)-102(a) (1) , incorporating 40 CFR 262.11 and RCSA Section 22a-449(c)-101(a) (1) , incorporating 40 CFR 261.2(f) . 16. That on the inspection performed May 19, 1992 I observed hundreds of containers which were described by Mr. Fischer and Mr. Kish as containing precious metal recyclable materials were not marked so that the contents were clearly identified, and were not marked with the date on which -accumulation began. RCSA section 22a-449(c)-101(c) (2) requires containers which hold recycled material which contain precious metals to bear markings which describe the contents and the date accumulation began. This regulation guards against companies from holding containers which may 'contain precious metal and storing them on-site indefinitely while speculating that the market price of the metal may increase (i.e. , so-called "speculative accumulation) ." This rule also allows detection of containers which have been stored for greater than the one-year limit for recyclable materials, as set forth in RCSA 22a-449(c)-100(c) . Based upon the foregoing, and upon the facts as set forth in paragraph 12 above, the site was in violation of RCSA Section 22a-449(c)-101(c) (2) . 17. That Wendy Jacobs, an engineer with the DEP Air Bureau, told me that Mike Barrata of South Windsor -Metallurgical, Inc. stated to her that halogenated solvents are not processed at the site. However, on the May 19, � � Part 5 of 5 Parts/Page 6 of 8 1992 inspection I reviewed a settlement (statement which determines the precious metal content and payment made to the generator) which explained the breakdown of precious metals content in a drum of 1,1,1, trichloroethane and methylene chloride still bottoms, both of which are chlorinated .-solvents. In addition, in a recent inspection I performed at Vitramon, Incorporated of Monroe, Connecticut on May 19, 1993, I was told by Haren Kamdar of that company that they ship containers of 1,1,1, -trichloroethane and methylene chloride still bottoms to South Windsor Metallurgical, Inc. on a regular basis. I also saw four hazardous waste manifests documenting recent shipments by this company to South Windsor Metallurgical. This discrepancy between what the site claims and what actually occurs illustrates the lack of knowledge on the part of the site regarding the waste it receives and handles. 18. That during the May 19, 1992 inspection, I asked Mr. Fischer why a company would choose their facility rather than a permitted hazardous waste treatment, storage, and disposal facility. He replied to me that it was "because we're cheaper than a commercial waste disposal company. " 19. The items described in paragraphs 5 through 16 this affidavit were observed by me in the following areas of the site: a.) the shipping and receiving area located in the western portion of the main building; b. ) the container receiving -storage area at the rear (southern) portion of the main building; c. ) the ovens designated TR-2, TR-5, and 'TR-10, located in the central portion of the main building; d. ) the Dry Pan Evaporator unit located in the central portion of the main building; e.) the air pollution control equipment located in the vicinity of the Dry Pan Evaporator in the main building, along with the ancillary systems associated with this air pollution control equipment; f.) the approximately twelve ball mills located in the central portion of the main building; g. ) the pre-settlement container storage ICY Part 5 of 5 Parts/Page 7 of 8 area in the eastern portion of the main building; h.) the post-settlement container storage area in the eastern portion of the main building; and, i. ) the office area in the northern portion of the :main building. Dwight J. Chernauskas 'State of Connecticut) s.s. Hartford September Zj 1993 County of Hartford ) On this the 2 � day of September, 1993 before me, Robert B. Teitelman, the undersigned official, personally appeared Dwight J. Chernauskas known to me, who subscribed the within instrument and swore to the truth of the statements contained in said instrument. Robert B. Teitelman .Commissioner of the Superior Court ``J� Part 5 of 5 Parts/Page 8 of 8 � ii ;3 -_ -- l 1 ycCy F vA-,d- - m4 t k b t , tj r� i STATE OF CONNECTICUT ) ss: Hartford COUNTY OF HARTFORD ) - Then and there and by virtue of the foregoing Administrative Search Warrant, service of the Administrative Search Warrant, Application for Administrative Search Warrant, Affidavit of Ross Bunnell, Affidavit of David Stokes, and Affidavit of Dwight Chernauskas, was made by Peter Ploch, Supervising Sanitary Engineer, Department of Environmental Protection, leaving true and attested copies of the foregoing documents on. September 29, 1993 with and in the hands of Larry Reina, Project Engineer, Handy & Harman, and Richard Deible, Manager, Engineering and Maintenance, Handy & Harman, being the persons in charge of the premises in Fairfield, Connecticut subject to the warrant at the time execution commenced, and by Mohamed Deria, Senior Sanitary Engineer, Department of Environmental Protection, leaving true and attested copes of the foregoing documents on September 29, 1993 with and in the hands of John Petrella, Lieutenant, Security Department, South Windsor Metallurgical, Inc. , being the person in charge of the premises in South Windsor, Connecticut subject to the warrant at the time execution commenced, and that the Commissioner of Environmental Protection, his employees, agents, representatives, consultants, and assistants, any agent or employee of the United States Environmental Protection Agency assisting the Commissioner, and police officers assisting the Commissioner, proceeded to execute the warrant as follows: A. As to the site in Fairfield, Connecticut: Wednesday, September 29 1993: The search team, consisting of Supervising Sanitary Engineer Peter Ploch, Sanitary Engineer Mary Hogan, Senior Field Page 1 of 15 Inspector David Stokes, Field Inspector Mark Jepsen, and Field Inspector Diane Duva of DEP, and Environmental Scientist Warren Timothy Bridges of EPA, arrived at Handy & Harman, located at 1770 Kings Highway in Fairfield, Connecticut at 9:30 a.m. After serving the warrant, the search team searched the Fairfield facility as follows: 1. The search team collected samples as follows: a. A sample designated as number HHF-93-1 was taken from two drums of mill wipes marked "Dept. 025" .which were in the Hazardous Waste Storage Area in the hangar building to the north of the main building. This sample was divided into three sample containers, consisting of two 32-ounce sample containers (one for Toxicity Characteristic Leaching Procedure ("TCLP") metals and one for TCLP organic compounds and methylene chloride) , and one four-ounce sample container (for precious metals analysis) . b. A sample designated as number HHF-93-2 was taken from one of several pans of sludge stored in the Hazardous Material Staging Area in the front portion of the hangar building to the north of the main building. This sample was divided into two sample containers, consisting of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . c. A sample designated as number HHF-93-3 was taken from a 55-gallon drum which was used for collecting baghouse dust from .the Aero baghouse in the main building. This sample was divided into two sample containers, consisting of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . d. A sample designated as number HHF-93-4 was taken from a 55-gallon drum containing baghouse dust from the Aero baghouse in the main building, which drum was stored in front of this baghouse. This sample was divided into two sample containers, consisting of one 16-ounce sample container (for TCLP metals), and one 150-milliliter sample container (for precious metals analysis) . e. A sample designated as number HHF-93-5 was taken from a second 55-gallon drum containing baghouse dust from the Aero baghouse in the main building, which drum was also stored in the vicinity of this baghouse, adjacent to the building wall. This sample was divided into two sample containers, consisting of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . f. A sample designated as number HHF-93-6 was taken from a wastewater treatment system sludge tank in the wastewater treatment room, which tank was referred to as "the right hand Lancy tank, " which contained wet sludge prior to dewatering. This sample was divided into three sample containers, consisting of two 32-ounce sample containers (one each for TCLP metals and organic compounds) , and one 4-ounce sample container (for precious metals analysis) . Page 2 of 15 g. A sample designated as number HHF-93-7 was taken of the residue in the Arco scrubber, an unused piece of equipment which had been disconnected and was stored outside the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 4-ounce sample container (for reactive cyanide analysis) . h. A sample designated as number HHF-93-8 was taken from a 55-gallon drum which was used for collecting baghouse dust from the Griffin baghouse in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 4-ounce sample container (for precious metals analysis) . i. A sample designated as number HHF-93-9 was taken from a 55-gallon , drum which was used for collecting baghouse dust from the Torit baghouse in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 4-ounce sample container (for precious metals analysis) . j . A sample designated as number HHF-93-10 was taken from a 55-gallon drum of floor sweepings in the scrap storage area. This sample was divided into three sample containers, consisting of two 32-ounce sample containers (one each for TCLP metals and TCLP organic compounds) , and one 4-ounce sample container (for precious metals analysis) . k. A field blank, designated as sample number HHF-93-FB was taken for quality assurance/quality control purposes. This sample consisted of a laboratory-prepared 40-milliliter glass vial containing distilled water which was taken to the site, placed in the same cooler, and sent to the laboratory with the actual samples collected. No wastes or other materials were placed in this container. 1. At Handy & Harman's request, duplicates of each of the samples identified in subparagraphs a. through j . above (i.e. "split" samples) were taken, placed in similar containers as the respective samples identified above, and provided to Handy & Harman for its purposes. 2. The search team took photographs and videotape recordings as follows: a. In the Hazardous Material Staging Area located in the hangar building to the north of the main building, photographs were taken of 1. ) numerous trays of metal hydroxide sludge; 2. ) metal hydroxide sludge on the floor around and among these trays and several 55-gallon drums; 3. ) several open drums; and, 4. ) a large hopper containing metal hydroxide sludge. A videotape recording was also taken in this area, panning across the storage area, and providing a general overview of the area. b. In the Hazardous Waste Storage Area located in the hangar building to the north of the main building, a photograph was taken of a five-gallon container of hazardous waste acid with two accumulation dates. Two additional photographs taken in this area did not come out due to camera malfunctions. Photographic slides were also taken in this area of 1. ) the same 5-gallon container identified above; and, 2. ) a 15-gallon hazardous Page 3 of 15 waste cyanide container with no accumulation date. A videotape recording was also taken in this area, panning across the storage area and providing a general overview of the area. c. In the outdoor, fenced, covered storage area located in the northeast corner of the Fairfield facility property, referred to as the LPM cage, photographic slides were taken of 1. ) two drums with hazardous waste markers and one with a non-hazardous waste marker identifying them as from Handy & Harman's Attleboro, Massachusetts facility; 2.) another view of the above; 3.) 15-gallon drums with unknown contents marked "DKS2" and "DKS3; " 4. ) a 15-gallon drum with unknown contents marked "DKS1; " 5. ) a 55-gallon drum in the corner of the area behind a stack of pallets which was later determined to be empty; and, 6.) a red 55-gallon drum with a flammable solid label, which was among several left at the Fairfield facility by Handy & Harman's transporter, LPM. Videotape recordings were taken in this area, showing a general overview of the area, a 15-gallon drum labelled "cyanide, " and the markers described in item 1. above. d. In the outdoor, unfenced, covered storage area located in the northeast corner of the Fairfield facility property, adjacent to the area identified in the previous subparagraph, photographic slides were taken of 1. ) a blue steel 55-gallon drum of floor sweepings; 2.) the drum identified in item c.6. above, which had been moved to this location from the area identified in subparagraph c. above; and, 3. ) a drum labelled "nonhazardous waste" which had also been moved to this location from the area identified in subparagraph c. above. Videotape recordings were taken in this area, showing a -general overview of the area. e. YThe following photographs and photographic slides were taken in the areas ;`where the sampling described in paragraph A.1. above was conducted::.`:: l.) two photographic slides were taken of the mill wipes sampled (i:e. sample number HHF-93-1) ; 2.) one photographic slide was taken of . the metal hydroxide sludge sampled (i.e. sample number HHF-93-2) ; 3. ) one photographic slide was taken of the Aero baghouse dust collection container sampled (i.e. sample number HHF-93-3) ; 4. ) one photographic slide was taken of the baghouse dust drum sampled, which was in front of the Aero baghouse (i.e. sample number HHF-93-4) ; 5. ) one photographic slide was taken of the baghouse dust drum sampled, which was in the vicinity of the Aero baghouse and adjacent to the building wall (i.e. sample number HHF-93-5); 6. ) one photographic slide was taken of a drum outside the main building in the vicinity of the: Aero baghouse which identified "Murata" as the generator (not sampled) ; 7. ) one photographic slide was taken of the wastewater treatment sludge sampled (i.e. , sample number HHF-93-6) ; 8. ) one photographic slide was taken of the baghouse dust from the Griffin baghouse (i.e. sample number HHF-93-8) ; 9.) three photographic slides were taken of the Arco scrubber residue which was sampled (i.e. sample number HHF-93-7) ; 10. ) one photographic slide was taken of the baghouse dust collected in the Torit dust collector (i.e. sample number HHF-93-9) ; 11. ) seven photographs were taken of the drums in the scrap storage area (i.e. , the drums sampled for sample number HHF-93-10) ; and, 12. ) two photographs were taken of two open 55-gallon drums stored on the roof of the main building which contained unknown material. In addition to the above photographs and Page 4 of 15 photographic slides, videotape recordings were also made in the scrap storage area, showing a general overview of this area, the drum which was sampled (i.e. , the drum sampled for sample number HHF-93-10) , and an adjacent storage area. 3. The search team examined and made photocopies of the following records: a. The Fairfield facility's Recyclable Materials Management manual, which included assay results, procedures for tracking, spill response, etc. , and descriptions of waste streams. b. The Fairfield facility's Process Material for Recovery manual, which included identifications of materials, assay results, procedures, and other related information. C. Portions of the Fairfield facility's Hazardous Materials Management manual, which included -memoranda, tracking procedures, the Fairfield facility's wastewater discharge permit application, a solvent management plan, training certificates for Larry Reina, staffing charts, and a U.S. Department. of Transportation Hazardous Materials Certificate of Registration. d. The Fairfield facility's Waste Analysis Plan and Waste Profile Sheets. e. The Fairfield facility's Recovery Lots Inventory, for the period October 3, 1992 through April 30, 1993. f. Refining Settlement Statements for lots number 0304, 0182, 0181, _2182, 0281, 0218, 0351, and 0402. Included with these were written Authorizations to Refine Scrap, assay results, shipping and receiving slips, and lists of drum numbers. g. Authorizations to Refine Scrap for lots number 0601, 0351 and 0352, 0403 and 0404, 0602 through 0605, 0609, 0405, 0606, 0607, 0608. Included with these were lists of drum numbers and assay results. h. A July 23, 1992 letter from Larry Reina to Diane Switzer of U.S. EPA Region I office in Lexington, Massachusetts concerning an inspection by EPA on June 9, 1992. i. A copy of Connecticut hazardous waste manifest number CTF0050714 for a shipment of hazardous waste from the Fairfield facility to Handy & Harman' s Attleboro facility. j . Two facility layouts, one showing the locations of spill stations and the other showing satellite container storage locations and the layout of the outdoor, unfenced, covered storage area located in the northeast corner of the Fairfield facility property, adjacent to the area referred to as the LPM cage. Page 5 of 15 4. After conducting the activities described above, the search team collected the equipment used to conduct the search and, along with the samples taken, placed them in DEP and EPA vehicles parked in the Fairfield facility parking lot. 5. The search team then left the Fairfield facility parking lot and proceeded across Grasmere Avenue to another portion of the Fairfield facility property on which was located the oil/water separator building. The search team then took the following samples: a. Three samples, designated as numbers HHF-93-11, -11A, and -11B, were taken from the oil/water separator located in a building in this portion of the Fairfield facility. Sample number HHF-93-11 consisted of a mixture of the oil and water phases in the separator, and was placed in a 32-ounce sample container (for TCLP metals analysis) . Sample number HHF-93-11A was taken from the oil phase in the separator, and was placed in a 40-milliliter sample container (for. EPA Method 624 volatile organic compounds analysis) . Sample number HHF-93-11B was taken from the water phase in the separator, and was placed in a 40-milliliter sample container (for EPA Method 624 volatile organic compounds analysis) . b. Duplicates of the samples identified in the previous subparagraph were taken from the oil/water separator for quality assurance/quality. control purposes. These samples were designated as numbers HHF-93-12, -12A, and 12B, and were placed in the same sized containers and analyzed for -the same parameters 'as the above samples. c. . At Handy & Harman's request, an additional duplicate of each of the samples identified in subparagraph a. above (i.e. "split" samples) were taken, placed in similar containers as the respective samples identified above, and provided to Handy & Harman for its purposes. 6. The team left the site at 7:30 p.m. This concluded the search of Handy & Harman at the Fairfield site. B. As to the site in South Windsor, Connecticut: Wednesday, September 29, 1993: The search team, consisting on this day of Senior Sanitary Engineer Mohamed Deria, Senior Environmental Analyst Paul Hassler, Senior Field Inspector Dwight Chernauskas, Field Inspector Mark Parker and Field Inspector Robert Garbauskas of DEP, and Environmental Engineer Daniel Granz of EPA, and accompanied by South Windsor Police Department Officer Richard Barile, arrived at South Windsor Metallurgical, Inc. , located at 300 Rye Street in South Windsor, Connecticut, at 9:00 a.m. After serving the warrant, the search team searched the following portions of the South Windsor facility in the following manner: 1. The search team collected samples as follows: a. Samples designated as numbers SWM-93-1, -lA and -1B were taken from a drum in lot number 74165 which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in Page 6 of 15 order, of one 250-milliliter sample container (for TCLP metals) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . b. Samples designated as numbers SWM-93-2, -2A, and -2B were taken from a 55-gallon drum in lot number 69418 which was located in the vicinity of -the dry pan evaporator in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals and pH) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . C. Samples designated as numbers SWM-93-3, -3A, and -3B were taken from a tray of black sludge in lot number 73461 which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , one 120-milliliter sample container (for reactive cyanide analysis) , : and one 150-milliliter sample container (for precious metals analysis) . d. Samples designated as numbers SWM-93-4, -4A, and -4B were taken from a drum in lot number 74155 which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals and pH) , one 120-milliliter sample container (for reactive cyanide analysis) , and one 150-milliliter sample container (for precious metals analysis) . e. Samples designated as numbers SWM-93-5, -5A, and -5B were taken from a drum in lot number 73946 which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 150-milliliter sample container (for precious metals analysis) , one 16-ounce sample container (for TCLP metals, flash point determination, and pH) , and one 120-milliliter sample container (for TCLP organics analysis) . f. Samples designated as numbers SWM-93-6, -6A, and -6B were taken from a drum in lot number 73821 which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals and pH) , one 120-milliliter sample container (for reactive cyanide analysis) , and one 150-milliliter sample container (for precious metals analysis) . g. Samples designated as numbers SWM-93-7 and -7A were taken from a drum in lot number 73797 which was located in the vicinity of the dry pan evaporator in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . h. Samples designated as numbers SWM-93-8 and -8A were taken from a drum in lot number 73805 which was located in the vicinity of the dry pan evaporator in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . Page 7 of 15 i. Samples designated as numbers SWM-93-9, -9A, and -9B were taken from a drum in lot number 74423 which was located in the container receiving storage area in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals and pH) , one 120-milliliter sample container (for reactive cyanide analysis) , and one 150-milliliter sample container (for precious metals analysis) . J . Samples designated as numbers SWM-93-10 and -10A were taken from a drum in lot number 74079 which was located in the .container receiving storage area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals), and one 150-milliliter sample container (for precious metals analysis) . k. Samples designated as numbers SWM-93-11 and -11A were taken from a drum in lot number 74431 which was staged in the vicinity of oven TR-5 in preparation for burning in that oven. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . 1. At the request of South Windsor Metallurgical, Inc. , duplicates of each of the samples identified in subparagraphs a. through k. above (i.e. "split" samples) were taken and provided to South Windsor Metallurgical, Inc. for its purposes. 2. The search team took a total of 12 photographs and 12 photographic slides of the materials identified in paragraph 1. above. Aside from these photographs and photographic slides, no other photographs or photographic slides were taken on this day of the search. 3. The search team requested, was provided copies of, examined, and made photocopies of the following records: a. hazardous waste manifests numbered CTF0076784, CTCO206402, CTF0076783, CTF0129190, CTF0129189, CTF0076779, CTF0129182, and CTF0235470. b. one three-page settlement for lot number 70397. After conducting the activities described above, the search team collected the equipment used to conduct the search and, along with the samples taken, placed them in DEP and EPA vehicles parked in the South Windsor facility' s parking lot. The team left the site at approximately 6:30 p.m. Thursday. September 30, 1993: The search team, consisting on this day of Senior Sanitary Engineer Mohamed Deria, Senior Sanitary Engineer Ross Bunnell, Sanitary Engineer Mary Hogan, Senior Environmental Analyst Paul Hassler, Senior Field Inspector Dwight Chernauskas, Field Inspector Mark Parker, Field Inspector Robert Garbauskas, Senior Field Inspector David Stokes, Field Inspector Mark Jepsen, and Field Inspector Diane Duva of DEP, and Environmental Scientist Warren Timothy Bridges and Environmental Engineer Daniel Granz of EPA, returned to South Windsor Metallurgical, Inc. , located at 300 Rye Street in South Windsor, Connecticut, at 9:00 a.m. After identifying ourselves to Page 8 of 15 security personnel at South Windsor Metallurgical, Inc. and indicating our intention to continue the search started the previous day, the search team searched the following portions of the South Windsor facility in the following manner: 1. The search team collected samples as follows: a. Samples designated as numbers SWM-93-12, -12A, and -12B were taken from a drum of scrubber salt solution with no lot number which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals and pH) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . b. Samples designated as numbers SWM-93-13, -13A, and -13B were taken as field duplicates samples of the above scrubber salt solution samples. These field duplicates were taken for sampling quality assurance/quality control purposes. c. Samples designated as numbers SWM-93-14, -14A, and -14B were taken from a drum of floor sweepings with no lot number which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . d. Samples designated as numbers SWM-93-15, -15A, and -15B were taken from a drum of dry baghouse dust with no lot number which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . f. Samples designated as numbers SWM-93-16, -16A, and -16B were taken from a drum of floor sweepings and related clean-up residues with no lot number which was located in the vicinity of the dry pan evaporator in the main building. The three samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , one 150-milliliter sample container (for precious metals analysis) , and one 120-milliliter sample container (for reactive cyanide analysis) . g. Samples designated as numbers SWM-93-17 and -17A were taken from a drum containing sweeps from lot numbers 73804, 73718, 74191, and 74215, which was located in row 68 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . Page 9 of 15 h. 'Samples designated as numbers SWM-93-18 and -18A were taken from a drum containing sweeps from lot number 74251, which was located in row 69 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . i. Samples designated as numbers SWM-93-19 and -19A were taken from a drum containing sweeps from lot number 73929, which was located in row 69 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . j . Samples designated as numbers SWM-93-20 and -20A were taken from a drum containing sweeps from lot number 74279, which was located in row 50 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . k. Samples designated as numbers SWM-93-21 and -21A were taken from a drum containing sweeps from lot numbers 73695, 73686, and 73705, which was located in row 59 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for - TCLP metals), and one 150-milliliter sample container (for precious metals analysis) . 1. Samples designated as numbers SWM-93-22 and -22A were taken from a drum containing sweeps from lot number 73775, which was located in row 60 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . m. Samples designated as numbers SWM-93-23 and -23A were taken from a drum containing sweeps from lot number 73788, which was located in row 51 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and. one 150-milliliter sample container (for precious metals analysis) . n. Samples designated as numbers SWM-93-24 and -24A were taken from a drum containing sweeps from lot number 74000, which was located in row 64 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . o. Samples designated as numbers SWM-93-25 and -25A were taken from a drum containing sweeps and bearing the identification number 12.08253, which was located in row 62 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . p. Samples designated as numbers SWM-93-26 and -26A were taken from a drum containing sweeps from lot number 73972, which was located in row 51 Page 10 of 15 in the settlement area in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . q. Samples designated as numbers SWM-93-27 and -27A were taken from a drum containing sweeps from lot number 73979, which was located in the settlement area in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . r. Samples designated as numbers SWM-93-28 and -28A were taken from a drum containing sweeps from lot number 73971, which was located in row 4 in the settlement area in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . s. Samples designated as numbers SWM-93-29 and -29A were taken from a drum containing sweeps from lot number 74073, which was located in row 22 in the settlement area in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . t. Samples designated as numbers SWM-93-30 and -30A were taken from a drum containing sweeps and bearing the identification number 12.08332, which was located in row 18 in the settlement area in the main building. The two samples consisted, in order, of one 16-ounce sample container (for TCLP metals), and one 150-milliliter sample container (for precious metals analysis) . u. Samples designated as numbers SWM-93-31 and -31A were taken from a drum containing sweeps from lot number 74169, which was located in row 1 in the settlement area in the main building. The two samples consisted, in order, of one 250-milliliter sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . V. A sample designated as number 101 was taken from a large evaporator tank which was part of the air pollution control system in the main building. This sample was divided into three sample containers, consisting of two 32-ounce sample containers (one for TCLP metals and one for TCLP organic compounds) , and one 150-milliliter sample container (for precious metals analysis) . W. A sample designated as number 102 was taken from the sump adjacent to oven TR-10, which sump was part of the air pollution control system in the main building. This sample was divided into three sample containers, consisting. of two 32-ounce sample containers (one for TCLP metals and one for TCLP organic compounds) , and one 150-milliliter sample container (for precious metals analysis) . X. A sample designated as number 103 was taken from the drum wash recirculating tank which was located in the southern portion of the main building. This sample was divided into four sample containers, consisting Page 11 of 15 of two 32-ounce sample containers (one for TCLP metals and one for TCLP organic compounds) , one 150-milliliter sample container (for precious metals analysis) , and one four-ounce sample container (for reactive cyanide analysis) . y. A sample designated as number 104 was taken of the sludge in a collection pan adjacent to the filter press associated with the dry pan evaporator in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . Z. A sample designated as number 105 was taken of the sludge in a collection pan adjacent to the filter press associated with ovens TR-5 and TR-2 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . as. A sample designated as number 106 was taken from a drum identified by Ed Fabrizio of South Windsor Metallurgical, Inc. , as containing sludge from the filter press associated with oven TR-10 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . bb. A sample designated as number 107 was taken from a drum used for collecting baghouse dust from the baghouse associated with oven TR-5 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . cc. A sample designated as number 108 was taken from a drum used for collecting baghouse dust from the baghouse associated with oven TR-10 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . dd. A sample designated as number 109 was taken from a drum identified by Ed Fabrizio of South Windsor Metallurgical, Inc. , as containing baghouse dust from the baghouse associated with oven TR-2 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . ee. A sample designated as number 110 was taken from a drum used for collecting baghouse dust from the baghouse associated with the dry pan evaporator in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container -(for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . ff. A sample designated as number 111 was taken from a drum identified by Ed Fabrizio of South Windsor Metallurgical, Inc. , as containing baghouse dust from the baghouse associated with the ball mills Page 12 of 15 in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . gg. A sample designated as number 112 was taken from a drum identified by Ed Fabrizio of South Windsor Metallurgical, Inc. , as containing baghouse dust from the baghouse associated with the main melting line in the main building. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . hh. A sample designated .as number 113 was taken of sweeps in a drum from lot number 73402, which was located in row 2 of the settlement area. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . ii. A sample designated as number 114 was taken of sweeps in a drum from lot number 74249, which was located in row 1 of the settlement area. This sample was divided into two sample containers, consisting of one 32-ounce sample container (•for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . jj . A sample designated as number 115 was taken of sweeps in a drum from lot number 73924, which was located in row 9 of the settlement area. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . kk. A sample designated as number 116 was taken of sweeps in a drum from lot number 74248, which was located in row 2 of the settlement area. This sample was divided into two sample containers, consisting of one 32-ounce sample container (for TCLP metals) , and one 150-milliliter sample container (for precious metals analysis) . 11. At the request of South Windsor Metallurgical, Inc. , duplicates of each of the samples identified in subparagraphs a. through kk. above (i.e. "split" samples) were taken and provided to South Windsor Metallurgical, Inc. for its purposes. 2. The search team took a total of 45 photographs and 12 photographic slides of the materials identified in paragraph 1. above. Aside from these photographs and photographic slides, no other photographs or photographic slides were taken on this day of the search. 3. The search team recorded approximately one minute of videotape during this day of the search. This videotape recording showed a dark exhaust that was venting out of a corroded pipe passing through the exterior wall of the main building in the vicinity of the loading dock. 4. The search team requested, was provided copies of, examined, and made photocopies of the following records: Page 13 of 15 a. hazardous waste manifests numbered MAG160570, CTF0092091, MAG129296, MAG129277, CTF0081158, MAG129468, CTF0129187, CTF0235472, CTF0174212, CTF0082435, and MAG129291, including the land disposal restriction notices and potential hazards notifications attached to these manifests. b. hazardous waste manifests numbered CTF0041488, CTF0293484, CTF0045792, CTF0003699, CTF0050713, CTF0235485, CTF0160719, CTF0160721, CTF0045791. and CTF0129180. c. excerpts of the Refining Receiving Log for the dates March 18, 1992, September 1, 1993, September 10, 1993, September 15 through 17, 1993, September 20 through 24, 1993, and September 27 through 29, 1993. d. one sample copy of a Refining Release form for release number 08253. e. copies of assay results for lots numbered 73402, 73404, 73695, 73929, 73924, 73972, 73788, 73449, and 73450. f. a contingency plan and another document entitled "Summary Report/Training for Safe Transportation of Hazardous Materials" which were on file at South Windsor Metallurgical, Inc.. g. hazardous waste manifests, bills of lading, acknowledgements of receipt, advice sheets, customer advices, Attleboro Sweeps Shipping Advices, refining invoices, process sheets, worksheets, potential hazards notifications, and related documents, totalling 94 pages, for lots number 74262, 74169, 74000, 73979, 73775, 74248, 74249, 74279, 73788, 73971, 73972, 73924, 73929, 74073, 74251, 73695, 73404, 73402, and 73804. 5. After conducting the activities described above, the search team collected the equipment used to conduct the search and, along with the samples taken, placed them in DEP and EPA vehicles parked at the site. The team left the site at 7:30 p.m. This concluded the search at _ South Windsor Metallurgical, Inc. The foregoing description constitutes all that has been done in connection with execution of the foregoing Administrative Search Warrant. The within and foregoing is the . original Administrative Search Warrant, Application for Administrative Search Warrant, Affidavit of Ross Bunnell, Affidavit of David Stokes, and Affidavit of Dwight Chernauskas, with a report of the doings of the Commissioner of Environmental Protection, his employees, agents, representatives, consultants, and assistants, any agents of employees of the Page 14 of 15 United States Environmental Protection Agency assisting the Commissioner, and any police officers assisting the Commissioner, hereon endorsed. / Z- David A. Nash, Director Waste Engineering & Enforcement Division Waste Management Bureau Department of Environmental Protection Page 15 of 15 ^� ty - - -- - -- --- --de �i lid 5�� EP cells metal refine likelysource 'of smell ® � no equipment with him to take a reading of refinery is responsible for the odor that The refinery, which denies that it's' the -By ANDREW NELSON the amount of elements in Wednesday's chil- Town Manager Jean E.Zurbrigen has called source, has asked the DEP for permit to Journal inquirer Staff writer ly air. a "source of great concern and distress for refine the circuit boards but was told that it Rose said his finding "doesn't mean that local residents." didn't need one because emissions would be SOUTH WINDSOR — The Department (South Windsor Metallurgical) is the only AIthough Carl Pavetto - chief of the minimal, according to Rose. of Environmental Protection today said a source"of the odor, adding that the DEP is DEP's air management bureau - said The company has hired T R C Rye Street metal refinery is the likely source continuing to monitor the area around the earlier this month that the source of the smell Environmental Consultants Inc. of East of a chlorine smell detected Wednesday in Famham Estates neighborhood. is burned circuit boards, the DEP is looking Hartford to test emissions from the refinery's the vicinity of a nearby neighborhood where . But comments from another DEP official into other potential sources, Sargis said stacks. _ residents have complained of a mysterious Wednesday also point to South Windsor Wednesday. In addition, a refinery lawyer stated in a odor for three years. Metallurgical as the likely source. South Windsor Metallurgical has been the letter.to the town that TRC will install a The DEP's Gary Rose said he identified -DEP air compliance official Robert Sarms South Windsor Metallurgical Inc.at 300 Rye revealed Wednesday that South Windsor focus of the DEP and town investigations. permanent wind-direction _and velocity St.as the source of a"distinct presence"of a Metallurgical burns computer circuit boards The refinery bums computer circuit-boards meter. TRC is slated to begin its work next chlorine, iodine and bromine odor he —what a high-ranking DEP official earlier, to extract the metals implanted on them, month. ._ .-:... smelled for several minutes at midday. this month identified as the cause of the according to Rose, who has said that the The DEP began monitoring the air around The odor wasn't`objectionable," accord- odor. - refinery's pollution-control is designed to Farnham Estates at the request of Rep. ing to Rose.But he admiited that he brought Still, Sargis too was reluctant to say the prevent objectionable emissions. 1 Kevin F. Rennie, R-South Windsor. The With Santa — Light o 3 Touch , '� / a _ C E fn �„ by Jack Whiteley,Sr. ' m > U If you're sick of paying taxes, 'there's a loophole:you can go to , prison. Poverty may be-no disgrace—but thars all you can say for it ' q Irs not doing what you like, but ° z 5. liking what you do thars the secret of happiness. -� t•i �� L •�r i�o� r ������, N sir` ii►I . ��� �J � �� ..� 1 Sunda - 12 noon-5 friend works two jobs-it's the ,i'i�f ��� \ M y only way he can keep up with those 12/3, 12/10, 12/17 _.. easy payments. '.:•� • • • * Ring in the Holidays••• ii 4 am-12 �r! Sunday, 12/2 , 8 What you call a miracle,the boss - ," calls a job. Ir n ,,. With.a Special Men s Jewelry Sale► /11 � .' cn DA's Groom�gg aP 7 Mctherthln sat• miracle Is the way the now carpet C fies reject dlrt V o& Pet Supply ore ..�., 0 you never knew ...• � ;�.'�rt�� 9 there was so much u for your et'' J P SINCE 1920 ��t���. Z 1 y [� Men's diamond channel set Contemporary gents ring (lt��' y" 11 a �l-.1�1 'r r) Cf K K FnfiP1A 1YTPPf'_ / 4, waeirlinn i%2nri M rt t_w-1 $1595 f3/A_ct t_w_l :1339 \I1flfL ` r tl ' T _ �v 2 - C44.,� ����f �'; S �t i ,�- 1 I- -�3'�S 11� ��� h'," ��� NOV-20-SS 11 = 58 FROM: BUREAU OF AIR MANGEMENT ID: 880 424 40B3 PAGE 2 STATE OF CONNLECTICUT VS. RANDY & RAR.MAN9 SOUTH WINDSOR METALLURGICAL, INC., M RATION CONSENT ORDER A. With the agreement of Handy & Harman, .south Windsor Metallurgical, Inc., and LFM Corporation ("Respondents"), the Commissioner of Environrnental Protection ("the Commissioner") finds: 1. Handy & Hann is a corporation which is or has been enraged in the manufacture of silver metal products at 1770 Ding's Highway in Fairfield, Connecticut ("the Fairfield facility"). 2. South Windsor Metallurgical, Inc., is a corporation which is or has been engaged in the processing and recycling of precious metal-containing wastes and materials at 300 Rye Street in South Windsor, Conmecticut ("the South Windsor facility") 3. LPM Corporation is a corporation which is or has been engaged in the transportation of precious metal-containing wastes and materials in or through the State of Connecticut. 4. South Windsor Metallurgical, Inc. operates the following equipment ("equipment") at the South Windsor facility: three reduction furnaces, one tray furnace (consisting of twelve units), three melting/induction furnaces (consisting of seven units), two gas furnaces, one hammermill, one dry pan evaporating furnace (consisting of eight units), and crushing, blending, powder-control and related processing equipment. South Windsor Metallurgical, Inc. has submitted air permit applications and an Intent-to-Test protocol to the Commissioner. 5. Pursuant to Section 22a-174.3(f) of the Regulations of Connecticut State Agencies ("RCSA"), South Windsor Metallurgical, Inc. operares the TR-2, TR-5 and TR- 10 reduction furnaces in a manner requiring a permit. 6. Pursuant to RCSA Section 22a-174-5(e)(2), the Commissioner may require the owner or operator of any stationary source to conduct emission tests of emissions; said emission tests shall be conducted in a manner satisfactory to the Commissioner. 7. Handy & Hannan has been a generator of hazardous waste at the Fairfield facility. NOV-20-56 11 : 68 FROM: BUREAU OF AIR MANGEMENT ID= 660 424 4063 PAGE 3 1 ' 8. South Windsor Metallurgical, Inc, has been a generator of hazardous waste at the South Windsor facility, and has engaged in the business of storing and treating precious metal-bearing chemical liquids or hazardous wastes. 9. L.PM Corporation has engaged in the business of transporting precious metal- bearing chemical liquids or hazardous wastes. 10. Based upon Department of Environmental protection inspections, the Commissioner issued the following two reports: a. Hazardous waste inspection report regarding the Fairfield facility dated May 10, 1996 (the "Fairfield Report"), and b. Hazardous waste inspection report regarding the South Windsor facility dated May 2, 1996 (the "South Windsor Report"), 11. On October 8, 1987 the Commissioner issued Order No. HM-459 to Handy +& Barman which required Handy & Harman to, among other things, "bring all waste handling procedures and facilities into compliance with the State's Hazardous Waste Management Regulations." 12. Handy & Harman did not request a .hearing on Order No. HM-459 within thirty days of the issuance of the order and the order therefore became a final order of the Commissioner. 13. On April 27, 1989 the Commissioner issued Order No. HM-606 to South Windsor Metallurgical, Inc., which required South Windsor Metallurgical, Inc. to, among other things, "bring all waste handling procedures and facilities into compliance with all applicable Connecticut Hazardous Waste Management Regulations." 14. South Windsor Metallurgical, Inc. did not request a hearing on Order No. HM- 606 within thirty days of the issuance of the order and the order therefore became a final order of the Commissioner. B. With the agreement of Respondents, the Commissioner, acting under Sections 22a-6, 22a-131, 22a-171, 22a-174, 22a-176, 22a-177, 22a-449, and 22a-454 of the Connecticut General Statutes, and. RCSA Sections 22a-174-3 and 22a-174-5, orders Respondents as follows: 1. Retention.of!Qogsultant. On or before thirty clays after issuance of this consent order, Respondents shall retain one or more qualified consultants acceptable to the Commissioner to prepare the documents and implement or oversee the actions required by this consent order and shall, by that date, notify the Commissioner y NOV-20-96 12: 00 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 4 in writing of the identity of such consultants. Respondents shall retain one or more qualified consultants acceptable to the Commissioner until this consent order is fully complied with, and, within ten days after retaining any consultant othee than one originally identified under this paragraph, Respondents shall notify the Commissioner in writing of the identity of such outer consultant. Respondents shall submit to the Commissioner a description of a consultant's education, experience and training which is relevant to the work required by this consent order within tent days after a request for such a description. Nothing in this paragraph shall preclude the Commissioner from finding a previously acceptable consultant unacceptable. 2. implication for Air Permits. On or before ninety (90) days after issuance of this Consent order, South Windsor Metallurgical, Inc. shall submit to the Commissioner complete revised air permit applications for the equipment described in paragraph A.4. above. The permit applications shall include, but not be limited to, the following, a. an Environmental Permit Application Package; b. a permit application fee of$100,00 for each permit application; and C. a schedule for the Commissioner's review and approval for completing emission testing of one reduction furnace, one dry pan evaporating furnace and one melting/induction furnace. d. At the tiart'te that this consent order is issued, the Commissioner views the facility as subject to regulation as an incinerator under RCSA Section 22a- 174-3(f)(1)(E). e. The revised applications shall be subject to Best Available Control T ology (BACT) review, unless a demonstration is made that a permit is re q iced and said demonstration is approved by the Commissioner, 3. Emission esting:, South. Windsor Metallurgical, fnc. shall conduct the emission testing in accordance with the schedule approved pursuant to paragraph B.2.c. above. Such emission testing and analysis shall include, but not be limited to, the following air pollutants: a. arsenic, antimony, barium, beryllium, mercury, cadmium, selenium, silver and lead; b, hexavalent chromium: C. nickel carbonyl; - 3 - NOV-20-66 12:00 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 5 d, formaldehyde; e. hydrogen cyanide; f, chlorine; g. hydrogen sulfide; h. nitrogen oxides; i. particulate matter less than or equal to 10 micrometers; j. benzene, ethyl benzene, xylenes, toluene, methylene chloride, 1, 2- c iichloroethane, tetrachloroethylene, trichloroethylene, carbon tetrachloride, methyl ethyl ketone and methyl isobutyl ketone; k. polycyclic aromatic hydrocarbons; 1. phenols; M. polychlorinated blphenyls; and n. dioxins, unless subsequently deleted by the Department upon a demonstration by South Windsor Metallurgical, Inc. 4. Intent-To-Test Protocol. South Windsor Metallurgical, Inc. shall submit a revised written intent-to-test ("ITT") protocol for the Commissioner's review and written approval not less than sixty (60) days prior to the emissions testing performed pursuant to paragraph B.3. of this Consent order. Said protocol shall be prepared and implemented in accordance with the following requirements: a. As,to the emission testing, the 117 protocol shall comply with the format as outlined on Department of Environmental Protection ("Department") Emission Test Guidelines and Form AE-404 and shall include, but not necessarily be limited to, the following information: i. Test methodology descriptions; ii. The worst case materials (i.e., materials resulting in highest emissions of the air pollutants referenced in paragraph B.3.) to be processed during the tests; iii. A description of methods to be used to determine subject equipment stack temperatures (degrees Fahrenheit); - 4 - MOV-20-BB 12:01 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4083 _ P_AGE 6 iv. A listing of process and control equipment operating parameter(s) proposed to be monitored; and v, A description of methods to be used to determine fuel feed rates. b. The ITT protocol shall provide that South Windsor Metallurgical, Inc. shall perform testing as specified in RCSA Section 22a-174-5, including _ operating the equipment at not less than ninety percent (90%) of its maximum capacity. C. South Windsor Metallurgical, Inc. shall perform all testing required by paragraph.8.3. in accordance with the approved ITT protocol. d. In conducting and performing the testing required by paragraph 8.3., and in analyzing the results of such testing, South Windsor Metallurgical, Inc. shall adhere to methods specified in RCSA Section 22a-174-5 and as approved by the United States Environmental Protection Agency ("EPA") and the Department. e. South Windsor Metallurgical, Inc. shall schedule the emissions testing so as to allow representatives of the Department to be present during such testing, and shall allow such representatives to conduct procedural and operational audits, South Windsor Metallurgical, Inc. shall notify the Department thirty (30) days in advance of the proposed date for testing, and shall cooperate with the Department in determining a mutually acceptable date for such testing. If the Department then notifies South Windsor Metallurgical, Inc. that the date is not acceptable, South Windsor Metallurgical, Inc. shall select an alternate date provided that it is- acceptable to the Department. f. South Windsor Metallurgical, Inc. shall submit a final test report for the review and written approval of the Commissioner with the results of said emissions testing and analysis not more than sixty (60) days (one hundred and twenty (120) days for dioxin, if required) after the completion of testing. g. Should the results of emission testing indicate failure to comply with applicable standards the Commissioner may take whatever actions he deems appropriate to bring the source into compliance including, but not limited to, requiring South Windsor Metallurgical, Inc. to take supplemental remedial action. The Commissioner's decision with respect to supplemental remedial action shall be deemed a final action for purposes of requesting a heauing before the Department of Environmental Protection limited to the necessity and appropriateness of the supplemental - 5 - NUV-20-BB 12:01 FROM: BUREAU OF AIR MANGEMENT ID: 880 424 4083 PAGE 7 remedial action. Within fifteen(15) days of performing any supplemental remedial actions, South Windsor Metallurgical, Inc. shall certify to the Commissioner in writing that the actions have been completed as approved. 5. Application for a Permit Pursuant to CGS Section 22a-454 and Compliance with Certain-Interim Rec;uiremerits_Pending Issuance of a Final Permit. a, Application for as Perm . On or before ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc;, skull submit for the Commissioner's review and written approval an application for permit under Connecticut General Statutes Section 22a,454. Such permit application shall meet the following requirements; i. It shall be filed on such forms as may be required by the Commissioner for that purpose. ii. It shall be accompanied by the application fee of $14,000.00 specified by the Commissioner for such a permit. iii. It shall include any attachments or other supplementary documents that may be required by the farms referenced in subparagraph is above, including but not limited to a Waste Analysis Plan (which may be referred to by South Windsor Metallurgical, Inc. as a Materials Evaluation Plan), an Inspection Schedule and Log, an Emergency Fuzz and Preparedness Document, Security Plans, Personnel TraiWng Records, Operating Records, a Closure Plan and Closure Cost Estimate, and Financial Assurance Documentation. All such attachments and supplementary documents shall be prepared in accordance with these forms, including but not limited to the document entitled "Instructions for Completing the Permit Application for Section 22a-454 CGS Waste Facilities," as most recently revised. South Windsor Metallurgical, Inc. shall use best efforts to submit a permit application which is in a complete and approvable form. In addition, South Windsor Metallurgical, Inc. shall timely respond to any notices of deficiency prepared by the Commissioner pursuant to the filing of such application, and shall in all other respects related to the processing of this application, act in good faith to ensure that the processing of this application is not unduly impeded or delayed as a result of any action or inaction on its part. - 6 - NOV-20-BB 12:02 FROM: BUREAU OF AIR MANGEMENT ID= 660 424 4063 FACE 6 b. Interim l ,equirernn_t_s. South Windsor Metallurgical, Inc. shall comply with the fallowing interim requirements until such time as the Commissioner issues the permit applied for pursuant to subparagraph a. above or until a final denial of such permit application has been finally adjudicated, provided that nothing in this consent order shall be deemed to be a permit or a waiver of any permit requirements that may be applicable under law: i. ProhibitiorL on the.Storage of Certain ;Materials. South Windsor Metallurgical. Inc. shall not store any secondary material on—site for longer than one year. In addition, South Windsor Metallurgical, Inc, shall not store any secondary material which has been determined not to be recyclable (such as pursuant to the procedures and policies required by subparagraph ii. below) for any Ionger than is necessary to arrange its return to the facility which generated it, or its shipment to an alternate facility designated by the generator. ii. _PIi?cedures for the Screening of Incoming Materials. On or before sixty (60)days after issuance of this consent order, South Windsor Metallurgical, Inc. shall prepare and submit to the Commissioner written procedures and policies designed to prevent the shipment to South Windsor Metallurgical, Inc:. by customers or by any facility owned or operated by handy & Harman, of: (1) ;recyclable materials conforming to Categories 1 or 3 in Attachment A; and (2) any recyclable materials which would be inappropriate for processing at the South Windsor Facility, including but not necessarily limited to pesticides, dioxins, polychlorinated biphenyls, explosives, pyrophorics, or radioactive materials. Such procedures and policies shall include but not be limited to a system for the maintenance of documentation regarding the hazardous constituents and precious metal content which is representative of each secondary material sent to the South Windsor Facility for recovery, and of each secondary material generated at the South Windsor Facility which is intended for further recovery, iii. Development of a Marking or Labeling System. On or before sixty (60) days after issuance of this consent order, South Windsor Metallurgical, Inc. shall: (1) develop and institute a system for the marking or labeling of all secondary materials generated or stored at the South Windsor Facility, which system shall ensure that the identity and accumulation time of each such secondary material may be readily and easily confirmed by 1DEP inspectors at any - 7 - NOV-20-SS 12:02 FROM: BUREAU OF AIR MANGEMENT ID: 960 424 40S3 PAGE 9 time during an inspection, and (2) submit to the Commissioner a report providing a detailed description and explanation of this system. iv. Dev. lnpment of a Comprehensive Invento[t Svstem. On or before ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc. shall: (I) develop and institute a single, centralized, computerized, tracking and inventory system to be used for each secondary material sent to the South Windsor Facility for recovery, as well as each secondary material generated at the South Windsor Facility which is intended for further recovery on- or off-site, and (2) submit to the Commissioner a report providing a detailed description and explanation of this system. Such system shall include, at a minimum, the substantive information In the refining receiving logs, refining invoices, assays, and refining releases described and included in the South Windsor Report. Such system shall be devised so as to be coordinated and cross-referenced with the labeling system required- by subparagraph iii. above, so as to allow for the identification of each and every secondary material present at the facility at any time during an inspection. Such system shall also be capable of providing on-line access to representatives of the Commissioner at any time during an inspection, and be capable of providing printouts of desired portions of the information, if requested by such a representative. V. t„Ipection Schedule and Log. On or before ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc. shall develop and institute a facility inspection schedule and log, and shall submit copies thereof to the Commissioner. Such schedule and log shall provide for, at a minimum, weekly inspections of all container storage areas and all processing equipment, and monthly inspections of all safety and.emergency equipment that are important to preventing, detecting, or responding to environmental or human health hazards. In addition, the inspection schedule and lag shall meet the requirements of 40 CFR 265.15. vi. Contingency Plan. On or before ninety (9Qj days after issuance of this consent order, South Windsor Me lurgx al, Inc. shall revise its Contingency Flan and shall sub it c ies thereof to the Commissioner and to all local olic departments, fire departments, hospitals, and local emergency response teams that may be called upon to provide emergency services. Said revised - 8 NOV-20-96 12 :03 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 10 Contingency Flan shall accurately reflect the current equipment, layout, operations, and personnel of the South Windsor facility, and shall meet the requirements of 40 CPR, 265..52 and 265,56. vii. Personnel Train i On or before ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc. shall effect the following changes to its personnel training program, and shall submit documentation of such changes to the Commissioner- (A) South Windsor Metallurgical, Inc. shall ensure that all personnel employed in positions involving materials handling or processing or emergency response are fully trained, and that any new employees in such position; do not work unsupervised until fully trained. In addition, South Windsor Metallurgical, Inc. shall provide annual refresher training for all such personnel. (13) South Windsor Metallurgical, Inc. shall retain records of the training provided pursuant to subparagraph (A) above. (C) South Windsor Metallurgical, Inc. shall revise its written description of personnel training in the following ways; (1) expand the scope of training beyond transportation related issues, (i.e., fully address on-site waste management), (2) include training in contingency plan procedures, and (3) in all other ways comply with the requirements of 40 CFR 265.16, viii. Documentation of Off.-Site Shipment. South. Windsor Metallurgical, Inc. shall take the following steps with regard to precious metal-bearing materials generated at the facility and shipped tiff-site, other than ingot and bar: (A) Until such time: as a variance is granted pursuant to 40 CER 260.30, South Windsor Metallurgical, Inc, shall export such materials only to facilities within member countries of the Organization for Economic Cooperation and Development (OECD) and in compliance with such obligations as it has under OECD Council Decision 92/39 - 9 - NOV-20-98 12:03 FROM: BUREAU OF AIR MANGEMENT ID: SS0 424 40S3 PAGE 11 regarding trans-frontier movement of waives intended for recovery. (B) Within ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc. skull apply for a variance pursuant to 40 CFR 260.30. ix. Compliance with Generator Requirements for Certain Materials Generated On-Site. Beginning on or before ninety (90) days after issuance of this consent order, and continuing thereafter, South Windsor Metallurgical, Inc. shall comply with the following requirements with respect to any recyclable materials generated on- site which conform to Category 3 in Attachment A: (A) For such materials stored in containers, the following requirements: the container storage requirements of 40 CFR 262,34(a), as incorporated by RCSA Section 22a- 449(c)-142 with specified changes, including but not limited to the ninety-day accumulation limit; the container storage requirements of 40 CFR 265 Subpart I, as incorporated by RCSA Section 22a-449(c)-105; and, the aisle space requirements of 40 CFR 265.35, as incorporated by RCSA 22a-449(c)-105. (B) The biennial report requirements of 40 CFR 262.41 as incorporated by RCSA Section 22a-449(c)-102 with specified changes. X. Other Ma erial s Management Reaui.rements. Beginning on or before the date of issuance of this consent order and continuing thereafter, South Windsor Metallurgical, Inc, shall not: (,A.) Manage any secondary materials in tanks unless.such tanks are installed and maintained in accordance with sound engineering practice and are (1) located indoors, or (2) stared on an impervious surface and provided with secondary containment sufficient to contain the volume of the tank: or (Br) Store outdoors; any secondary materials or any decomrinissioned or obsolete processing equipment which has not been thoroughly decontaminated, unless such materials or equipment are stared on an impervious surface - 10 - NOV-20-96 12:04 FROM: BUREAU OF AIR MANGEMENT ID: 960 424 4063 PAGE 12 and provided with secondary containment sufficient to contain any releases therefrom. xi. Filing and Retention of One-Time Notices. On or before ninety (90) days after issuance of this consent order, South Windsor Metallurgical, Inc. shall place the following one-time notices in its operating record, and submit copies thereof to the Commissioner: (A) The notice required by 40 CFR 268.7(a)(6). (B) The notice required by 40 CFR 266. I00(t)(1) and, if applicable, 266.100(c)(1)(i). After filing such notices, South Windsor Metallurgical, Inc. shall retain them in the facility operating record continuously thereafter. 6. COMRliance Schedule Related 5peciFcally to LPM Coryoration. LPM Corporatism shall, with respect to all of its operations within the State of Connecticut, comply with Connecticut General Statutes Section 22a-454, and with RCSA Sections 22a-449(c)-11, and 22a-449(c)-103. In particular, but not by way of limitation, LPM shall do the fallowing: a. LPM Corporation shall comply with the manifest requirements of RCSA Section 22a-449(c)-103(a)(1), incorporating 40 CFR 263 Subpart B for each and every non-recycled hazardous waste it transports, and for each and every recyclable material it transports which conforms to Categories 1, 2, 3, or 4 in Attachment A. b. LPM Corporation shall comply with the monthly reporting requirements detailed in its transporters permit for each and every non-recycled hazardous waste it transports, and for each and every recyclable material it transports which conforms to Categories 1, 2, 3, or 4 as defined in Attachment A. C. LPM Corporation shall not store waste oil or petroleum or chemical liquids, or hazardous waster at any location without having first received a permit from the Commissioner pursuant to Connecticut General Statutes Section 22a-454, which permit specifically allows such storage. 7. Co 2lliance Schedule Related Specifically to Handy and Harman and the Fairfe�ld Facility. a. Plan for Future Compliance_. On or before ninety (90) days after issuance of this consent order, Handy & Harman shall submit for the - 11 - NOV-20-BB 12:04 FROM: BUREAU OF AIR MANGEMENT ID: B6O 424 4063 PAGE 13 Commissioner's review and written approval a plan detailing actions and/or operational changes to ensure future compliance with the requirements applicable to handy & Harman identified in the Fairfieid Report. "Phis plan shall include at least the following elements: i. An inventory of all the secondary materials generated at the Fairfield Facility, A secondary material, for the purposes of this consent order, shalt be defined as any material which is not a primary product and which is disposed or reclaimed, including any spent materials, sludges, by-products, off-specification commercial chemical products, and scrap metals, as such terms are defined in 40 CFR 260,10, 261.1, or 261.2. ii. A hazardous waste determination, with supporting documentation, for each secondary material listed in subparagraph A above. Each such hazardous waste determination shall be conducted in accordance with 40 CFR 262,11. iii. A determination, with supporting documentation, specifying the: regulatory category of each such secondary material, in accordance: with the definitions in Attachment A. For any materials for which the determination may vary from one shipment to the next, this documentation shall list each possible regulatory category, and shall clearly identify the factors which brim about this variability. iv, Procedures and policies to be followed that will ensure that cacti secondary material, is handled in accordance with all applicable hazardous waste requirements, In addition, said procedures and policies shall specifically ensure that secondary materials corresponding to Categories 4, S, or 6 in Attachment A are not stored in excess of one year, and that secondary materials corresponding to Categories 1, 2, or 3 in Attachment A are not stored in excess of the applicable generator accumulation time limit. V. A system for the labeling and identification of all secondary materials generated and stored at the Fairfield facility, which system shall ensure that the identity and accumulation time of each secondary material in storage at the Fairfield. Facility may be readily and easily confirmed by a representative of the Commissioner at any time during an inspection. Saki system shall be devised so as to be coordinated and cross-referenced to the inventory and determinations required by subparagraphs i, through iii. above. - 12 - NOV-20-BB 12:05 FROM: BUREAU OF AIR MANGEMENT ID, 860 424 4083 PAGE 14 vi. The plant required by this subsection B.7,a shall not apply to materials generated at the Fairfield Facility which are returned to the original process from which they are generated without first being reclaimed. Within fifteen (15) days after the Commissioner approves such plan, Handy & Harman shall carry out the plan and maintain it in full effect thereafter. b. Closure Roguirements. On or before ninety (90) days after issuance of this consent order, Handy & Harman shall perform an investigation of past operating practices at the Fairfield Facility and shall submit for the Commissioner's review and written approval, a report detailing: i. Handy & Harman's findings with respect to the historic use of any and all storage areas discussed in the "Closure" section of the RCRA checklist comprising Section 1 of the Fairfield Report, and in violations E.22. and E.33. through E.35. in the List of Violations comprising Section 2 of the Fairfield Report. In particular, but not by way of limitation, these findings shall summarize any available information indicating that any such areas were or were not used after November 19, 1980 for any of the following purposes: (1) the storage of any non-recycled hazardous waste for greater than 90 days; (2) the storage of any recyclable materials conforming to Categories 1, 2, or 3 in Attachment A for greater than 90 days; and (3) the storage of any recyclable materials conforming to Categories 4, 5, or 6 in Attachment A for greater than one year. S. Revisions to &qu'red D%uments. Respondents may request that the Commissioner approve, in writing, revisions to any document approved hereunder in order to matte such document consistent with law or for any other appropriate reason. 9. Full comp i. ce. Respondents shall not be considered in full compliance with this consent order until all actions required by this consent order have been completed as approved and to the satisfaction of the Commissioner. 10. Status of Orders No. HM-459 and HN -606. Full compliance with this consent order shall also constitute full compliance with Orders Nos. HM-459 and HMy 606. 11.. No admission of liability. Nothing in this consent order shall be considered to be an admission of liability by the Respondents. This consent order shall not be - 13 � NUV-20-66 12:06 FROM: BUREAU OF AIR MAMGEMEMT IO: 880 424 4063 PAGE 15 admissible as evidence in any proceeding in any forurn, except that it shall be admissible in a proceeding initiated by the Commissioner to enforce any of the: provisions of this consent order. 12. Samplinj and sample any. All sampling and sample:: analyses which are required by this consent order shall be subject to the following teens and conditions: a. Except as provided by paragraphs 13.3. and 13.4. above, and except for sampling to determine the precious metals content of materials, all sample analyses which are required by this consent order and all reporting of such sample analyses shall be done by a laboratory certified by the I.J.S. Environmental Protection Agency and/or the Connecticut Department of Public Health and Addiction. Services for such analyses, b. All sampling and sample analyses performed unclear this order for the: purposes of hazardous waste determination shall be performed in accordance with the IPA ,guidance document number SW-846, 'Pest Methods for Evaluating Solid Waste--Physical/Chemical Nfethods. c. Analysis for precious metals content shall be conducted in accordance with fire assay methodology as described. in A Textbook of Fire Assayirng (3rd ed.) (Sugbee; Colorado School of Mines Press, 1940) and Fire Assaying (Shepard and Dietrich; McGraw Hill; 1940), and by a Iaboratory capable of performing such methodology. d. Unless otherwise specified by the Commissioner in writing, the value of each parameter shall be reported to the maximum level of precision and accuracy specified in the applicable protocol, and if no such level is specified, to the maximum level of precision and accuracy passible within the applicable protocol. e. All other sampling and sample analyses performed under this:order shall be performed in accordance with procedures specified or approved in writing by the Commissioner. 13. Approvals. Respondents shall use best efforts to subunit to the Commissioner all documents required by this consent order in a complete and approvable form. If the Commissioner notifies any of the Respondents that any document or other action is deficient, and does neat approve it with conditions or modifications, it is deemed disapproved, and said Respondent shall correct the deficiencies and resubmit it within the time specified by the Commissioner or, if no time is specified by the Commissioner, within thirty days of the Commissioner's notice of deficiencies. In approving any document or other action under this consent - 14 - NOV-20-SS 12:06 FROM: BUREAU OF AIR MANGEMENT ID: 880 424 4063 PAGE 16 order, the Commissioner may approve the document or other action as submitted or performed or with such conditions or modifications as the Commissioner deems necessary to carry out the purposes of this consent order. Nothing in this paragraph shall excuse noncompliance or delay. 14. Definitions. As used in this consent order, "Commissioner" means the Commissioner or an agent of the Commissioner. The date of "issuance" of this consent order is three business days after the date the order is deposited in the mail or personally delivered, whichever is earlier. 15. bates. The date of submission to the Commissioner of any document required by this consent order shall be the date such document is received by the Commissioner, The date of any notice by the Commissioner under this consent order, including but not limited to notice of approval or disapproval of any document or other action, shall be the date such notice is personally delivered or the date three business days after it is mailed by the Commissioner, whichever is earlier. Except as otherwise specified in this consent order, the word "stay" as used in this consent order means calendar day. Any document or action which is required by this consent order to be submitted or performed by a date which falls on a Saturday, Surd "`ox:a-,6onnecticut or federal holiday shall be submitted or performed on or bef ref` h �e, n xt day which is not a Saturday, Sunday, or Connecticut or federal h 16. Notification of nonco gli nt . In the event that any of the Respondents becomes aware that it did not, or may not comply, or did not or may not comply on time, with any requirement of this consent order or of any document required hereunder, such Respondent shall immediately notify the Commissioner and shall take all reasonable steps to ensure that any noncompliance or delay is avoided or, if unavoidable, is mirvmized to the ,greatest extent possible. In so notifying the Commissioner, any such Respondent shall state in writing the reasons for the noncompliance or delay and propose, for the review and written approval of the Commissioner, dates by which compliance will be achieved, and such Respondent shall comply with any dates which may be approved in writing by the Com=issioner, Notification by such Respondent shall not excuse noncompliance or delay, and the Commissioner's approval of any compliance dates proposed shall not excuse noncompliance or delay unless specifically so stated by the Commissioner in writing. 17, Cerci.ftcaton...caf.. tocurnents. Any document, including but not limited to any notice, which is required to be submitted to the Commissioner under this consent order shall be signed by a responsible corporate officer of each Respondent or a duly authorized representative of such officer, as these terms are defined in section 22a-430-3(b)(2) of the RCS ► and by the individual or individuals responsible for actually preparing such document, each of whom shall certify in - 15 - NOV-20-SS 12:07 FROM: BUREAU OF AIR MANGEMENT ID: eS0 424 40S3 PAGE 17 writing as follows; 1 have personally examined and am familiar with the information submitted in this document and all attachments and certify that based on reasonable investigation, including my inquiry of those individuals responsible for obtaining the information, the submitted information is true, accurate and complete to the best of my knowledge and belief, and [ understand that any false statement made in this document or its attachments may be punishable as a criminal offense." 18. Noncompliance. Except as specifically provided otherwise in this consent order, this consent order is a final order of the Commissioner with respect to the matters addressed herein, and is nonappealable and immediately enforceable. Failure to comply with this consent order may subject Respondents to injunction and penalties under Chapters 439, and 445 or 446k of the Connecticut General Statutes. 19. False statements. Any false statement in any information submitted pursuant to this consent order may be punishable as a criminal offense under Section 22a-438 or 22a,-131a of the Connecticut General Statutes or, in accordance with Section 22a-6, under Section 53a-157 of the Connecticut General Statutes. 20. Notice of transfer liability of Respondents and others. Until Respondents have fully complied with this consent order, any of the Respondents shall notify the Commissioner in writing no later than fifteen days after transferring all or any portion of the operations which are the subject of this consent order, the site or the business, or obtaining a new mailing or location address. Respondents' obligations under this consent order shall not be affected by the passage of title to any property to any other person or municipality. Any future owner of the site may be subject to the issuance of an order from the Commissioner. 21. Commissigner's powers. Nothing in this consent order shall affect the Commissioner's authority to institute any proceeding or take any other action to, prevent or;abate violations of law, prevent or abate pollution, recover costs and natural resource damages, and to impose penalties for violations of law which are willful or criminally negligent or for which penalties have not been specifically provided in this consent order, including but not limited to violations of any permit issued by the Commissioner. If at any time the Commissioner determines that the actions taken by Respondents pursuant to this consent order have not successfully corrected all violations, the Commissioner may institute any proceeding to require Respondents to correct violations. 22. Respondents' obligations under law. Nothing in this consent order shall relieve the Respondents of other obligations under applicable federal, state and local law. - l6 - NOV-20-BE 12.07 FROM: BUREAU OF AIR MANGEMENT ID= 88O 424 4083 PAGE 16 23. No assurance by Commissioner. No provision of this consent order and no action or inaction by the Commissioner shall be construed to constitute an assurance by the Commissioner that the actions taken by Respondents pursuant to this consent order will result in compliance. 24. Access to site. Any representative of the Department of Environmental Protection may enter any of the Respondents' sites during regular business hours without prior notice for the purposes of monitoring and enforcing the actions required or allowed by this consent order. 25. No effect on riizhts of other persons. This consent order shall neither create nor affect any tights of persons who or municipalities which are not parties to this consent order. 26. Notice to Commissioner of changes. Within fifteen days of the date that any of the Respondents becomes aware of a change in any information submitted to the Commissioner under this consent order, or that any such information was inaccurate or misleading or that any relevant information was omitted, such Respondent shall submit the correct or omitted information to the Corrunissioner. 27. Submission of documents. Any document required to be submitted to the Commissioner under this consent order shall, unless otherwise specified in writing; by the Commissioner, be directed to: a. With Respect to Connecticut-regulated or hazardous waste matters_ Mr. Ross Q. Bunnell Waste Management Bureau--Engineering and Enforcement Division Department of Environmental Protection 79 Elm Street Hartford CT 06106-5127 b. With Respect to air management matters: Ms. Wendy Jacobs Air Management Bureau—Engineering and Enforcement Division Department of Environmental Protection 79 Elm Street Hartford CT 06106-5I27 28. Joint and several liability. Respondents South Windsor Metallurgical, Inc. and Handy & Harman shall be jointly and severally liable for compliance with this consent order. 17 - NOV-20-SS 12 :06 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 19 29. Potential Future Transfer .of the South.._Windsor Facility. The parties acknowledge that the transfer of the ownership and operation of the South Windsor facility is presently in negotiation, with closure anticipated within sixty days, Respondents Handy & Harman and South Windsor Metallurgical, Inc. shall ensure, prior to the consummation of the anticipated transfer, should it occur, that the transferee of the South Windsor facility will, at the time of closing, assume all liabilities, obligations and responsibilities under this consent order regarding ongoing operations at the South Windsor facility as a direct obligation to the State of Connecticut in, a consent order identical to (and limited to) the portions of this consent order pertaining to the South Windsor facility (with the exceptions of paragraph 28 (regarding joint and several liability), which shall not be effective as to the transferee, and that the names South Windsor Metallurgical, Inc. and Handy & Harman may be replaced). Upon issuance of such a further consent order, and upon a demonstration to the satisfaction of the Commissioner that the transferee is capable of complying with the terms of same, and notwithstanding paragraph 20 of the present consent order, the liabilities, obligations and responsibilities of Handy &Harman and South Windsor Metallurgical, Inc. under the present consent order with respect to the South Windsor facility shall terminate. Respondents consent to the issuance of this consent order without further notice. The undersigned certify that they are fully authorized to enter into this consent order and to legally bind the Respondents to the terms and conditions of the consent order. 18 NOV-20-96 12 : 09 FROM: BUREAU OF AIR MANGEMENT ID: 960 424 4063 PAGE 20 HAMx & HARMAN Its: Vice President, General, Counsel and Secretary .duly 3, 1996 NUV-20-BB 12:06 FROM: BUREAU OF AIR MAMGEMENT ID: 660 424 4063 PAGE 21 SOUTH WINDSOR METALL,LMGICAL, INC. I By Its: , — 20 NOV-20-96 12: 09 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 22 By ISee tarp—Tree urer DaW: July, 3, 1996 f 21 NOV-20-96 12: 10 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 23 Issued as a final order of the Commissioner of Enviro=ental Protection on i 1996, Sidney , lhrook Commissioner ORDER NO, HM- 8 a 3 22 NOV-20-96 12: 10 FROM: BUREAU OF AIR MANGEMEMT ID: 660 424 4063 PAGE 24 ATT.,ACHMENT A Definition of certain terms used in this consent order "Category 1" materials are the following secondary materials: (1) characteristically hazardous or listed hazardous commercial chemical products, characteristically hazardous sludges, or characteristically hazardous by-products being reclaimed which do not contain recoverable amounts of precious metals; or, (2) characteristically hazardous or listed hazardous spent materials, listed hazardous sludges, and listed hazardous by-products being reclaimed which do not contain recoverable amounts of precious metals; or, (3) solid wastes which are mixed with, contain, or are derived from listed hazardous spent materials, listed hazardous sludges, or listed hazardous by-products which mixtures are being reclaimed, and which mixtures do not contain recoverable amounts of precious metals; or, (4) materials subject to the exemptions of 40 CFR 261.2(e), which do not contain recoverable amounts of precious metals. "Category 2" materials are the following secondary materials: (1) characteristically hazardous or listed hazardous spent materials, listed hazardous sludges, or listed hazardous by-products which are being reclaimed, and which contain economically significant amounts of precious metals, and which have been accumulated speculatively at one of the Respondents' locations; or (2) solid wastes which are mixed with, contain, or are derived from listed hazardous spent materials, listed hazardous sludges, or listed hazardous by-products, which mixtures are being reclaimed, and which mixtures contain economically significant amounts of precious metals, and which mixtures have been accumulated speculatively at one of the Respondents' locations. "Category 3" materials are the following secondary materials: (1) characteristically hazardous or lasted spent materials, listed hazardous sludges, or listed hazardous by-products which are being reclaimed, and which do not contain economically significant amounts of precious metals, and which do contain recoverable amounts of precious metals. or, (2) solid wastes which are mixed with, contain, or are derived from listed hazardous spent materials, listed hazardous sludges.. or listed hazardous by-products, which - 23 - NOV-20-96 12: 10 FROM: BUREAU OF AIR MAMGEMENT ID: 660 424 4063 PAGE 25 1 mixtures are being reclaimed, and which mixtures do not contain economically significant amounts of precious metals, and which mixtures do contain recoverable amounts of precious metals; or, (3) characteristically hazardous or listed hazardous commercial chemical products, characteristically hazardous sludges, characteristically hazardous by-products, or materials subject to the exemptions of 40 CFR. 261.2(e), which have been accumulated speculatively at one of the Respondents' locations. "Category 4" materials are the following secondary materials; (1) characteristically hazardous or listed hazardous spent materials, listed hazardous sludges, or listed hazardous by-products which are being reclaimed, and which contain economically significant amounts of precious metals, and which have not been accumulated speculatively at one of the Respondents' locations; or, (2) solid wastes which are mixed with, contain, or are derived from listed hazardous spent materials, listed hazardous sludges, or listed hazardous by-products, which mixtures are being reclaimed, and which mixtures contain economically significant amounts of precious metals, and which mixtures have not been accumulated speculatively at one of the Respondents' locations. "Category 5" materials are the following secondary materials: (1) scup metals being reclaimed, except for such scrap maetals which are ignitable or reactive, per 40 CFR 261.21 and .23, respectively. "Category 6" materials are the following secondary materials: (1) characteristically hazardous sludges or by-products which are being reclaimed, and which contain recoverable amounts of precious metals, and which have not been accumulated speculatively at one of the Respondents' locations; or, (2) characteristically hazardous or listed commercial chemical products which are being reclaimed, and which contain recoverable amounts of precious metals, and which have not been accumulated speculatively at one of the Respondents' locations; or, (3) solid wastes which are mixed with, contain or are derived from listed hazardous commercial chemical products, which mixtures are being reclaimed, and which mixtures contain recoverable amounts of precious metals, and which mixtures have not been accumulated speculatively at one of the Respondents' locations; or, 24 NUV-20-96 12 : 11 FROM: BUREAU OF AIR MANGEMENT ID: 880 424 40S3 PAGE 26 (4) materials subject to the exemptions of 40 CF"R 261.2(e). which contain recoverable amounts of precious metals, and which have not been accumulated speculatively at one of the Respondents' Iocations. The term "contain" as used herein with respect to precious metal content of materials handled by the Respondents, means to possess, as documented by representative sampling of said materials (which may include representative sampling over time). The term "secondary material" as used above is defined in subparagraph 7.a.i. of this consent order. The terms "reclaim," "spent material," "sludge," "by-product," "commercial chemical product," and "scrap metal" as used above are defined in 40 CFR 260.10, 261.1, and/or 261.2. The term "recoverable amounts of precious metals" as used above means amounts which are technologically capable of being reclaimed, and are measurable and quantifiable. The term "economically significant amounts of precious metals as used above means amounts which, based on representative sampling(which may include representative sampling over time), are sufficient to cover all costs of reclamation, including but not limited to pre-processing sampling and analysis, transportation, processing, assay, refsning, and the management of any processing residues. The term "accumulated speculatively" as used above is defined in RCSA Section 22a-449(c)- 100(c). 25 - NUV-ZW-UW 12: 11 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4063 PAGE 27 VrrVJ°!la RAIL 19.44 r-'-L 09u 4�V4_1440 mmon ^\ SM TeraCXionfrerrid Ava., Rya.IVY 103W J p�(y14)92i-"400 rAX-(914)GI5-4AC6 July , i998 Sidney Holbrook, Commissioner Dapa t ent of Environmental Protection 79 Eim at vwA H>arftrd, CT 06106 lam'Commissioner Holbrook: Enclosed is Handy & Harman's check number 013585 in the amount of $2:50,000. to be applied as foliOwe: 1, $100,000 to be granted by the Department rf Environmental Protection to the Friends of Conneubcut State Parks for the purpose cif enhancing Connecticut state parks; an iW 2. WOW tv be allocated to th+s Long Island Education Rem"aSound Fund, of hrch Fund fur $5a0,00() shall ba ailocated to the S+ nda-t the purpose of gents for high school environmental science educ stivn. Very WY Yours, Handy & Harrnarr, T By: Paul E. n Vice Prgsident, Generai COu"sel and Secretary —ti is :7i` :1'��U<< F i1OCrfOrSO>!u�iCl47e�s Tt1Ar�7�r %ul r,wtob and all"• per"s d sjj, 6f_Odd Wd pl&rlum NOV-20-SS 12= 12 FROM: BUREAU OF AIR MANGEMENT ID= B60 424 40S3 PAGE 28 LA-S Ic. S'TAl'E OF CONNEC'TICUT VS. HANDY & HARMAN, SOUTH'VVMSOR METALLURGICAL} INC., CONSENT ORDER MODIFICATION Pursuant to Section 4-18la(c)of the Connecticut General Statutes and Section 22a-3a-6(c} )of the Regulations of Connecticut State Agencies,the Commissioner of Environments,Protection("the CotritnlSsionen hereby mo 'dues Consent Order number HM-803 signed by the Commissioner on July 3, 1996{"the Consent Orderl as follows,to correct three clerical errors; A. Paragraph 13.2.e. of the Consent Order is modified to read as follows: "'Me revised applications shall,be subject to Best Available Control 'technology(BAC'1) review,unless a demonstration is made that a permit is not required and said demonstration is approved by the Commissioner." B. Paragraph B.5.b.vi. of the Consent Order is modified to read as follows; ".CgjjdnZCncj Ehla. On or before nicety(90)days after issuance of this consent order,South Windsor Metallurgical,Inc.shall revise its Contingency Plan and shall submit copies thereof to the Commissioner and to all local police departments, fire departments, hospitals, and local emergency response teams that may be called upon to provide emergency services. Said revised Contingency Plan shall accurately reflect the current equipment, layout, operations,and personnel of the south Windsor facility,and shall meet the requirements of 40 CFR 265,52 and 265.56." C. Paragraph B.15. of the Consent Order is modified to read as follows; "Dates. The date of submission to the Commissioner of any document required by this consent order shall be the date such document is received by the Commissioner. The date of any notice by the Commissioner under this consent order, including but not limited to notice of approval or disapproval of any document or other action, shall be the date such notice is personally delivered or the slate three business days after it is mailed by the Commissioner, whichever is earlier. Except as otherwise specked in this consent order, the word "day" as used in this consent order means calendar day, Any document or action NOV-20-SS 12 : 12 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 4OUJ r which is req=' d by this consent order to be submitted or performed by a date which falls f on a Saturday,Sunday,or a Conne fi"or federal holiday shall be submitted or performed "r on or before the next day which is not a Saturday, Sunday, or Connecticut or federal holiday." ,All other portions of the Constnt Order shalt re== uaChmged unless further ordered by the Commissioner. lssueci as a feral order of the Commissioner of Environmental Protection on � 1996. �20 Si a olbmok Commissioner ORDER NO.MI-803 MOD FIEU .. .�,t,• �„ ,.•s:x •• ,'�. r':t.'Y% :. ,y. ./' 'r�s;•'t•.�,,w e ",1 y !"' 'r'.• '�;•,P'T"',2•,'�f;.j°';/„`r'.eQ"r�i..:r.• •' r ": 11 ' , -2- NOV-20-96 12: 13 FROM: BUREAU OF AIR MANGEMENT ID: 660 424 40B3 PAGE 30 0 STATE OF CONNECTICUT D,FPA.RTMENTI OF ENVIRONMENTAL PROTECTION .. 79 ULM STREET HAATFORD, CONNECI'ICUT 06106 J. Holbrook F#O�iE M 203 424.3001 :.�.� � ::... Sidney Commissioner July 18, 1996 Brian r"recra n, Esq.' Robinson & Cole OOIG CpmII,2CrCIRI plaza r ,�.'�•.,.,;'� F.,'. ,. 280 Trumbull Street ' Hartford CT 06103-3597 Dear Attorney Freeman: I am in receipt of your letter dated July 10, 1996 regarding three typographical err 1n Cods nt Order M 1-803, which was signed by me on July 3, 1996. After reviewing your submittal,, cncwt with your assessment that these are typographical errors, and that they should be corctcd. .: -1S1a c latians i f 1 Therefore, pursuant to Connecticut General Statutes Section ( ) and Regu Cpnmecticut State Agencies Section 220a-6(c)(3), which permit me td correct "clerical errors ,,f. in administrative orders, I am correcting these errors per your request. Enclosed is My , .modifying Consent Order M4-803 accordingly. - '! w Sidney . Holbrook "'tommissioner " .;.h,rd: Robert S. Teitelman Assistant Attorney Cenerai i`,l ' MJ ,y�Vw►L«i,. ' 1,• , •( � •{.'I;:,,� .e ���"�.t' �Z�� H•a��ret.6'Y ,tiff I`��� ��r uJ6.1� ---- i 4 1 �' i .)-. � I� 1 Y <.s , j ti j STATE OF CONNECTICUT I.D. ACCESSION NO. ACCOUNT O. Department of Health Services _ ROUTE Laboratory Division ° R:51 1601 tt 2 2 0 9 S 06 0 74 � 10 Clinton St. P.O. Box 1689 INFORMATION Hartford, CT 06144 "TELEPHONE: (203) 566-5063 SOUTH WINDSOR STIR EAM � �lI5C. i3HERT DEPTULAo SANITARIAN SOUTH WINDSOR 1540 SULLIVAN AVE TOWN HALL COLLECTED RECEIVED REPORTED SOUTH WINDSOR . CT 06074 06/21/69 05/21l89 07l05/89 L 11 : 00 11 : 59 09:55, FINAL REPORT SrRFAM TAR SLUDGE j t SAMPLE OF: SLU-'DE) CJLLECTED JY: RD ) t COMPOSITE: NO ) t NO, KIND OF BOTTLES: 1 iaL) E HYOROCAR8ON3 SIGMA 20-U0 FID FIB}) BENZENE 1 (AREA) uG/L t SAMPLE SHOWS TRACE LEVELS OF EARLY ELUTING UNIDENTIFIED) t COMPONENTS CHARACTERISTICALLY FOJND IN ORGANIC MEDIA) *** THIS IS A FINAL REPORT. ** ORM NO.OL-6A f n STATE OF CONNECTICUT P- I.D. ACCESSION NO. ACCOUNT NO. I jR=UTEjP7"G-: Department of Health Services Laboratory Division 29'34799 Stl� )74 1 10 Clinton St. P.O. Box 1689 INFORMATION Hartford, CT 06144 TELEPHONE: (203) 566-5063 _ TROY RD 1'(J OS DLx11 JLA., 4A1hV j TA 1 AN 1 :4C SULLIVAN FA '-- TveiN 93LL SOUTH WTND:. O CT 06-J74 n6/21/89 06/21/89 06/29/89 L_ J �11 . 0J 11a59 11e29 FINAL REPORT C.YAiNIDEt -10 _41W-iA118FAi TOiY F04-, EXAMINATION C A D M I J V1 107 " U2 C11ii4()e1'.UM 1 )5� ^i.= 1 CLIPPER 111 3.02 N,ICf(LL 11 ) LEAD 11`4 0-04 SILVER? '' 122 0.00 A FINAL REPORT. )RM NO.OL-6A STATE�"OF CONNECTICUT' ESSION NO. ACCOUNT NO. I _ Department of Health on V1 s Luboratory Division N R :51 22084 Q ,6074 10 Clinton St. P.O. Box 1689 • • "Hartford, CT 06144 TELEPHONE: (203) 566-5063 R D SUN OFF STREA,1 TROY RD SOUTH WINDSOJ DIR OF HEALTH GERALD SCHWAR Z MD 57 UNION ST. ROCKYSLL-E CT 06606 06/2'1/89 Oa/21 /89 06/29/89 L _J 11 0u 11 : 59 11 : 29 FINAL REPORT • CYANIDE. COMPLEX 505 UNSATISFACTORY- FOR EXAMINATION ( 'SAMPLE ACIDIFIED 4H N REC_w. E-D) CADMIUM 107 0.02 CHROMIUM 109 0_.01 COPI�FR 11`1 0.02 NICKEL 119 0.00 L4-A D' 11'4 0.04 I:1 qc 127 0.09 12`2 0.00 ** THIS IS A 'FINAL REPORT, *** DRM NO.OL-6A n f� STATE' OF CONNECTICUT I.D. ACCESSION NO. ACCOUNT NO. I ROUTE JPAG'; Department of Health Servozes: Laborator}- Division `dR : 220634199 Du6J74 10 Clinton St. P.O. Box 1689 INFORMATION 'fIartford, CT 06144 TELEPHONE: (203) 566-5063 '? ST?EAA, �RUN OFF � TROY RC SOUTH 41NDSOR DIR OF HEALTH , ;i;RALO SCNWAR"'Z Mt; COLLECTED RECEIVED REPORTED 5' UNION ST. RCICKNILLE CT 06606 06/21 /89 06/21 /89 TO61.29189 L J 11 : 0u 11 : 59 11 : 29 FINAL REPORT ' CYA IJEr COMPLEX 5P5 U�iSATI�fACT(;�Y' FOR ="AMINATION :MF.L E f+ClDA A. Awic:ii nc.0 I1 G) tAO' IU4 117 0002 C;1ROMIU,%1 1,09 Oa1�1 t1 4 2 N KCL, 119 0.00 n LEAfl 114 0.04 IIC,- 1Z7 J ) s T:L #� 1 2 .C#U THIS IS A FINAL _REPO2_T. �** 1 FORM NO.OL-6A 4a. ` _ - - _ - __-- 2 �. �� ___ � ,� 3 1��gs�s�,� .,� tJ � ��`'_ _ _ __ - - - - __ E - - � --_ --- _ _ 2 _ _ _. _ ___ __ � ,- _ _ ____ _ -- -� ,- I - _ -_ _ _ - - __ ___ _- _. ,I ^��� ��,�` - - l __ __ _ _ __ _ __ I`. i -- - ---. .----- I---_____ - ----- -- _ - - -- - - - _ _ _ i f . "a0+�� �r j I j - - i li i owl. n CO-V cam,., ! . LA- - ---- -- ---- i i 6-g--go, 00, ----- --- ---- -- -- - fi� '� -lNv_. e-W-4. 41- 12 4,99 - - To Date, . Time 16) AM PM WHILE YOU WERE OUT of Area Code Number Extension TELEPHONED PLEASE CALL CALLED TO SEE YOU WILL CALL AGAIN WANTS TO SEE YOU URGENT j RETURNED YOUR CALL Message v771.e Operator AMPAD ®EFFICIENCY® REORDER #23-000 Zoe- v ( LD X4 ' i.; V v J z Z� a NOTES ON TRC REPORT OF MAY 19, 1990 Executive Summary Previous studies indicate potential for odor, but not objectionable odor. Trace amounts of six compounds found in air samples . All concentrations found were at least 160 times lower than State limits--i.e. , no health risk. However, they will continue to try to improve their existing operations . Plant Operations All furnaces and pollution control equipment approved by DEP prior to installation. Should exhaust only carbon dioxide and water vapor. Possible that some odorants not being fully controlled. Conclusions Two exhaust stocks emit trace amounts of volatile organic compounds . No health risk from these emissions . Some of these compounds can cause detectable odors . D 1540 SULLIVAN AVENUE . SOUTH WINDSOR. CONN. 06074 r��soe•co� AREA CODE 203/644-2511 June 25, 1990 Mr. Edward Kish Chief Refining Engineer South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 Dear Mr. Kish: Thank you for notifying the Town regarding the equipment malfunction at your facility on June 22, 1990. This malfunction apparently did cause odor problems in the Farnham Estates area on Friday June 22 . Three complaints were phoned into our Police Department on that day between 4:00 and 5 :00 p.m. Also, your concerns expressed during our conversation of 6/25/90 as to Finding the cause of the malfunction and your indication the operation will be shut down until the cause is found and corrected are appreciated. Please keep us informed of your progress and of the nature of emissions from your facility as this is of paramount concern to all involved. Yours very truly, Robert Deptula, R.S. June 25, 1990 MEMORANDUM To: Jean E. Zurbrigen, Town Manager Re: Odor complaints of 6/22/90 from Farnham Estates On 6/22/90 at approximately 4:30 p.m. , Mr. Edward Kish of South Windsor Metallurgical, Inc. telephoned this office to inform the Town of an equipment malfunction which might cause odor problems in the area. The South Windsor Police Department has indicated that three odor complaints were received between 4 :00 and 5 :00 p.m. on 6/22/90. On 6/25/90 (a.m. ) , Mr. Kish confirmed that there was an equipment malfunction ( possibly electrical in nature) which had caused a damper to close. There are presently maintenance personell working on the equipment to locate and repair the cause of the problem. Mr. Kish indicated that the equipment will remain shut down (possibly for several days) until the cause is found and corrected. Yours very truly, Robert Dept la Environmental Health Officer _ WD IU may/ Y2, CA, - all lie - �� Al e/- PA, _ i G ore,,-, n� i ---- - _--- ---�_. a�--_. �_.. - - - ----- ----cam -- -- - -_- ___--- a_��'-. -Vo - � � . r i i i �f I� i _ I - STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION r4NST rJ r May 6, 1991 Gerald Schwartz Director of Health South Windsor Health Department 1540 Sullivan Avenue South Windsor, Connecticut 06074 Dear Dr. Schwartz: This is to advise you, that although the period for public notice for your application for DEP delegation of authority has passed, no decision on approval has yet been made. The Department of Health Services (DOHS) has expressed some concern regarding part-time local health officials possibly not having the time to perform both delegation of authority duties and regular health department responsibilities. DOHS has asked us to delay acting on the South Windsor Health Department's application until they can come up with a DOHS policy decision regarding DEP delegation for part-time health officials. If you have any questions please do not hesitate to give me a call at 566-2860. aSincerely, Judy Belaval Bureau of Waste Management cc Department of Health Services Commissioner Susan Addiss Judy Sartucci, Director of Local Health Administration, Department of Health Services (Printed on Recycled Paper) 165 Capitol Avenue • Hartford, CT 06106 An Equal Opportunity Employer r 1// r An i - _ 1 _-c -- f Handv& Harman Precious Metal Refining Division:300 Rye Street,South Windsor,CT 06074 Telephone:(203)282-0003•Fax:(203)282-7461 June 15, 1990 Mr. C. F. Shaw Assistant Director Public Works / Pollution Control Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 RE: South Windsor Metallurgical Odor Investigation Dear Mr. Shaw: This letter will confirm the discussion which you and I had on Monday afternoon in reference to an odor complaint which you received on Friday, June 8th at 2:45 P.M. After your call was received, I immediately had one of our men investigate the complaint. It was reported to me that on Farnham Road there was an odor which was described as freshly cut grass. On or near 51 McGrath Road, a slight odor was detected similar to what was detected the previous day. We also carefully inspected our equipment, and found a small leak which may have caused the problem in question. At this moment we are making the necessary repairs to the equipment and the equipment will be down until repairs have been made. We are also setting up a program to monitor our stacks directly for odor during the operating day. Although we cannot be positive that the small leak we found caused an odor, we are making the necessary repairs and are continuing to initiate programs that will eliminate possible odor complaints from this source. Sincerely, Edward Kish Chief Engineer EK/mef cc: B. Wayne J. Bullock M. Fischer R. Kettler Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum group metals Z 6 - 90 <,1 VAT ` it)' An, a4ex-- ,O - i � 040 f✓1-�3 odor- 01.O Qz i i i ✓uP� . 6-6-90 x -.�-•--- -..ter--�-- ° _ - - - ___ - _ _ ___ --- .J�r�, �c_t c-caw•-e�4� hlz _ _ _ - __ _ � 22tx, �aa- ► -soh �aa �� `Z _ 416 vj ,, f AQ ' �- c 41 • � �2G _�7c/_t,3 South Windsor H:: Metallurgical, Inc. A Handy&Harman Company 300 Rye Street,South Windsor, CT 06074•Telephone (203)282-0871 October 19, 1990 Mr. Bob Deptula Sanitarian Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Bob: This is to inform you of the reason for the odor complaint which we received on Wednesday morning at 11:00 A.M. from Angeline Goodlin, 41 McGrath Road. As I mentioned during our phone conversation on Wednesday morning, we had two servicemen .from Yankee Gas here at the plant, who were changing a gas meter on the incoming gas line. We were assured that there would be no interruption of gas service because there are provisions for bypassing the meter. Unfortunately, one of the two regulators in the bypass line did not fully open thereby causing a fuel shortage, which then automatically shut off all burners. Only one piece of equipment was affected by this shutdown of gas service. The service was restored in about thirty minutes. At the time of the call, the wind was out of the South and Southeast at 2-3 mph. In the future, in order to prevent another occurrance of the above incident, any changes which may be required in our gas distribution systems will be scheduled for the weekend when our production equipment is not operating. Should you have any questions or if additional information is needed, please cal me at the plant. Sincerely, Edward Kish �-� Chief Engineer EK/mef Fabricators of precious metals, special metals and alloys•Refiners of silver, gold and platinum *` SENT BY.-D, E. P, Waste Bureau 3— 4-91 ;10:32AM 2035664924-+203 644 3761 ;# 1 !! STATE OF C O J.V NE CT I C lJ 1 ti�1tL l I{�71ti i s DEPARTMENT OF ENVIRONMENTAL PROTECTION A�Jl A- S fi F' ``gam 2: i 1t'. t MAR 4 ' 9 1 1 0: 43 20356643'24 PAIGE . C101 SENT BY.D. E, P, Waste Bureau ; 3- 4-91 ; 10:33AM 2035664924-f203 644 3781 ;# 2 uA - STATE.. OF CONNECTICUT DEPARTMENT-OF ENVIRONMENTAL PROTECTION 6F CY.3rtffE-_'TtMrr 1 T11 : P9,1"i' i� t)r kN ORI)Lh TO SOUTH WINWOR METALLUR01CA1,, INC. TO PLY WITH CONNECTICUI`'S HAZARDWs WASTE KkNAG 'P REGULA710m. ORDER Having found that South Windsor Metallurgical, Inc.,, located at 3vC Ryi Street in South Windsor, Connecticut is in violation of Connect,iout'S Hazardous Waste Management Regulations under the provi3ions of Chapter 446k of the Connecticut General Statutes as amended, the Commissioner Of Environmental Protection, acting unr9er Section: 2�a4 and 222a-1449 of the Connecticut General Statutes 1er,vuy 6rders South Windsor Metallurgical, Inc. to take ;such action el is necessary to: lm Bring all waste handling procedures and facilities irate, compliance with. all: applicable COMectiout Hazardous Waste to C`T] i11 Rej;u .ati ons. r South Windsor, Me�allurgical, Inc. Is further or-dared to gcuMP118h the dove described program, except as may be revised by . taw• Corwissioner of Environmental. Protection in accordance witil the ` fc-M1lkow-Ing scheduler A. On or before flay 31 , 109, verify to the Commissioner of Env3.ripiraerila PrOt.ect.ion that a qualifiai con sul.tarit hr been retained or that in-house expertise exists to perfonr. the rie�essary :3 NUGi es =der Directive 1. H. On or before 'U'Y 3' , 1989, submit to the C.otIssioner of _. E.i;`Vi��iii�i�i].�. Pro-ection for revitaw approvs 4 detailed report providing an inventory Ndentif� arlr quantify) and hazardous Waste determination and/or Precious raeta4' declaration for all wastes and/cur _ recyclable materials stared ors-site. ;;. On or before �'u y 31 , 1989, submit to the Commissioner C-4, Env"rork-ue; tal i'r ul,ect,ion for review and approval a detailed report providing for necessary managesttent procedures to comply with Connecticut's Hazardous Waste Ma-rAgtment Regu'atlons. This report must include, at a minimum',, container management procedures, record keeping regwlrewrnts c; docL3i'6r r1t that inaterials are no' atjciuii'�11a�:eri 4la ulat ively, and a demonstration that -materia' s tire le=grite g.elY vec;yrqed. m63 CAP1101 A.enue A Hanford, Ccsonft-O.-ut 061r)6 .fin Egwal Oppurfunar1 E,npdovrr 11AR 4 ' 91 10- 44 2023-5654924 PANE . 002 SENT BY:D, E, P, waste Bureau f 3- 4-91 ; 10:33AM 2035654924-f203 644 3781 ;# 3 k. Page Two D. On or before July 31 , 1989 aubmlt to the Commissioner of Environmental Protection for review and approval a report detalling ManifeRt procedures. E. On or before October 31 , 1989 verify to the Commissioner of Environmental Protection that vAl hazardous wastes identified in the report approved under Step B have been rived and disposed of properly. F. On or before October 31 , 1989 verity to the Commissioner of Environmental Protection that the remedial measures approved in compliance with Step C have been implemented. OY On or before October 31 , 1989 verifyto the Commissioner of Environmental Protection that the manifesting procedures approved in compliance with Step D have been implanted. Entered as an Order of the C=d loner .of Envirozmmental Protection this - day of RA. A A _.._..,, 1989. ' Leslie Carothers Commissioner Order No. M4- 606 Town of South Windsor Town of South Windsonr Lard Record-- Sent Certified Mail Return Receipt Requested P 701 020 472 MAR 4 191 10: 44 �0 35 E,G 4'_{ 4 SENT BY:D, E. P. waste Bureau ; 3— 4-91 ; 10:34AM ; 2035664924-+203 644 3761 ;# 4 .10wit.s WASTE Is"VECTION C!ECKLIST te: • O. c4 *fir S;%.##'n 0.$i:r'� �`_' -_\""'+IA — Name. r�)r:; r1�(�_I,�fCLS� ' l' ts_: ljt?E ; !{; /Ist3p�Cic�,n t ateir . -7 Location, �n ,4=v(w , 5 a --- -- A:� Ni;tit5er as: knerator: .�..o._.- �.�...a- - Transporter:. Phone No: ) TSDF: ID No. /�7i) _ lfa, Pert A Application No, _ Yes Contact R C �4'�.St UTc: - .41 Inventory: �..� mailing Address ( If di ferent frog Complaint Igo. location) --, Other {describe}: Inspectgr(s) : II , -- -`MW y✓�.r,_ CnA;�A'a7tR1Zw.`'ICN OF S?TE ACTIVITY } Date Established at Present Location: } I40. of E1r�p1 oyees. SI1i fi:s : - ,• �.�_._�. ._._..� Type of Activity. •�:� � ip t, ,_,�t�„C„�-�,1��- �.*-��1+�v-S 'Ct`,1L1�"if•�,`:, `-s�C' i�i� i:�a �-sc";� ` }1.{,:,,:`.��,.. r_ r E !2 f/ � s F} t � t�"� h ! t. t t:ik r Y`', C a t i qfl� .s.f 6) Septic SyS ten j ? , Puri i c i i3a i S 6we t"t ,; , -- SENT BY:D. E, N, haste Bureau ; 3- 4-91 ; 10:35AM ; 2035664924-+203 644 3781 ;# 5 PKi�j i.l q� n g rYC Hi � 1..� t star f�f" {ice Yi a P r 1 aL r ��'�� III IwYENTD�Y c i no ifie�! EPA u►►dc�° the Comprehensive Environ Mil G es Ori Nis this site pL er th l (Comm+only known as Superfu � and Liability ptt of MO (Attat►� toPy Of tdWficatiCn. if Available) When; Vhat type: Amovntl Prior to the No►e.n�er 19, 198?1 In`vIrTra sporters .lentation Ofaailities.t�it.} art wastes disposed Fre�4eticv; Ko lar+y, and by W o of Off site: _,_._..,._.�..�..�---•- - ,.-.---- ..,max- s Is there any eYi me of On-Site disPogarre uenty; L a *f Tit Wsite dispasa�l has Give fy,,pr0Airite l KSticn. IyPe; .w . -.w. been used, etc. (specify any historical on-�iitt dispasl*- ,. . SENT BY,D: E, F, Waste Bureau ; 3- 4-91 ; 10:35AM ; 2035664924-►203 644 3781 ;# 6 r LC..'�a7S I) DOC Loment No. �ier>Rrill.vr `D1 a tLA wans,e. address: - = !) Transporter(s) name, address: -- - --- 4)- Continuing Transporter ID, Nance, Address: S) YSD Facility IN naff*, address: - -- S) Waste Type/ Quantity: $') Data Shipped- S) Delivered. International ShWing ftnii`rst: -s#cc(c)- 1i) Exception Report: ir) Wtn15_ _5 �n -54ce(c)-2 j j plan an site; plan should include (4) paranete+rs: (b) test uethWs: (d) frequency►: 3) copy of ilesults= S.ta/ c) nttitan schedule and La ;lJ +' i 11 �ctions conducted• E� J ;ti , .i} Are insp 1 . 2)° Written inspection schedule: -e• Insptction 094 , . . ... z p 1 10 din ark unloading of areas 3vbject U $pilhv �#�>F?�!�` � ��fit►`Ci! egadi�.►nt i� #anti.; . � ,_. ;r lG 1t!, ti f'1�t tt' . tit ui -it� 1-1 H R 4 SENT BY:DPE, r, waste Bureau ; 3- 4-91 ; 10:36AM 2035564924-+203 644 3781 ;# 7 tb5,15! ` c) Inspection Scnedwle end Lo (contivi*4) ?5-64c(0-25 - (B) Weekly - physical conditions of cootaiwrs: Y - physical conditions of tanks - physical conditions of surfat.e ispowida*nts; ' I,,� - physical conditions of dwsVOWSIbio. treatmentW 7 facility: I�)r) -'bS.Tb! �d Personnel_ Traini._rr Records 1 ) Job titles/position description and AM of C%loyee mr i 2) Description of training: 5 a trc-n 3) Records of training: — rr�.: i�� rsvt_ 'Argh+ u 4) Trair,in; completed: 1 > L - _ 5 .5s/ 1 )4Plan on site. = �} 5-54cck'c)-31 ivt c�i .4%14�vt�- L..+Si 4-,s��: � .., • -. 5y5.(5■r3/ q4 2) Flan to local authorities: j Content of Plan. -54cc(c)931 a) Emergency plan: ���� L1.�'�!''t�� �, !, Local eufihori LY arrangevnts: oci 1 rc�ra:, farts c) Identify ev*r9ency coordinator: --�- c%,U� 'List of emergency egt„irmut� e) Evacuation plans : f C Fore are POST-tlosu a Pr_IIA s P Colt E5tifttw 55.=I2. , 1; 1 % C ure Plata (TSD Facilities) - ;.54cc(C`- A) Plan on site: ,, b) Dots plan! include: Schedile of partial class i pplitible: Estimate of 04ximam invents f aste its st+ora9e or 2) � �' trteAtwant of Sivtn time: I .-=. ... ..... - A) Sc.heduQl;e for final Clasurc ;�Mttzt�of the evected Y"r o .t y .I tM of iw" of steps needed t - wtamirate fatuity., I Ott b) GertiT'i: ati�='• +;�& coosJre: - __-- _ _. _ W. M R 4 - _D I. 1: -4 5ib 4' 4 PAGE . i_t SENT BY:D, E, P, ;caste Bureau ; 3- 4-91 ; 10,36AM ; 2035654924-+203 644 3791 ;# a Y r Po closure Plan (disposal fiLilitieu GeV) a) P1 n site: .,,_., F. ._ _.. b) Does pl 6entity and inclNde frequer+ty of: o planned gr oun at - �toriny: o planned maintenance 1 Securi tiritie3: o nArie, address and phone number of t-C101 n`e Contact: c) Length of post-closure period identifie_: 31 closure Cast Estimate (TSD facilities) a) Estinate on site: AMOUnt Of-AtizAta: b) Estir.ate adjusted annually on 11/I9 for in eLio 0 0Ha5 Closure plea changed? d) If answer to 3 is yes , has cost esti hangtd? i.1:�; C` Fie,. c 1 Gs ire Cost stirnbt _ SO facilities nrily) J y A i'j Estira vita: Amount of estirAtt: b) P-finate adjusted annually an 11119 fv inflatiom haS PoSt-clos ure plan changed? d) If answer to 3 +3 yti4lbs cost 0tiutE athbngtr' t.73/ y) 02triting Records 1) Records on Site: . r �) Description, quantity, x*thod and data of 3) Location on-site and aatnifest tier. 4) Results of e►atte analysis. 51 Rep.-Ord Of any incident$ requiring use of COf 1WOMY plan: Rec,or*ds and results of Impections: 7 Closure and pvst_tlasvre cost tStiMUS If rat — t t r +ly ?i-S il4f' C?� �:=516I 4'�+'224 PA �E . =100 SENT Waste Bureau 3— 4-91 ; 10:37AM ; 2035664924i203 644 3781 ;# 9 C. h, 1 d A , R,, clleving, LPM trucks deliver boxes, cai4uii,s anii caiai of all ;need . bearing waF:tes , Trucks unloaded, load seperated in sr,$ging brNa (ic cau6tics , acids , cyanides) 2 -3 days later the individual containers are weighted. Weight is compaired to quantities listed on manifests , if weights are correct, th,6 load is distributed to the various departments, if container is a material no handled at this facility, it is theta re-manifested (with note. on manifest - Trans-shipped) And shipped via LPM to either the Fairfield or the Waterbury f l_ity, b , Tncineration: This department uses furnices for burning solid materY all (circuit boards) and evaporating the liquid, metal bearing materials. Each set of furnices is exhausted through exhaust duct liquid scrubbers . Once materials have been. burned or dried, it is sent to the Baxl Milling Department.. c•. Fall Mill: this department reoieves the ash from the furnace department mechanica.1. y screens the ash, to separate the metal (larger partz.cies) front the finer asps generated, Once screened the ash is milled to fui:then separate t;-.e metals portion of the ash. . Once completed this department will general-c grades metal bearing ash per load, plus larger metal particles which Are me,itaU i.nt o inp;ot.s .Tha ash will then be distributed to the foundary department (i. high S-�7ade ash) or ra-shipped to independent smeltesrw (ie nvazSBa vi:i.p�raiet,rs-{;g 't*.Ai1V, Asia, FSelgium) d . Foundary: This department reeieves the separated metal. T:;nzt•ion cal ih:- ash as well as raw metal wastes. The materials ere melted iro. one c.i apw-ox J.0 furnaces (2 furnaces are induction. types the others are gas Tile �ne:ald melt:acl ire the foundary are poured iiiLb ingor molds, onca cooled they it seperated and stacked as to type metals (ma.jor � of imdtal in ingot:, most i :6c -_ con^ain maT,y types of metals-lead, bra.s,s , silver, gold, iron, ALA.) From hew, the metals are shipped out r.o various smelters (i.ndependant.) for furti,ei,- zefining, `blese described operations do not raciaim tlie marer_^-AI S a usubli: state , rather it reclaims the materials to a state where a sm lta er can readily �;eparAte i r into 1.Ls var 'Ous e.onstituexrts. e . Zxhau.,.7 Ventilation Scrubbers: Ille, flue gases goes tht,o�1 ',1 a }et ies o heat exchanger"; ' water quenciz chambers, packed towers with na I.;as . The vat:er is coxit:.inually i-ecir:culated through the pola.ut:i ,:i control system mealy a pe:^eent.HF.e of t:kiN water is pu-np@d to a p'r. ad,1IsL a t: {sodit.ri hy,,r"oxide ireatment) then a c:larif..er. The setrlpd Sri ,i. 13 ark bbr!.)ualh a r7.10ar E7res9 . The -'fudge is sttroo 11 oL �Irture t.i rec,.),hl.rn any mer-als ac:c,_L elated. 0 gal%dad, of scr4,'bell w '.t� 1.s cxra%.,n -)ri' , pi_- Into open top drums to be evaporAned (both r„f amc,lent A .r. and inci_neratso-,.1% ThosoA l !,-rii.dS aree also treatc-d Fo- meta's clii.s5 : i c- )1..Rnt;edl �. the baghouses are also packaged and shipped overseaG fo,t metal",, !�b_'C -a`ix. SENT BY:D, E, P, waste Bureau 3- 4-91 ; 1u:38AM 2035664924-Q03 644 3981 ;#10 s, Fl.t► �nr�.n.ufact oring: this department manufactory bzazir'& and so.Lciaring fluxes . First, various powders (flourides, boraces, boric acids) are poured into a mill which crushs it into fine particales. iIater is added throught a plumber ineteri.i:g $Y-Stam, The slurry is mechanically mixed rhari pumped v:La dedicated pt.tiftg to a large vat. The vat deliveres a mea$urRd Amount or flute to contairiers on a eonveyor bear, 16 different type fluxes a_'e blended, each being besicl y the name in composition (sea attached MSDS) , once a speoif,c tYPe i`iux is blended, the system is flushed with water, the water is dischsrgec? abovR pr;ound tan- . Contact claims this ri113e water is non•hacardou,,s 'bee page 2 sect; 1V Haz Waste Determinations) �. iiaintiance Department: Very minor mainLinanca is conducted, Mainlq invOlves 573te'n upkeep (piping repaires, equipment painting, furnace repairs; Clear'Ling paLt:s i9 done using either kerosene or diesel fuel. There is a 35 gay. can it rha shop with about 5 gal we.ete solvent, contact saki this is about t. ypa~s acaI,MI-Lidtion, however- when talking to the shop foreman, tla said wast:r st�lvk�iit s are `:iorm$llY inclnexated in t_he furnaces and the generation rate �s about :U S,ei Per Year of mineral spirits , kerosene and diesel fuo1. depas' n ent. has a small raehin�rik area, "Tapemati:c Gurting FIi.11.Ci" C �itCi_i.1.11 r. 1, 1, ., 1Y�C.^,.IsLC78 1a'Ltd, is use r`t. Milan up is done using disposable wi'Das , W�;E wirf 3 t;'r= arc,. , 'tltite.d and also 1r:rirarared. c Drum uondirioning: Drums racjteved from custotitesrs ama and �nsill-, cakes pl-ac.c c7ver the scl:u'r,t>>r. w{. . ;: The drums aluA r)nly rinsed, includl.n� rhosa than nontainaa SOlvel r-; used. !'h,�- .s',;v bber avatar is the Same sc.rub,rn* r waT-�-r �.II:.iLS threuo-, th , - i ar' prrs:s and the same water being air and u'rnace <a.CiC"'.1 for YrieY $ls L;C4ci lrv- :,-OneYit'J_y thRre arci 20 Awpcy (noT1 C.Sruns t)`,3% pL'E�ViO iY t r�nT,:a�.1':ed C-. _ C. Sn' iP,1.c31;.S (.TaSL�a [rV t11iC�H .S LrC�m.: ti ridl' f1�iT'zn� ;. Acilebc,:�c iitigs , dt �i 1:i..l2jtt8 aslcl imam: American Chomir,.al and Raf.iriir.;�. t]ate-=br.iry c r{l 4/nn23/Si3}}. silos?ri be. no, eid tha'c some of rile c AY t l s^D�(i 4:4i it14 ve dates (,Jn thlet har.ardouy wa-qt e ,h11)a.' s� S MAR 4 ' 9 1 i 0 ;_035664924 P A 6 E . 01 0 SENT BY:D. E, P, Waste Bureau 3- 4-91 ;10:38AM 2035664924-+203 644 3781 ;#11 Page ; 3 , Waste FrAl"n . 1. Waste Profile, Mr , Fisher, adamantly, a-udLeo. the Lirsye "i a"A I it non-hazaidoun , however lao ananwo ku spr 1988 , inviroxworwhi Kuk himicoui gives the rinse waterm 8 flash point of 139 dog, V Poor to !gad the rinse uyate-r.-, we.ro sl-;ip?ed off Aa 1)002 and F006, Envifite Was rorracted (by Paul Frarsoz-,,) conceznirg the5e wawa codes , EnviritA lab analysis indicated IwtI$I_e. was I-igzi jjj ler,,j fo2;t those shippwgnts , 26 Ap:c 1,988 resvits indicd H r fla,,I; Uf 139 deg, F. . ca"Cac, said the Wa6te as being ratonred by W.) difforenL lab, And rhc scaults wnuW be forwarded upon Ve&M . 2 , Tngpenzion schejule and log: The Uspgnrlon prognam won fivir WsOftut"d On Dec formal training resajon was held "ong vixuai aids : Ttuse ain outlined oil, foquirmerts of the propow, such-as, insplutions are to w8 ct v t,i d w,a,= to 100I.. f or d-ty i -ing the Luspeov ion, Each areas s upervisoL K for Uspostfing his ovn WOO area, (5ce attached forms)1"jz'1 6 a, Thera to UQ written progran'' b Tourp in no provisons tot Agm Ame of Wspoccion, c , Dues nun indicate storagm area location or departmenc Wing Wpected. d, Does out lava smergenm responce equipment luumvion8 a , Thond have cook for saperacions of acidn and cyanions V Does now includy dmily jonpections for the flux inking holding va,A tp.; aAgocrarall y1sQuig g, UoeA not include their own gancraLed W=sg , SunWhAr W""' ILV �YVYj7 !OVZ ' WWLOJ 3 . Owerv. ln4 -Ocorqy , All incoming MaInKAIS , incound Lnno We uper=ag record. Each culn6lorn load 1z a ft. jOWW We law from day of raniept to final smelting. bescrivIorn n jjkrh )rigs of nimammnL are not indicated OrhOr than by furnRea ball All department, etc) , Recordu do not UAV storage oca _con, again, this is WONated only by deParrmonv comm . an rbe AnUal Weparnion (Dec 1988) contact .' mid WwOnq PoWA0 % vesia, cq,jj for pH, aQ orhnr pertinan, information is o0tniieo itua hazanduab wawLm labels and wmnitasrs . 31 Clio return Kato walk aAnh lioUid Watarial it MIMI by On mzjnnan�o 0, 1 ropins CE resuirs is a dounry?"nay ir manes !, , -Ypp , Felln. Tab Y7 no4z; ohs V.Ondso; ;ALL MAR 4 ' 91 10 : 49 2035664924 PAGE . 011 �k SG�`vl� w �e4 S66 z3o -- -- Lps-- - - - - - -- --- oo le , n - STATE OF CONNECTICUT ti. DEPARTMENT OF ENVIRONMENTAL PROTECTION r ✓! APPLICATION FOP. DELEGATION OF AUTHORITY OF THE COMMISSIONER OF ENVIRONMENTAL PROTECTION PURSUANT TO THE REGULATIONS OF CONNECTICUT AGENCIES NEW APPLICATION REVISION OF ORIGINAL APPLICATION RENEWAL APPLICATION SECTION 22a-2a-1, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION SECTION 22a-2a-2, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF WATER POLLUTION Please Rrint or type As the Director of Health for %owh c-� � f� kds� (indicate the name of the municipal or district department of health) , I hereby request (check appropriate category) delegation of authority, T renewal of delegation of authority revision of delegation of authority for the following as set forth in Subsection (b) of Section 22a»2a-1 and/or Section 22a-2a-2, Scope of delegation (Circle below as appropriate. If a revision is involved, circle below as appropriate and indicate whether the category is being added or de-leted. ) Abatement of Air Pollution 1. visible emissions 2. fugitive dust X 3. odors Abatement.of Water Pollution 1, blowdown from heating and cooling equipment 2. building floor drain wastewaters 3, commercial laundry wastewaters' 4. cooling water (non-contact) 5, domestic sewage 6. stormwater 7. swimming pool backwash 8. water-production wastewater 9. agricultural pollution sources In making such application, I understand that I am requesting to act an an agent of the Commissioner of Environmental Protection within the boundaries of my jurisdiction and that I and any members—of_.my_..-staff who perform delegated duties shall abide by the standards of conduct for state employees contained in Chapter 10 of the Connect cut General Statutes, as amended, pursuant to Subdivision <ofloctiona-2a-1 and/or Section 22a-2a-2, I Phone: i6i Capitol Avenue a Hartford, Connecticut 06106 An Equal Opportunity Employer I£ this is a revision which involves a change of Director of Health, or his alternate designee, please provide the revised information and indicate it as such. In support of this application, I Provide the following information A, Name of Director of Health ✓` d S�,�wuv �Z Address 5` V Ki b',1 S vl Telephone (Business) r?a ,6loU Telephone(Emergency) Date of Appointment as Director of Health in Accordance with Section 19a-200, 19a-201 or 19a-242 of the Connecticut General Statutes (Also indicate applicable Saction(s) . �- 2-1- Experience and Training Related to the Delegation Request If Applicable- Comments Concerning Revision B. Name and title of each staff member who will perform delegated duties, estimated percentage of time to be spent on delegated duties, related experience and training and date of appointment, Pursuant to Subdivision (d) (1) of Section 22a-2a-1 and Section 22a-2a-2, a designee may allow his or her staff to perform delegated duties, provided the designee oversees and is ultimately responsible for the work of staff members, !dame a 1�M7[KblNln a.'1 Percentage of T C -I�ti%--c Date of Appointment u Dy ajejQLaVO-O Experience and 'Training Related to the Delegation;.Request n tp Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request C. The names of one or more staff members who will be considered as alternate designees in the case of the resignation or incapacitation of the Director of Health pursuant to Subdivision (c)(1) of Section 22a-2a-1 and/or Subparagraph (c) (1) (F) of Section 22a-2a-2, Is This a Revision? If Yes, Please Describe Name Address Telephone (Business) Telephone (Emergency) Date of Appointment Experience and Training Related to the Delegation Request • Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment Experience and Training Related to the Delegation Request In making this applicatio-6, I understand the requirements of sections 22a-2a-1 and 22a-2a-2 and agree that all persons listed in A, B and C above will Complete all applicable training requirements Pursuant to Subdivision (d)(2) SectiQu 22a-2a-1 and/or 22a-2e-2. I also understand that any changes in the information provided in accordance with Subdivision (c) (1) of Section 22a-2a-1. and/or 22a-2a-2 must be reported within 10 days of such change, Signature Name Title Date As (indicate chief executive officer and name of municipality or chairperson of the board name of dist ua trict department of health) , I have duly authorized this applicationPur Subdivision (c) (1) of Section 22a-2a-I and/or Section 22a-2a-2. Signature Name Title Date Revised 12/3/87 w. , SENT BY:D, E, R ,Waste Bureau 6-14-90 ; 11 ,09AM 2035664924-4203 644 3781 ;#38 i '- STATE OF CONNECTICUT ' DE,PARTMENT OF ENVIRONMENTAL PROTECTION i-4; � APPLICATION FC)fk DELEGATION OF ,A.U'THORITI� OF THE CO:dMISS10NER OF ENVIRONMENTAL PROTECTION PURSUANT TO THE REGULATIONS OF CONNECTICUT AGENCIES NEW APPLICATION REVISION OF ORIGINAL APPLICATION RENEWAL APPLICATION SECTION 22a-2a-1, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION SECTION 22a-2a-2, rVILEGATION OF AUTHORITY FOR THE ABATMENT OF WATER POLLUTION As .e e r m rs (indicate ptF Is 'd �w3-1 �7�atZ1Crthe am`;= de ar i.rlent of Y I hereby request Catezory J Gtel egay—ion of 8,'l chori y -- - renewal of :y de - )4' au: iva?t> rovisixin of delegation of authority for , e T_, rtth 4 n Subs�eci" (b) of Sect{are 22s 2a-I and/or Section uP01 7aIegh^ ion � ,,A role C elo tSs fipprop P]atf'�. If 8 7:6v18iOT2 3 8 S A,''13- Ui�Y' .I2Ci indi..are tJ?"1cther the Category is bein. s � -1 t...r cra',n wa_s tt s.a e S lF f.C77P``.��..C....A .._ �.,t��,`l, :1..:c e:FVT yrE: In ,a:.,iT11 �. t} °i t,l .c�t .r�, i ci er a,lc * .� [ am requesting to act as an agent �€ fib C?" 1?'.''1 - o:—net r '�-'4-+�yrion wi'�irL the boundaries of my iu •; -• t:: ..c tar li_d an, of my staff Tito perform delegated duties "hs. a' z« ,< lse a a i a' cs v` Cori 1. 't a tor state employees contained in Chapter rr 117 0% v a :.,,;�ze�-.,.L _atf�r6:1_ A :r t—s, as amended, pursuant to Subdivision < ti 165 Capitol Avenue w Hartford, Connecticut 06106 An Equal Opportunlry Employer SENT BY:D, E, P, Waste Bureau ; 6-14-90 ; 11 :10AM ; 2035664924-4203 544 3761 #39 r oAl'--- Ifthis is a revisic,ii which involves a change of Director of health, or his alterxiate. desi.gntts, plenae provide the revised information and indicate it as such. In support of this application, 1 provide the following information A, Na_mg of Director of Heal~<h Address i�le ihta I- ;EusiIlass) �_. To lephona(EnQrganc.y) Date of Appointment as Director of Health in Accordance with Section i.�a-200, l9a-s01 or i^Va-2 2 of the Connecticut General Statutes (Also indicate. applicable Soction(s) . Exper enc.a and Training Related to the Delegation Request iv ii_jtnlit.apl ?1PeLt..s Concerl�-n�,, Revision B, Name and Title of each staff member who will perform delegated duties, eutimared percentage of eima to be spent on delegated duties, related experiAnce and training and date of appointment, Pursuant to Subdivision (dj (1) of Section 22a-2a,-I and Section 22a-2a-2, a designee may allow his or her staff to perform delegated duties, provided the designee oversees and is txltimate+iyesponsiole for the work of staff members, E aIn'e __.. 1'i t l e - pRtoa� i Date or Appointment 5 JUH 14 90 1 - . 16 2 0,_,'56 6 4'LE'4 P. . t;_._ SENT BY:D, E. P, Taste Bureau 6-14-90 ; 11 . 10AM 2035664924-�203 644 3781 440 f. sxpetience and 'rrainine, Related to the Delegation Request Name z�..� Tits ;,a f 1:ppointMent: _----------- Experience and Training Related to the Delegation Request percentage of '_rime- date of Appointment, Exper 6nQe and Training Reia.ced to the Delegation Requeac 1UH 1 30 1 1 N 2: 0: c;bb 19 ;_ l.J-4ll F'F C SENT BY:O, E, P, Waste Bureau ; 6-14-90 ; 11 : 11AM ; 2035664924-►203 844 3781 ;#41 Newie Of Tir+r a3 ---- Date of Appolc:tn.enL Experience and Training Related to the Delegation Request rarcentAge of Time 3 —��- - Date of Appointment Exparienca and Training kelated ro the Delegation Request C. The names of one or more staff members who will be considered as alternate designees in the case of the resignation or incapacitation of the Director of Health pursuant to Sabdivision (c) (1) of Section 22a-2a-I and/or 'S 00 aragmapia {P) (l (. of Section 22a-2a-'2, is This A Revision? if Yes, Please Describe Name Title Addresu telephone 4B_.fii .efis; Telephone (Emergency) Date of ADnoingym,€n JUN 14 ' 90 1 : 1 7 2 03 F-:1 6 4'924 F`fH6E . 04 1 SENT BY:D, E, F, Waste Bureau ; 6-14-90 ;11 .11AM 2035664924-►203 644 3781 ;#42 4 -Experience and Training Related to the Delegation Request . - Name ---- - - ----�----= T i t I.e Address Telephone (Business') 114H1aphone (Emergency) Date of Appointment Experience and Training Related to the Delegation Request JUH 14 990 12 1 7 203566,4 24 PHGE L-I4 2 SENT BY:D, E, P, Waste Bureau ; 6-14-90 ; 11 :12AM 2035664924-+203 644 3781 ;#43 in making this application, I understand the requiremento of Sections 22a-2a-1 and 22a-2a-2 and agree that all persons listed in A, B and C above will complete all applicable training requirements pursuant to Subdivision (d) (2) of SecLio 22a-2a-I and./car 22&-2a-2. I also understand that any changes in the information provided in accordance with Subdivision (c) (1) of Section 22a-2a-I and/or 22a-2a-2 must be reported within 10 days of such change. Name -- Title Dat.Y As _ _..__.�_- -- --- _._ .-_�___�_-__�____ (irdicato chief executive officer and name of municipality -'%r chairperson of the board and name of district department of heath) , I have duly autharized this application pursuant to Subdivision (c) (1) of Section 22a-2a-1 and/or Section 26a-2a-2. _y s;L�t a -- - --- - �r x S; Revised 12/3/$1 JUN 14 ' 90 12 : 13 chi.56F49='4 PAGE . L34 SENT BY.D. E. P, Waste Bureau 8-14-90 ;12-"88PM 203566492-4-+203 644 3781 ;# 2 Janus M-911,1-1 ov, of A," dpjj,�",q ri t G Chespron-o,i-t I-I. Che8f;,, 67,330 WO'LCOtL Watertown Clinton Her.' C.1, :"e-P, V -70 ,Danbury jqeaj _riop L East Hartford X 68 9 so Milford X 52,040 52,100 Nau&atuck Valley H Dig t X X Ansonia 114,680 Beacon Fall& Derby Naugatuck Seymour Newington NXentral. uc-o ty 10 Enfield 90.190 Windsor F. 171ndsor Suf r1ola Pompezeu- F: Disti;lc v 2'2 10 Woodb,.ary witr Gt Oxford ad i t C�n 0 f oxford) Quinnipiack valley DiA« Hamden North flavc-n Woodbridge Stamford Health Dept, X X Torrington Araa H, X X BethlehAm 0 2,2C Cornwall Goshen �i$rjaintsn - Kant ti Litchfield Morris Salisbury Thomaston Torrington Warren Winchester Waterbury 33u Wethersfield lir;ialth Dept. X X X 2107,7,510 JUH 14 ' 90 13: 44 203566492'4 PAGE . 002 a ' i t -t r tF ' ._,�„�—s��•=ate 4=s.i � -_ rt. 1 F j• 11 f E9uc.- s 4� • Fi i-$•�.._ .�i- 4 }p• 4 "i � F - k f-1' y S f- • h i s -- <.... . .�..:;,_• .._..__ i - is sad 0 - - w - . 1 Q z i -i ems, + - TUN 11 ' 90 1 13 21, 1 44 PH =aE . O>_i 1 � r STATE OF C ONNECTIC UT ( " '.P, I EP'ATNIFNT O- F ENVIRONMENT.AI TOLL �F $emu Compla-I n a hand-ling Prvah_-e+.Li.re Wherw-Ve;:, a complr.,inaiat calls --regal:-ding a source :from a jurisd.icl;inn w-, h delegated authority to handle such a oompla.int I"ref . attaoheu ii,s;) , zs:k_: te]Ll the person 'to a-a l the appropriate Health 1.+ } r.t,4m 3n /.1,.��E. l� a.��a i.t the t✓ +.' Indicates haq; i�J,F8y +-�.a e a.1 early done SowPlea8a by ey ley ncl1�- �his under "other pertInent de3t oI2 �)je Y' Attachments Y 4,liC; 165 Carlai?l {.unnecticut .An Equal Opppriunily 6rucl![,vtr j UN 1 1 0 1 14 - 0 7c) To"s del Table" �. Health Dm .K_it?ist+ roct 3uc es<�vc?tau k fairec<< aal lice"�rF .i*.ei r atf^ Cf ciGPie� SCaff Weinber:s Delegated Authority TERff OF MOAJ �. 1 B1, CHE4Nilkf7" �cfwf .4IRE IP TRICK ACCARD" GL01YfCr:lk£ DCH"'COEA Ea1RRApiwE Lelti'COl IJ!$EOIf FP�E� k". T-1 S 1c 6P ° ESt r'S i i? �t24a E1pGhfl. dt. A4dalIL'p; iC11R.m m.6..k;F;LTrh Fi E 6�lpG➢:a:°': U.tST < �l? 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Y4, .. 144 I a �t prvrp 201 irh s k r e 1 20 — 203 204 E 205 g 205208 207 20 p w 21 2"i err,. ..h�n. .,n4" �.; C:T _ y°,A�ra1,rG,('Afj I � ,.,.� 4d; ; _ 30-90 a a 212 213 214 215 T, T. m I'! Il• I ° � t � �� e �2`,�� �,.�l 5' l�tit_ �-�P- ��^may y""C / ', ���`�.., �L-.®. 1'J�i'.� �..4� O� �� Handy&Harman Precious Meta(Reflning Division:300 Rye Street,South Windsor,CT 06074 Telephone:(203)282-0003•Fax:(203)282-7461 November 28, 1990 Mr. Bob Deptula Sanitarian Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Bob: Thank you for your call to me at 12:40 P.M. on Tuesday, November 27th and the report of your investigation of the odor complaint received by Mr. Fred Shaw from a resident at 6 Abar Lane. Enclosed is a copy of the memo sent to the Department of Environmental Protection and the wind direction chart for the time in question. If there are any questions, please call me at the plant. Sincerely, Edward Kish Chief Engineer EK/mef Enclosure Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum group metals r HandY&Harman Precious Metal Refining Division:300 Rye Street,South Windsor,CT 06074 Telephone:(203)282-0003•Fax:(203)282-7461 November 27, 1990 Department of Environmental Protection 165 Capitol Avenue Hartford, CT 06106 Attention: W. John Doolittle, III P.E. Air Pollution Control Engineer Subject: Odor Complaint ;. Dear Jack: On Tuesday November 27, 1990 at 8: 35A.M, we were informed by Fred Shaw of an odor complaint which he had received from a resident at 6 Abar Lane. Mr. Shaw immediately sent Bob Deptula to the above address to investigate the complaint. Bob's findings were as follows: 1. At 8 :46A.M. he did not detect any odor. 2 . The wind direction at 8 :45A.M. was out of the Northeast. Our wind instrument recorded winds out of the Northwest between 8 :00-8:30A.M. and out the North-Northeast at 8:45 to 9:OOA.M. These readings agree with the report of the investigator. Enclosed is a copy of the wind instrument chart for the time in question. Should you have any questions, do not hesitate to call me at the plant. Sincerely, Edward Kish Chief Engineer EK/mef Enclosure Fabricators of precious metals,special metals and alloys•Refiners of silver,gold and platinum group metals C �_I I I I ILI I I I I I 1,1J,f_ � I I I�I I I I I IfI•�)I(,t�lrl�I tI I I(�I��4I`Il l LI t I !I I I!I I I - c illlll! !�! II ! 1 !L - '!I 1 IT !!) I11�#I+JVkillll IIII�IIaI I liilli _ I Ij�lll IIII I I !! 1 '1•��41�1!rt 1 I ! IIIII II !II'I ! I i - ml I !,Il+li°�-�IIIII �IIII I I IIIII I II �` .'., ��'r': 'i i LI '' lil �tll lilli ''i i111 111 �� 1111J1<< .� _I<<I- ?5 I I III I l I I I III II II i I "'i i i'I !IIi110 ; 20II 3011 II 40 1 180 l�ol;l Rio Io I'eol 10o I ( I 1 I 11111; I I I I I !I ;!i► !! II!i!i j TV- 0 !l I I !Ir i ii_�iiI111111L1 1 I I I — I 1 I I ► 11���1I I _� !1►,Il ! ►1L1i ► ��i ! 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I I'J 1�1�1 III'i Ili IIi III !1 �i_.J__!ICI � ! , I: I 'III i 11 i ,�;,,�i�._ _ I_I_._ 1J �l l 1 .1�. I l ! ! I III►I ► I .I �! � I: iill1l ►l�I �IiII _I�,IJ�l!!!�_1�!11 ��lil]�1_�I.11_;111�1_I1� i;l;��" 'I�iiI11!!I!_� ILL � l�! ;_ " ii li;l `�,f 111 ( ! '! !iii Jul' I' I '��� I!iIi 11_;�!_►! j -I I I II 1 I' 1 N`` III111 �!1►lil it ►1_Li 1 -A -ii1111.Ii. I - II1 � ; , !L I►11► f I ,, .` ' ! 1'lllli II►II!�i( I ! I � I !1 I' 1'►I Ii_ l Ii111i►� I��1;�1�1 j II11 _ I __ : IiIII I_ r �-! � - ;) I I ! ,III i j -,) j` t�lll !� I! •^�" �..; I t: I ' J , STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION �AEPLICATION FOR DELEGATION OF AUTHORITY OF THE COMMISSIONER OF ENVIRONMENTAL PROTECTION PURSUANT TO THE REGULATIONS OF CONNECTICUT AGENCIES NEW APPLICATION REVISION OF ORIGINAL APPLICATION RENEWAL APPLICATION SECTION 22a-2a-1, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION SECTION 22a-2a-2, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF WATER POLLUTION Please Rrint or type As the Director of Health for TOW k o•K' s'c��+'1 k 1.4+ k tl D►^ (indicate the name of the municipal or district department of health) , I hereby request (check appropriate category) delegation of authority ✓ renewal of delegation of authority revision of delegation of authority for the following as set forth in Subsection (b) of Section 22a-2a-1 and/or Section 22a-2a-2, Scope of delegation (Circle below as appropriate. If a revision is involved, circle below as appropriate and indicate whether the category is being added or deleted.) Abatement of Air Pollution 1. visible emissions 2. fugitive dust L.4. odors Abatement of Water Pollution 1. blowdown from heating and cooling equipment 2. building floor drain wastewaters 3. commercial laundry wastewaters 4. cooling water (non-contact) 5. domestic sewage 6. stormwater 7. swimming pool backwash 8. water production wastewater 9. agricultural pollution sources - In making such application, I understand that I am requesting to act as an agent of the Commissioner of Environmental Protection within the boundaries of my jurisdiction and that I and any members of my staff who perform delegated duties shall abide by the standards of conduct for state employees contained in Chapter 10 of the Connecticut General Statutes, as amended, pursuant to Subdivision (d) (3) of Section 22a-2a-1 and/or Section 22a-2a-2. Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 2 If this is a revision which involves a change of Director of Health, or his alternate designee, please provide the revised information and indicate it as such. In support of this application, I provide the following information A. Name of Director of Health _ ]Dr' &VV 'Ia j $40LAU26- .: Address Telephone (Business) "" Telephone(Emergency) Date of Appointment as Director of Health in Accordance with Section 19a-200, 19a-201 or 19a-242 of the Connecticut General Statutes (Also indicate applicable Section(s) . Experience and Training Related to the Delegation Request If Applicable- Comments Concerning Revision B. Name and title of each staff member who will perform delegated duties, estimated percentage of time to be spent on delegated duties, related experience and training and date of appointment. Pursuant to Subdivision (d) (1) of Section 22a-2a-1 and Section 22a-2a-2, a_designee may allow his or her staff to perform delegated duties, provided the designee oversees and is ultimately responsible for the work of staff members. Name y. 41k Title;5/1 41)N0K _ as Kee drd Percentage of Time Date of Appointment T 0 K A 3 Experience and Training Related to the Delegation Request Kt Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request s' 4 Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request ' C. The names of one or more staff members who will be considered as alternate designees in the case of the resignation or incapacitation of the Director of Health pursuant to Subdivision (c) (1) of Section 22a-2a-1 and/or Subparagraph (c) (1) (F) of Section 22a-2a-2. , Is This a Revision? If Yes, Please Describe Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment 5 Experience and Training Related to the Delegation Request Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment Experience and Training Related to the Delegation Request 6 In making this application, I understand the requirements of Sections 22a-2a-1 and 22a-2a-2 and agree that all persons listed in A, B and C above will complete all applicable training requirements pursuant to Subdivision (d) (2) of Section 22a-2a-1 and/or 22a-2a-2. I also understand that any changes in the information provided in accordance with Subdivision (c) (1) of Section 22a-2a-1 and/or 22a-2a-2 must be reported within 10 days of such change. Signature Name Title Date As`T6cSIQ MRn(Ig,-�- }10 W SOl)I'l'I tJlNi ndicate chief executive officer and name of municipality or chairperson of the board and name of district department of health) , I have duly authorized this application pursuant to Subdivision (c) (1) of Section 22a-2a-1 and/or Section 22a-2a-2 Signature Name aA N C Zv ► R C Title (7 LJ N F'1 r4 aG,c i2- Date Revised 12/3/87 STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION 9PLICATION FOR DELEGATION OF AUTHORITY OF THE COMMISSIONER OF ENVIRONME PROTECTION PURSUANT TO THE REGULATIONS OF CONNECTICUT AGENCIES NTAL NEW APPLICATION X REVISION OF ORIGINAL APPLICATION RENEWAL APPLICATION SECTION 22a-2a-1, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION SECTION 22a-2a-2, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF WATER POLLUTION Please print or tune As the Director of Health for Town of South Windsor the name of the municipal or district department of health) , X hereby(indicate (check appropriate category) delegation of authority__ renewal of delegation of authority__ revision of delegation of authority for the following as set forth in Subsection (b) of Section 22a-2a-1 and/or Section 22a-2a-2, Scope of delegation (Circle below as appropriate. If a revision is involved, circle below as appropriate and indicate whether the category is being added or deleted.) Abatement of Air Pollution I. visible emissions 2. fugitive dust X 3. odors Abatement of Water Pollution 1. blowdown from heating and cooling equipment 2. building floor drain wastewaters 3. commercial laundry wastewaters 4. cooling water (non-contact) 5. domestic sewage 6. stormwater 7. swimming pool backwash 8. water production wastewater 9. agricultural pollution sources In making such application, I understand that I am requesting to act as an agent of the Commissioner of Environmental Protection within the boundaries of my jurisdiction and that I and any members of my staff who perform delegated duties shall abide by the standards of conduct for state employees contained in Chapter 10 of the Connecticut General Statutes, as amended, pursuant to Subdivision (d) (3) of Section 22a-2a-1 and/or Section 22a-2a-2. Phone: 165.Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer . 2 If this is a revision which involves a change of Director of Health, or his alternate designee, please provide the revised information and indicate it as such. In support of this application, I provide the following information A. Name of Director of Health Dr. Gerald Schwartz Address 57 Union Street, Rockville, CT 06066. Telephone (Business) 872-6100 . Telephone(Emergency) ' 64.4-2511 Date of Appointment as Director of Health in Accordance with Section 19a-200, 19a-201 or 19a-242 of the Connecticut General Statutes (Also indicate applicable Section(s) . 1-22-81 Experience and Training Related to the Delegation Request None If Applicable- Comments Concerning Revision B. Name and title of each staff member who will perform delegated duties, estimated percentage of time to be spent on delegated duties, related experience and training and date of appointment. Pursuant to Subdivision (d) (1) of Section 22a-2a-1 and Section 22a-2a-2, a designee may allow his or her staff to perform delegated duties, provided the designee oversees and is ultimately responsible for the work of staff members. Name Robert pt1,1 a Title Evironmental Health Officer Percentage of Time AG Neer1t-d Date of Appointment upon p-o royal 3 Experience and Training Related to the Delegation Request None Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation_ Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request i 4 Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request Name Title Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request C. The names of one or more staff Abers who will be considered as alternate designees in the case of the resignation or incapacitation of the Director of Health . pursuant to Subdivision (c) (1) of Section 22a-2a-1 and/or Subparagraph (c) (1) (F) of Section 22a-2a-2. Is This a Revision? If Yes, Please Describe Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment 5 Experience and Training Related to the Delegation Request Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment Experience and Training Related to the Delegation Request 6 In making this application, I understand the requirements of Sections 22a-2a-1 and 22a-2a-2 and agree that all persons listed in A, B and C above will complete all applicable training requirements pursuant to Subdivision (d) (2) of Section 22a-2a-1 and/or 22a-2a-2. I also understand that any changes in the information provided in accordance with Subdivision (c) (1) of Section 22a-2a-1 and/or 22a-2a-2 must be reported within 10 days of such change. Signature Name Title .P_�`G TG 07' Date '3 As T6v r\I K O I'H Win1 ndicate chief executive officer and name of municipality or chairperson of the board and name of district department of health) , I have duly authorized this application pursuant to Subdivision (c) (1) of Section 22a-2a-1 and/or Section 22a-2a-2 Signature Name atA ry C Zk, ► R � Title 0 W N wi Date `s x k 1 jJ 1 I - I ' Y 1 Revised 12/3/87 { f t STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION March 4, 1991 Bob Deptula South Windsor Health Department 15-40 Solomon Avenue South Windsor, Connecticut 06074 Dear Mr. Deptula: Your call inquiring about the progress of South Windsor's application for the delegation of authority program came as quite a surprise, since this office never received the completed application. It's quite possible that the application either got lost in the mail or was delivered to some obscure section of DEP where it has remained - unrecognized and forgotten. Since you probably still have the original delegation materials that were sent with your application I am not enclosing additional copies; however if you would like copies of any of the following materials, please just give me a call: 1) a short description of the Delegation Program 2) a sample of a typical Memorandum of Agreement - which is the vehicle used to delegate authority to the local Health Director 3) a sample of the forms used to report investigations of air and water pollution violations 4) inspection information for six of the delegated categories of water pollution problems 5) a copy of the Regulations of Connecticut State Agencies relating to the Delegation of Authority (22a-2a-1, 22a-2a-2) I have enclosed another application for DEP Delegation of Authority. Please recall that when filing an application the Director of Health and Mayor must sign on the last page. Just a reminder of the procedure that DEP follows once an application for Delegation of Authority is .received: the DEP must publish a 30 day legal notice of such application in a newspaper having general circulation in the municipality affected. The notice must indicate the scope of delegation requested in the Delegation Application. A copy of such notice is also sent to the Commissioner of the Department of Health Services. Following such 30 day notice, if no request for a public hearing or adverse comments are received, p " -«the DEP contacts the Director of Health as to DEP's response to the application (approval or disapproval) . Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer If an application is approved the DEP prepares a Memorandum of Agreement (MOA) for signing by the Director of Health and the Commissioner of Environmental Protection. The MOA is the legal document which officially delegates specified authority (air pollution and/or water pollution investigative power) to the local Director of Health. You should know that the possibility for funding for the delegation program for the next fiscal year is extremely remote; the budget Governor Weicker sent to the legislature did not include money for delegation grants. However the delegation program will still function since it's statutory authority is not contingent upon the availability of funding. If you have any further questions or need more information on any facet of the program, do not hesitate to contact this office at 566-2860. Sincerely, Judy Belaval Waste Management Planning & Standards L 1 L R-� Ll O j\ e n 1��- 0 7 yr��1, o/ d/-E-O r nvd � 02 i.�• ro•2� i J•9fi' ` h i r, - STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTIO APPLICATION FOR DELEGATION OF AUTHORITY OF THE COMMISSIONER OF ENVIRONMENTAL PROTECTION PURSUANT TO THE REGULATIONS OF CONNECTICUT AGENCIES NEW APPLICATION X REVISION OF ORIGINAL APPLICATION RENEWAL APPLICATION SECTION 22a-2a-1, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION SECTION 22a-2a-2, DELEGATION OF AUTHORITY FOR THE ABATEMENT OF WATER POLLUTION ?lease 2rint or twe As the Director of Health for Tnwn of South Windsor- (indicate the name of the municipal or district department of health), I hereby request (check appropriate category) delegation of authority X renewal of delegation of authority_ revision of delegation of au` th ity for the following as set forth in Subsection (b) of Section 22a-2a-1 and/o— Section 22a-2a-2, Scope of delegation (Circle below as appropriate. .If a revision is involved, circle below as appropriate and indicate whether the category is being added or deleted.) Abatement of Air Pollution on 1. visible emissions 2. fugitive dust X. 3. odors Abatement of water P011utio 1. blowdown from heating and cooling equipment 2. building floor drain wastewaters 3. commercial laundry wastewaters' 4, cooling water (non-contact) S, domestic sewage 6, stormwater 7. swimming pool backwash 8. water production wastewater 9. agricultural pollution sources In making such application, I understand that I'am requesting to act as an agent Of the Commissioner of Environmental Protection within the boundaries of my jurisdiction and that I and any members of my staff who perform delegated duties shall abide by the standards of conduct for state employees contained in Chapter 10 of the Connecticut General Statutes, as amended, pursuant to Subdivision (d)(3) of Section 22a-2a-1 and/or Section 22a-2a-2. Phone: 165 Capiiol Avenue • Hartford, Connecticut 06m An aqua! Opportunity Employer I£ this is a revision which involves a change of Director of Health, o alternates designee, please provide the revised information and indicate r his such. icate it as In support of this application, I provide the following information A. Name of Director of Health Address 57 Union Str Ro Telephone (Business) 872-6100 Date of Appointment as Director of Health in Accordance 6 with 44 SSection 19a-200, 19a-20I or 19a-242 of the Connecticut General Statutes indicate applicable Section($). Also 1-22-81 Experience, and Training Related to the Delegation Request None If Applicable- Comments Concerning Revision ,S B. Name and title of each staff member who will perform delegated duties estimated percentage of time to be spent on delegated duties, related experience and training and date of appointment. Pursuant to Subdivision (d)(1) of Section 22a-2a-1 and Section 22a-2a-2, a designee may allow his or her staff to perform delegated duties ed the ultimately responsible for the work of staff ammbersdasignee oversees and is Name Robert Deptula Title Environmental Health Officer Unknown at Percentage of Time this Date of Appointment Upon. approval Experience and Training Related to the Delegation Request None --------------- Name Title .<' Percentage of Time Date of Appointment Experience and Training Related to the Delegation Request t . Title rcentage of Time A : —__ Date of Appointment er ,Once and Training Related to the Delegation Request Name Title _ Percentage of Time . Date of Appointment Experience and Training Related to the Delegation Request q est 4-- Name Title Percentage of Time Data of Appointment ExPeriancs and Training Related to the Delegation Request :. E C• The names of one or more staff members designees in the case of the ho will be considered as alte r.. of Health pursuant to resignation (or 1 incapacitation of the Dir Sub ara rah c 1 F Subdivision (c)(I) of Section 22a-2a-1 e subparagraph p O( )O of Section 22a-2a-2. Is This a Revision? If YesP Please Describe Name Title Address Telephone (Business) Telephone (Emergency) Date of Appointment making this application, I understand the requirements of Sections 22a-2a-1 and 22a-2a-2 and agree that all persons listed in A, B and C above will complete all applicable training requirements pursuant to Subdivision (d)(2) of Section 7 22a-2a-I and/or 22a-2a-2. I also understand that any changes in the information provided in accordance with Subdivision (c) (1) of Section 22a-2a-I and/or 22a-2a-2 must be reported within 10 days, of such change. Signature Name Title ` tee ee Data As __Town Manager of south Windsor (indicate Ichief executive officer and name of municipality or chairperson of the board and name of district dspartmsnt of health) , I have duly authorized this application pursuant to Subdivision (a)(1) of Section 22a-2a-1 and/or Section 22a-2 -2. Signature Name Jean E. • urbr Title Town Manager Data October 18, 1990 Revised 12/3/87 company mm►ea monaaria cream: tnF commission acted legally in that the commission could schedule both instances. a hearing-for June, said William-- The warehouse would generate Klug, president of Services about 1,400 trucks a day and serve , Development. Corp.`, which is as Roadway.'s`-Hartford distribu ap lying on behalf of Roadway. tion center. The Woodcocks say , If it received the plans after that such traffic would overburden. Monday,rite commission could not. Sultivan:4venue,one;of the town's hold the hei aaagg urttt$July accord-' major throughways. , ing to town officials. Traffic on the road 'also During the weeks of debate, a known as Route 194— zips by at neirbor-of the site Roadway plans close to 15,000 vehicles daily. to 6ufid on sought a new hearing A public.hearing before the Plan- on both the current application — ning and Zoning Commission is the redefinition of the boundary of scheduled tonight at 8 in Town two acres of wetlands = and an Hall. ,�22:-fro Council may seek OK to cite metal refinery for emissions today. ' By ANDREW NELSON . But the report never said if the ' Journal Inquirer staff writer emissions — including bromine, . chlorine and iodine — threaten SOUTH WINDSOR — Com neighbors'health, he said. plaints from a neighbor persuaded Daniels wants the-council`ta the.Town Council Monday to con- apply to the Department of Health sider asking the state for the power- Services for power to cite the to cite a Rye Street metal refinery refinery.if town officials determine for any, hazardous chemicals that emissions pose a threat. � • - _ emitted from the stacks there. Right now only the state can cite The council said it.would con- a facility,but gives power to towns:f sider at a-special-meeting in coming in a "delegation of authority" ga . . :v weeks the suggestion Monday from because of an -overwhelming „. George H. Daniels Jr-. of 19 High caseload. :. Water Road, who says neighbors The council will discuss Daniels' want to know if emissions threaten request at an upcoming meeting, The most discouraging part-of losing can actu, their health. Mayor Lincoln H. Streeter said ' weight isknowingyou'll probably. so-called The refinery confirmed suspi- today.- gain-it all back.Unless you're on you add i cions of Daniels and other "If there is some hazardous The OPTIFAST Program. food cost neighbors a month ago when it emission coming from the stacks... revealed in a report that it prod ucxs we certainly want .to loolE at.it," Mlle our typical patients lose So cal occasional odors from its stacks. Streeter said: more weight:..fasters than on any-- You'll Ilvf But the report prepared by TRC Also Monday, the council otherweight loss program(44 pounds ever after Environmental Consultants.Inc. of accepted the resignation of Clifford in 13 weeks;1,they also lose safely. East Hartford called the. odor Slicer from the Inland Wetlands ' - "faint and unobjectionable." Commission and allocated $5,000 Our patients also maintain more 'That just satisfies the fact that for the production of a videotape , n .Weight loss,on average,than o the neighbors weren't just imagin- that will promote the town as a any other program.' ' ing something," Daniels said home for industry and businesses.. ` And it's all due to,the comprehen Couple injured in Windsor accident sivesupportof a team of physicians; behaviorists and registered dietitians name may be incorrectly fisted, specially trained in weight manage sr Journal Inquirer stag Their daughter,' Agnes Evans, inert;They'll constantly iEnonitor your 29 of the same addr� was•dis; WINDSOR—A Hartford cou- charged; as were her-two children, piss as they teach you skills you ple was in Hartford Hospital late need to lose weight and keep.the Monday after heir `brought there a 3-year-old and a 1-year-old;wl . y g also were transported.then Sapisti. PouttdS off, Ihexr slonalt by Lif6 Star helicopter>Saturday day. - -'.Sup sed mailatertanca trogra after a two-carandcar accident at West The driver of the other car, May Y wff reinforce all you've le-rued Wolcott and M lice and avenues, Luney, 68, of 51 White Rock t . What's more,The'OFr(FiST"ram[ `according to police and hospital Drive, Windsor, was treated and spokesmen. released olive said. . - . The operator of station wagon ,p MANCHESTER MEMORIAL F in the accident, Walter Matthews, The, accident, which: was 58, of-109 West Euclid-St., was irt. reported,at-almost&p.m.Saturday ; stable condition, the hospital-said. occurred when the cars had a His wife, who police have listed as "minor" collision at the intersec• ALSO AVAILABLE AT MANCHESTER' Irennar Mathis, 52f of the sane tion,according to police: address, was in ,intensive "care, According to Officer Frank j according to. the -hospital,.which Starnes, the Mathis car hit a tree, r 2 has her listed as Irene. Both police and "that's where the real damage ; and hos�ltid�tilt6dtiffJ litlr�c -:` STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTIONJA 4R March 20, 1991 Jean E. Zurbrigen Town Manager - Town of South Windsor South Windsor Town Hall 1540 Sullivan Avenue South Windsor, Connecticut 06074 Dear Ms. Zurbigen:This is to let you know that due to mail delays the Public Notice regarding South Windsor Health Department's application for delegation of authority will appear in the Hartford Courant on March 22, 1991 in lieu of March 21, 1991. �= co ; 1� Sincerely, R"an ? 519910 Town ;,t 1 r' Judy Belaval South Yri„dsor Planning & Standards Division �r! Bureau of Waste Management N � (Printed on Recycled Paper) 165 Capitol Avenue • Hartford, CT 06106 An Equal Opportunity Employer STATE OF CONNECTICUT sa DEPARTMENT OF ENVIRONMENTAL PROTECTION March 8, 1991 Gerald Schwartz, M.D. Director of Health South Windsor Health Department 1540 Sullivan Avenue South Windsor Connecticut 06074 Dear Dr. Schwartz: Attached please find a copy of the Public Notice regarding your Application for Delegation of Authority for the abatement of air pollution. The notice will be published on March 21, 1991 in the Hartford Courant. If you have any questions or require any further information do not hesitate to call me at 566-2860. Sincerely, Judy Belaval Planning & Standards Division Bureau of Waste Management Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION LEGAL NOTICE STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION PUBLIC NOTICE OF APPLICATION BY A DIRECTOR OF HEALTH FOR DELEGATION OF AUTHORITY FOR THE ABATEMENT OF AIR POLLUTION POLLUTION PURSUANT TO SECTION 22a-2a-1 OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES Gerald Schwartz -M.D., Director of Health of the South Windsor Health Department, has applied to the Commissioner of Environmental Protection for delegation of authority: to investigate certain existing or potential air Pollution discharges as described in Chapter 446c of the Connecticut General Statutes being limited to violations of the standards, criteria and other requirements pertaining to odors contained in Section 22a-174-23 of the Regulations of Connecticut State Agencies. No authority to investigate any existing or potential source of pollution originating from a facility or property owned by the state or any instrumentality of the state shall be granted. The applicant shall be considered an agent of the Commissioner. Information regarding the application can be obtained from the Planning and Standards Division of the Waste Management Bureau of the Department of Environmental Protection, 165 Capitol Avenue, Hartford, . Connecticut 06106 (203-566-2860) . Any comments regarding said application should be filed by 6104:36 p.m. , April 22, 1991 with the Planning and Standards Division of the Waste Management Bureau, attention Judy Belaval. 7z� Carmine DiBattista Director Planning and Standards Waste Management Bureau Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer . e STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION March 15, 1991 Robert Deptula South Windsor Health Department 1540 Sullivan Avenue South Windsor Connecticut 06074 Dear Bob: Attached please find a copy of the Public Notice regarding your Application for Delegation of Authority for the abatement of air pollution. The notice will be published on March 21, 1991 in the Hartford Courant. If you have any questions or require any further information do not hesitate to call me at 566-2860. Sincerely, Judy Belaval Planning & Standards Division Bureau of Waste Management Phone: 165 Capitol Avenue • Hartford, Connecticut 06106 An Equal Opportunity Employer gula . y i P. date Bureau of Air Management January 16, 1991 Control of Odors - Section 22a-174-23 During 1990, the Connecticut Department of Environmental Protection's Bureau of Air Management established revised regulations for the control of odors. The revised regulations state that: "No person shalt cause or permit the emission of any substance or combination Of substances which creates or contributes to an odor, in the ambient air, that The new odor constitutes a nuisance. " regulation is The major change from the old regulation is that it prohibits odor that causes a now based on ' nuisance. In the old regulation, odors were judged on whether or not they a nuisance were objectionable. . standard There are three methods for detecting an odor and determining if it is a nuisance. The first method is an inspector using his or her unaided nose. The second method would apply a 7 to 1 dilution factor to the odor measurement and the third method would determine if a substance listed in Table 23-1, was in excess of the allowable concentration. The criteria for determining if an odor is a nuisance, are summarized below. An odor constitutes a nuisance if: (a)(2)Based of the odor's Intensity Characteristics Frequency and There are Duration, that; three methods The odor is injurious to public health, or; for detecting an odor Unreasonably interferes with the enjoyment of life or the use of property, considering the injury to, or the interference with the: Health General Welfare Property or Use of property of the people affected, and The location of the pollution source and The character of the area or neighborhood affected Ct.Dept of Environment Protection Page 1 October 1990 Page 23 - 1 Sec. 22a-174-23. Control of odors (a) ( 1 ) No person shall cause or permit the emission of any substance or combination of substances which creates or contributes to an odor, in the ambient air, that constitutes a nuisance. (2) An odor constitutes a nuisance if present with such intensity, characteristics, frequency and duration that: (A) It is, 'or can reasonably be expected to be, injurious to public health or welfare, or (B) It unreasonably interferes with the enjoyment of life or the use of property; considering the character and degree of injury to, or interference with, the health, general welfare, property, or use Of property of the people affected, and the location of the pollution source and character of the area or neighborhood affected. . Whether the source of the emissions was present in the location first shall not -be a consideration. .y (3) Except as provided in subsection (b) of this section, in determining whether an odor constitutes a nuisance the . commissioner shall review information gathered from any source of information, including but not limited to citizen complaints and site inspections or surveys. (b) Odor in the ambient air shall be deemed to constitute a nuisance if a representative of the commissioner or at least fifty percent of any group of representatives of the commissioner determines, based upon at least three samples or observations in a one hour period, that after a dilution of seven parts clean air to one part sampled air, the odor is equal to or greater than the odor detection threshold. Each of the three or more sample's . -or' observations shall be separated by at least fifteen minutes . The burden of. rebutting the presumption of nuisance created by this subsection shall be on the owner. or operator of the source. (c) Odor in the ambient air shall be deemed to constitute a nuisance if any substance or combination of substances is present at a concentration in excess of any concentration stated in Table -23-1 of this section. The burden of rebutting the presumption of nuisance created by this subsection shall be on the owner or operator of the source. (d ) The commissioner may determine that an ambient odor which does not exceed the limits set forth in subsections (b) or (c) of this section nevertheless constitutes a violation of subsection( a ) of this section. October 1990 Page 23 - 3 Table 23-1 Odor Limit Value in parts per million, fifteen-minute average Compound Concentration Chlorine 0.0240 Ethyl acrylate 0.00037 Ethyl mercaptan 0.00040 Formaldehyde 2.49 Hydrogen- sulfide _ _ 0.0045 Methyl ethyl ketone 17.0 Methyl mercaptan 0.0010 Methyl methacrylate 0.34 Perchloroethylene 71. 0 Phenol 0. 12 Styrene 0. 15 :.. Toluene 11 . 0 1l- 13 3114-14 1 — 1 ro —li ll� � ! l-fib a!�d� ate- .� - � �� !� � ,�.. �< �- •� ��- �� � � � �� �- �„� ��- �� �� 70w:n /JC V/ SotdA ?d C a y 1540 SULLIVAN AVENUE SOUTH WINDSOR, CONN. 06074 soe•co� AREA CODE 203/644-2511 July 19 , 1989 Mr. Thomas Flynn South Windsor Metallurgical, Inc. 300 Rye Street South Windsor, CT 06074 Dear Mr . Flynn: As follow-up to our telephone conversation of July 19 , 1989 regarding the chemical odors noticed by area residents , I appreciate your assistance in resolving this problem. As I have reported, residents have noticed said chemical odor in the area of the South Windsor Metallurgical Facility on numerous occasions in the past. The latest incident was on July 18 , 1989 late in the afternoon between the hours of 4 :00 p.m. and 5 :30 p.m. . The odor has been variously described as an iodine-like odor and as a sweet/sickening chemical smell. Please contact this office when further information is available. Thank you for your cooperation. Very truly yours, C. F . Shaw Assistant Director of Public Works CFS:bmr cc: Robert Deptula, Environmental Health Officer Michael Gantick, Director of Public Works 3 ' 36t fTr sic v o-& DA rE TIME Q Q M QF �. .HP. ONE UMBER .... � - :. .EXTENSION I `i MOSSAGE �I i SIGNED LITHO IN U-SA. _ TOPS 1p FORM 3002P South Windsor ,H[ Metallurgical, Inc. A Handy&Harman Company 300 Rye Street, South Windsor,CT 06074•Telephone (203) 282-0871 September 25, 1990 Mr. C. F. Shaw Assistant Director Public works/Pollutionn Control Town of South Windsor 1540 Sullivan Avenue South Windsor, CT 06074 Dear Mr. Shaw: ThI8 letter will confirm the discussion which you and I had on Friday morning, September 20, 1990, in reference to the odor complaint which you received from Diane Wicks of 121 McGrath Road. As I mentioned, we did investigate the odor complaint at the above address immediately following your call around 9:00 A.M. We did not detect any sulfur odors in front of or near the above address. Upon further investigation, we did detect a sewer gas odor above the grate of the roan drain in front of the house at 121 McGrath. I suspect that the sulfur odor may have come from that particular road drain. While returning to the plant, we stopped at the transfer station at the corner of Rye and Troy and did detect a sewer gas odor coming from the vents of the transfer station. While the odors at the transfer station and at 121 McGrath were similar, I doubt very much that the odors at 121 McGrath came from the transfer station because of the wind direction which was out of the Northeast between 8:00 A.M. and 8: 35 A.M. As you have suggested as a means of locating the source of the odor at 121 McGrath Road, you were going to arrange to sample the road drain at the above address early in the week of September 24, 1990. Upon completion of your odor investigation we would appreciate receiving a copy of your test report. Enclosed is a copy of the chart recorder for both wind direction and speed for the date and time in question. Should you have any questions relative to the recorded information,. please do not hesitate to call me at the plant. Sincerely, Ed Kish Chief Engineer EK/mef Enclosure Fabricators of precious metals,special metals and alloys•Refiners of silver, gold and platinum 4✓ � + 1 I I 1 5 I 10 I 15 20 25 jr 10 I +10 120 30 (�0 �0 90 101 27 360 90 180 1120 � 40 I ; boll �80 �,o° All Lu �D- �o�/ /� Sa��h �' ! 1. I_ - - � (��1�1� •I .I I I I I) I:I G U 1 11 �a lit- It1�i1 Ia 1 . • (I I �; � �!1• � ��:,�r�°� III i% I l li J 10 '15IIf 20 ilt � � �►0 I I I IT }laI� 10 20 30 40 50 0 ' 1 27f III 180 I 20 40 6 8 0 0 100 a _l 1 _1 l.I I � 1�� ���.;; l I_ Ilf �I► `- ►����I I IIII Ill... . J LI.1111 �lll !. 1 �,: l 1.1 L11I111!1-���,:�.7::I I II IIIII .I� .��� II►I IIII III I►II � IIII illy IIII I I . I I III L '{�,�����r��;l �'iiii11111 II .I IIII I „s... -,PuA-� 5 , V-.� AIL a-el y -74 ao e,/ 10—1 10.919 F: 17 ^.....'f- SIGNED - UTHO IN U.S A. TOPS 9 FORM 3002P c��� VV4 111-i a11� �� I'. S=�'_ q z �.� !�vz.�ti� �L r� C A�'�'�' .G�.-a� �n�L�N^ �. .ate, p� �� r� �`�.���. ��� �� � � ; : �� r ,,, i ,, i� �� ;; ij I!, ill ji I 'I 'I I4 li _ f I �I I :.a ; � - ,.• ��—f- f L - --—� - _� �� �----�� ti'�- p ----------------- --- --- �. --- --- �T p ��v� � �- � ------ _ ------ J��n „ i - - - --- - -- ----------=------- Z) __ a1� ---- -- -- -- - -__ ----- -- -- - - -- _ —_____ —�"-------- --��o,��Q--- -- - - --- sou _. - ----- --- -- vice�� NA - -o� - - _-- _�- -� Pam_- - -- --- ----- -- - ---- ruwc � i pw Ir IMPORT IIIISmtry CAQ TO. A Q� .M. L DATE TIME WH LE YOU ERE OUT M OF PHONE Area Code Number B�clmeiu Q FAX 0 MOBILE Area Code Number TELEPHONED` SE CALL WAS IN TO SEE YouRETURNED YOUR CALL WANTS TO SEE YOU WILL CALL AGAIN WILL FAX YOU I IURGENT f� Message ve Operator - PACE G4�0- - - -- --------- - -C2�.L 1J4- - 5-4 6 - ---- - ., - -- - d- 16--- - -- - - — - ---- �u - - --- --------- ------- t- S ice 'PTI O- - :._..:�.ce+.._.-...:..�.—�--s.nv=:.....� ...m:..r.--_.gym..-•�.". - 1 �- ri �- -. .- v>�::: ..:..v..,.-.. i t,�....1-�:a.w..h�.✓x.asR.:r�.-tiYira..a i...na_. a....�.e:s.;+f+-far...+w�.�..,.:.a_.ar i- "-....-..�..r�....-a_a...e..m� .. .. - r.a.-n- .x inn-.. -i._ kr'si.eca.�.s:.a'� _�• FF t 1 k i if Sec. 22aa174-18. Control of particulate "emissions'" ( a) 'Visible *Ohniz4iosus* * (a) ( 1) Visible *emission* restrictions for ''stationary sources . " ( i ) No 'Person" sna il,l cause or permit the "emissiranO of v; Mite °'air poilt<ttants" of a shade or density equal to or darker then that designated as No.. 1 on the ' .ingelmann chart" or 20 percent *opacity. * v-p rson" may discharge 'air pollutantsw into the atmoophere from any "source* of "e ission^ for a period or periods aggregating not more than 5 minutes in any 50 minUtOs, provided that said "air pollutari%s" are of a shade or density not darker than Ko. 2 on the "Ringelmann chart" or 40 percent - �opacity �` Operi urning conducted under provisions of section 22a-4';I'4-10 shall not be subject to this subsection. (a ( 2) risib e "emission" restrictions for "mobile No 'person" shall cause or permit. the "emission" of nisi Ie "air- pollutants" from gasoline powered *Mob! le So4urees' for longer than f i ve (5) Ct;A5ecut.-ve seconds. ( a ) No "person" shall cause or permit the "emission" of clearly visible "air �,r�iltatar�ts" (comparable to a shade or density equal to or darker than No. 1 can the ":Ri.ngeimenn chart" or 20 percent "opacity" ) from diesel powered motor vehicles for more than ten (A) consecutive seconds, during which time the maximum shade or density of "emissions" shall be no darker than No. 2 on the "Ringeimann chart" or 40 percent *opacity. * ( a) (j) Exceptions for uncombi.ned water. Where the presence of uncombided water, such as water vapor, is the only reasons for the failure of an emission" to meet the requirements of this regulation then the provisions of this r�egulation4 shall not apply. (a) ( 4) the followinq shall, he exempt from the requirements of subsection (a) ( Y Antique aut::�nob les over 30 sears old; i 1l i Vehicles used exclusively for racing -, and JL_iha i a ' rair Maven Health De artment TU MaLn treet 09SUVATION OF AN AIR POLLUTION vAOLATION violation No. VISIBLE E"MIS aNg Too, Mr a rt -wiser, 6Ii. r Man fau ..firing Company_ 87 Main Mtraet, Fair Haven, (;onnectit:Ut 06000 _ ' 't9ta neeto'� ai�� xavri�-' onnecticut� �'Z` ova n �: n titLat c ��o atit�n s`i" � 'e� cmi trative Regulation, for the Abatement of .sir POIlUtion 22a-174-18 (a) ( 1) ( i ) (any opacity in excess of % ) . At 8 .25 on 4/29/87 dense black smoke of 0% opacity was observed emanating From 4he.a_.-H dykY the #3_poi er at`rie above--cited premise for a duration of 1-0 minutes. Pursuant to to Act 237 and. Section 22a-2a-l of the R.egnat ions of Connecticut Mate Agencies. This constitute a violation of Section 22a-174-18 ( a) ( s) ( i ) of the Connecticut Administrativ Regulations for the .Abatement of Air Pollution which stipulates that "no- -= person shalt cause or permit the emission of visible air pollutants of a shade or densi°y, equal to or darker than percent opacity. Observation was made from Main street. _ by Jane Smith _ _ of the Fair Haven Heal h Departmelnt , - Gland eras �r�om��e�-No�t�i — at apprc�xi'matel tt?P also the a,tached investigation report. Please sijbMit :in writing to the address below, the details of any corrdctiv action taken , or proposed corrective action including a schedule for completion of such act-ion. A copy of this observation report including details of trie investigaticn will be sent to the Air Compliance linit of the Connecticut Department of Environmental Protection fifteen days, from this,-- date. Responses on your behalf will be considered in recommendations made to the Cor.4nLS3io er of Env ironmen a Grote tiicon. DA'TEd. 1;>8' ohn Doe, DIRECTOR OF HEAL,TY i Haver, t1ca`l-t-11-1 M,�in_ t�W.�- �_ 'aiL° Rave, C`l` 01,000 - TELEPHONE !4U31ABIEH; ReCC3,mmend.at ions for actions -o be taken by the Connecticut Department of Environmental Protect ion' Signed.- Ji����� _ I IV'v�E T IGAT R DIRECTOR AL'T`H OBSERVATION OF AN AIR _ POLUrrtON VIOLATION Vio-Iation No. - VISIBLE MISSIONS SWj���t The* To owing cons itutes W a c anon � t ���an��iscratxv� Regua at�c�ns f or the Abatement of Air Pollution 22a-174-18(a) ( 1) M zany opadity in excess of � ) At on , dense smoke of opacity was obser-v_ed emana c� from�e star. of the �y®. a�the above-cited pram for a duration of minutes." Pursuant to Public Act 237 and Section 22a-1a-1 of the Regu ations of 1onnecticut State Agencies. This constitutes a violation of Section 22a--174-18 (a) ( 1 ) ( i ) of the Connecticut ; Administrativt Regulations for the Abatement of Air Pollution which stipulates that "no person shall cause or permit the emission of visible air pollutants of a shade or density equal to or darker than to percent opacity. Observation was made fa om _ by _ ��� of the i11eaI L� Department . W47r 7P w�a �om LddC; �i � at approxzma y � 'mph. See also the attached investigati - report . Plese submit in writing to the address below, the details of any corrective action tamer, o.- pr.oposed, corrective action including a schedule for completion of such action . A copy of this observation report including . details of the investigation will be sent to the Air Compliance Unit of the. Connecticut Department of Environmental Protection fifteen days from this date. Responses on your behalf will be considered in recommendations made to the Commissioner of Environmental Protection. DATED: - - --- --- DIRE CTOR OF HEALTH TELEPHONE NUNI BER Recomend.ations for actions to be taken by the Connecticut Department of Environmental Protection, Signed: _ Signed: INVESTIGATOR - DIRECTOR OF HEALTH TUH 14 '_iI I 1 '_ .I- - -------=----------------------EXAMPLE--------- INVESTIGATION REPORT VISIBLE EMISSIONS For 31ispecte y i c tl 3 Fair Haven �1Ppar,�.ment of Health i Main Street , Fair Hive^., -- T e o n e N tarn e r 3 1, Company fame: riser' s Manufacturing Company Company Contact : Ro ert iser Telephone: (203) 999-7378 Street Address. Main treet M `own: Fair maven Violated Sections 22a-174-- 18 (a) ( 1) ( ) Equipment Responsible: Type & Manufacturer' s Identification. (e .g. Babcock and Wilcox Mfg. boiler)'— Cdn�tro-Equipment : n'T a na :anuxacturer' s Identifieastio _ __a_-_.-� -- - - - - r Investigator' s Finding: ( Include Schematic/I)ia� if necessary) ( Include: Permit information, Fuel Burning Equipment-Fuel Identification , Firing Rates, -Process E ui ment - Material Tn uts, Pro action Ca acit , Production rate Purina lnS ection, jear�...�Tem eratures, etc. Control Equa meta - Art erburr.er Temperatures, Scrubber ar Ba--g-M:Yuse �ressu e- __.A.C* F.M, etc. ) _ - - ource was swit.c inch t e No. 1 o-3 er tF .�iatura Gas- w� -Tore—R the No. oi—er-t6 1 -mb to� maximum gyring rate wh cE- Sunsequent inveat:.gation revealed an�ustrrtentYorr= m to the r9 elmas-s tuel air ratio ^C}I1tL`�i V iVe. ------ _ ReCCmidendation - HaVe Dut�iC�e—a�rV1Ce-e3'l�l nee r recall rate this-mixing controT-75-7-ve, Additional Reports Rendered None Case Development History ( Include: date of violation , date source received written notification, source response ate ,`�cor�pZ lance inspection: da-e , �` ?ow-+ua !ewters , er_c. ) Wda�ttee•vinla_rion issued ! , source received V atlol response at e lance inspection, _ ilFx, termiF 1on CdSe Invest_gaTed by Jane Stith Director of Health Signature - -�- -date: 5/13/87 I)SSTIGATION REPORT FOR VISIBLE EMISSIONS F6r Suspected Vio at ions of 22a-171-'ILE71_a ) Company blame: Company Contact., -- - ---_a_ Telephone: Street Address: Town. ViDlated Sections 22a-174- 18 (a) ( 1 ) ( i ) Equipment Responsible. Control Equipments Investigator ' s Finding: Additional Reports Rendered Case Development History Investigated by: Director of Health Signature: Date: JUN 14 ' SiO 1`= : 04 20356GG144 Pi CIF . 00,E! i 5 n I NVEST I GAT I QN REPORT FOR FUG I T I VE DUST For Mspectea V IB at ions o ;- -L 0 1 ) Company Name; Company Contact. Tell 7 ltp's:E)3�a: Street Address: - _ _ _ Town --- --- Violated Sections 22a-174- 18 (b) t - Equipment Responsible: - Control Equipment-, Investigator' s Finding: Additional Reports Rendered Case Deveiopment History Investigated by: Director of Health Signaturet Date: JUH 14 ' 9L1 15 : 04 _203566 144 F'RG1: . 007 OBSZRVkTION OF AN AIR M S Fair Haven Health Department 10 Main Street Fa i r Haven Violation No. To.r Mr, JaW CAS 7ohnson, Process E1_9i F - �ect: rivate Sewage Treament FaCl 1ty, dater Roa , Fair Haven, Connecticut 06000 rat e following constitutes vlolat o Zs o the A n st iive Regulations for the Abatement of Air Pollution 22a-174-23-(a) ( 1) V I DLAT 16RT—sT - - - ------ ---_ While responding to a complaint , at 5 :00 on 5J1/87 , John Smith of. th+ Fair Maven Health Department detecte-d a(n) tcl-c7 a one extremety strong very strong - definite odor resembling�urzit'sewa_- The odor was etected at Water Road a locat onnownwin b tthe above-cited premise, but was not aetectea at Lucky Street Upwind of the premise. The odor, considering its nature, concentration, duration, and location is deemed objectionable. This notice is issued pursuant to Public Act 237 and Section 22a-2a-I of the Regulations of Connecticut State Agencies. This constitutes a violation of Section 22a-174-23( a) ( 1 ) of the Connecticut Administrative Regulations for the Abatement of Air Pollution which stipulates that "no person shall emit or cause to be emitted into: the outdoor air any substance which creates an objectionable odor beyond his property line. " See also the attached investigation report . Please submit in writing to the address below, the details of any correctiv action taken, or proposed corrective action including a schedule for completion of such action. A copy of this observation report including details of the investigation will be sent to the Air Compliance Unit of Connecticut Department of Environmental Protection fifteen days from this date. Responses on your behalf will be considered in recommendations made to the Commissioner of Environmental ?protection. DATED D I RECTOR OF HENETP Fa r F3aven Hea 1 t h I� a�rt:r�ent L - -- -"Street Fdlr Haven, CT TELEPHONE, NTUNI EER: 555-1212 - - Recommendations for actions to be taken by the Connecticut Department of Environmental Protection, Signed: Signed, Tr7T7sTTr.amrP T)TPr1CTnR CF HEALTH TUby 14 1 5: 0r 2,0,3566r 1 44 F AGE . 008 v o -- ----------------------w.----EXAMPLtL'--------------------v— I NVEST I GAT I ON WORT FOR CONTROL OF ODORS Suspected violations of 22a-174-23 (a) ( 1) Fair Haven Deeartment of _Health 10 Ma'n Street , Fair Haven ,-Ct ,- TelepFone N1= ert Company Name: Private Sewage Treatment Facility Company Contact: fir. JacR Johnson— Telephone: ( 203) 999-1111 Street Address: ater Road— 'Down: Fair even - violated Sections 22a-174- `3 (a) ( 1) Equipment Responsible: Multiple Health_ Sewage Stud e _ Incinerator Control Equipment: Wet Sc:�uu and ter urner investigator' s Finding: ( Include Schematic/Diagram if necessary) ( Include: Permit information, Fuel. Burning Equipment-Fuel Identification, Firing Rates, Process ui ment - Meter a In uts, -Pro uctron ap_ ac y, Produ_ct�can rate during inspection,- HeartTemperatures, etc. `- Cfontrt3�_ u� ment --Afterburner Temperatures, Scru er or Bag QUse �ssure r� A. `-F.M, etC. --- - - S u e Fee Rate at 35b`gp` earth- temperature note at 11 'in # 000- Normal—operating temperatures noted u�C?nLl h A.M, - P.M. were 00- in eart an -1 SUO in heartAbnormal earth temperatures due to operator ma unct�r�n in ai�zn to re u ate s :ure1 content . Recommend insta _ation of s use ee rate and mo7sture content automatic relator. Re__er to DEP ter bssuance of State Order --- tC3 e`��.&a 1 Lc t1fS G` �Ltlpm nt s Additional Reports Rendered Gperat®rs' temperature strip chart attached Case Development History ( Include: date of violation, date source received written notification, source response date, com lance - ins ect� )n date, foll-ow--2p letters,etc. ) date of violation ; received inspection see attac.,e report nc u e how the premise was veri ie as the sou rce-QT_-tom air poITution robTem ex -�detecte ownwinr Yet not upwin Investigated by Jane Smith Director of Health. Signature Date: 5/31/87 - - JUhd 14 90 15: 06 OSSZRVATION OF Al AIR Ri3LLVT I ON VIOLATION ODORS Violation No. s T e a awing caristitutes vlolati6n(s)of the Administrative RRegulations for the Abatement of Air Pollution 22a-174-23-( a) ( 1) While responding to a complaint, at on o.f the Health Department-Tetected a(n (circle one extreme:ty T�strong - very strong - strong_definite odor resembling oc or was detected at a location downwind--a the- , above-cited premise, but was not etecte at Upwind of the premise. The odor, considering its nature, concentration, duration, and location is deemed objectionable. This notice is issued pursuant to Public Act 237 and section 22a-2a-I of the Regulations of Connecticut State Agencies. This constitutes a violation of Section 22a-174-23(a) ( 1 ) of the Connecticut Administrative Regulations for the Abatement of Air Pollution which stipualtes that "no person shall emit or cause to be emitted into the ot,tdoor air any substance which creates an objectionable odor beyond his property Line. " see also the attached investigation report . Please submit in writing to the address below, the details of any correctiv action taken, or proposed corrective action including a schedule for . completion of such action. A Copy of this observation report including details of the investigation will be seat to the Air Compliance Unit of Connecticut Department of Environmental Protection fifteen days from this date. Responses on your behalf will be considered in recommendations made to the Commissioner of Environmental Protection. DATED: DIRECTOR OF HEALTF TELEPHONE NUMBER: - Recommendations for actions to be taken by the Connecticut Department of Environmental protection: signed: Signed: INVESTIGATOR DIRECTOR OF HEALTH - TUN 14 ' 90 1 5 : 06 2:.E1356t-61 44 PPGE . tt09 H • K A J I NVEST I GAT I ON REPORT FOR CONTROL OF ODORS Suspected violations of 22a-174-23(a) (I ) Company Name., Company Contact : -- -- Telephone: Street Address: ..�..__�.. __�.- 'down: Violated Sections 22a-374- 23 (a) ( 1.) Equipment Responsible, Control Equipment: - -- - - -� - Investigator' s Finding.- Additional Reports Rende± ed Case Development History: - Investigated by: Director of Health: Signature: Date: JUh1 14 ' ` C-1 1 5: Cl r' 20351666144 PAGE . 0 1 1 SENT BY!'D. E, P. Waste Bureau 5-14-90 ; 10"48AM 2035664924->203 644 3781 ;# 1 3 STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PRO ECTI0N yi ��6�4,��.� •i t L�-t.rr; 9. iti.�s�.r"L IJ h�-i�.ad� ;, i:ter= r. �� ,y' �`w.""�_,__�•. ,.,,r "��: - �a a i ;F i (Primed on Recycled paper) As Capitol Avenue i I<I"ord, CT 06106 An Equa! opportunity Employer JUN 14 ' 61] 11 , 53 2035664924 PAGE . 001 SENT BY:D. E, P, Waste Bureau ; 6-14-90 ; 10:48AM 20356649244203 644 3781 ;# 2 STATE OF CONNECT'ICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION , Bob Deptu-La South Windsor Health Department South Windsor, Connecticut Dear Mr. Deptula: in rasponse to our recent conversation concerning the Delegation of Authority Program, I am faxing soma relevant literature which will hopefully give you a more detailed picture of what the Delegation Program entails and how it is implemented. Includad please find: 1> a short description of the Delegation Program 2) a sample of a typical Memorandum of Agreement - 'which is the vehicle lased to delegate authority to the local Health :Director 3) a sample of the forms used to report investigations of air and water pollution violations 4) inspection information, for six of the delegated categories of water pollution problamn �) a copy of the Regulations of Connecticut State Agencies ralatirg to the Delegation of Authority (22a-2$-1, 22a.2a-2) A''Iso Included is an application for DEP Delegation of Authority. Please note that when filing an application. the Director of Health and Mayor ign on the last page. PO"Owing receipt of an application for Delegation of ,Authority, the DEP must publish a 30 day legal notice of such a.pplicatior, in a newspaper having general circulation in the municipality affected, The notice must indicate the scope of delegation requested in the - Delegation Application. A copy of such notice is also sent to the C,QRUTt ,ssioner of the Department of Health Services . Following such 30 day nottee, if no request for a public hearing or adverse (Printed oa Recycled PILPtr) 165 Cepltol Avenue s Hartford; CT 06106 An r'qual opportunity Employer Uh! 1 4 ' 3E� 1 1 : �4 2035664924 PAGE . 0Cj2, SENT BY:D, E, P, Waste Bureau ; 6-14-90 ; 10*49AM ; 2035664924-+203 644 3781 ;# 3 comments are received, the DEP contacts tine Director of Health as to its response to the application (approval o:: disapprovai) , if all application is approved the DEP prepares a Memorandum of Agreement (MOO) for signing by the Director of Health and the Commissioner of Environmental Protection. The MOA is the legal document which officially delegates Specified authority (air pollution and/or water pollution investii3ative power) to the local Director of Health, If you have any further questions or need more information on any facet of the program, do not hesitate to contact this office at 566-2860 Sincerely, Judy Belaval Waste Management Planning & Standards JUtd 14 90 2035664S24 _.. -- SENT BY-D, E, P, Waste Bureau ; 6-14-90 ; 10:49AM ; 2035664824-4203 644 37B1 ;# 4 _ ��LEG.41`Ic7N OF A�t)i'Ht ,� Sections 22a.-2a-1 and. 22a-2a-2 of the Regulations of Connecticut State Agencies establish the mechanism for the Commissioner of Lnvironmental Protection to delegate authority to municipal and district (.regional) health directors for the investigation of certain types of exist_ and potential discharges into the water and air of the state. Delegation is voluntary on the part of the health director. Specifteally, the present scope of delegation available to health directors _. includes the following: (1) Water: Domestic sewn:tc ollection and treatment (privately owned) agricultural wastes; blowdown from heating and cooling, building floor drains, commercial laundry wastewaters, stormwater, swimming pool backwash and water production wastewaters, (2) Ai;.: visible emissions, fugitive dust and odors. Additional areas of delegation, including inventorying conditionally exempt small quantity generators of hazardous waste, investigation, of noise complaints, verification of underground storage tank removal, and discovery of unregistered underground storage tanks, are being considered as amendments to the present delegation regulations, The delegation regulations allow a health director to perform complaint and compliance investigations a:-. an agent of the Commissioner. As an agen the health director's testimony will. i�a valid at administrative & d court : ea j. gs on Department enforcement actions in the delegated areas. This program represents the establishment of improved relationships with local and regional health directors and will provide for improved enforcema-it of Department rules and regulations. With the establishment of the Department in 1972, much environmental responsibility was taken from local health directors. This caused tension which is still in existence to some degree, In the mid-701 s, delegation of authority programs to local agencies for the Department's air program were ended. This furthered tensions. The current delegation program represents a good faith effort on the part of the department to strengthen relations (both cooperative and communicative) by recognizing the -- importance of the local agent (health director) in carrying out certain Department roles and regulations. In fact, some of the enforcement areas under the delegation program either are not or cannot be addressed by the Department. The program will provide for the expansion of Department resources for pollution problems that are local in nature, require InLmediate response time and are time consuming. In early 1986 following adoption of the Delegation Regulations, Commissioner Stanley Pac forwarded correspondences to all municipal and district directors of health encouraging their participation in the Delegation grogram. During the spring of 1987, applications from thirteen health directors representing thirty-six municipalities were approved to receive delegated authority, Necessary public notices and training requirements of the regulations had been met; - TuH 14 ' 9i_} 1 1 : ` _) SENT BY,'D. E, P. Waste Bureau ; 6-14-90 ; 10:50AM ; 2035564924-4203 544 3781 ;#,5 71he official merhanicam used to delegate authority to health directors is a memor.anduza, of agreement (MCA.) , (A copy of stamiord's MOA is enclosed as an example: ) In accordance with -the Delegation regulations, the MOA is between aao Commissioner of Environmental Protection and the Director of Health, Thus far fourteen MOA's knave been fully executed, having been signed by local directors of health (representing 4.1 towns) and the Commissioner of Environmental Protection. Reporting and enforcement protocols have been established for each delegate and the DEP (LAPC, Air Compliance and Water Compliance Units) . The DEP's budget for the 1990-1991 fiscal year provides funding for the health director delegation of authority grogram. At this point in time, the funding level for the .subsequent fiscal year is unknown. In the event that fuming is available, the present health directors will receive first consideration for such funding. If there are funds that are and will not be used, the next health director to receive derogation will be given priority. Since the level of funding is fixed, this program has been administered on a first-come-first served basis. The MOA's are not contingent upon the availability of grant funds. Attached is a list of Health Departments (including associated Municipalities) which have entered Memorandums of Agreement with the Commissioner of Environmental Protection for the purpose of receiving Delegation of Authority. 11Jha 1 4 0 1 i e �;� (13 5 6f -1 9 2 4 F'rii; BENT BY.'D, E, P, baste Bureau 6-14-90 ; 10*51AM 2035564924-Q03 644 3781 ;# 6 MMORANDUM OF AGREEMEt;T _ This' Memorandum of Agreement made and concluded at Hartfoi d, Co*itecticuc, this second day of September 1988, by and between the Commissioner of �:�ry Yo�uttier,Cal Protection, duly authorized pursuant to Section 22a-2a of the Co: nuo ticut General Statutes, and the Director of HeaItt, of the City of Stamford", herein&ftFer referred to as the "Director" of "contractor" , shall be effec.rive from the 17th day of May, 1988, through the 16ch day of May, .1991. WTTNESSETH THAT: WHERE?:S, Section 22a-2a of the , cbhnBd�ticut adneral Statutes authorizes the Commissioner of Environmental Pro.tecti»pn'3to delegate certain responsibilities and functions to At%Y state or 2*,.gion*l agency or municipality of employee thereon;and WHEREAS, Section 22a-2a of the Connecticut General Scatutas requires that the Commissioner of Environmental Protection adopt regulations in accordance with Chapter 54 of tha Connecticut: Ceneral Statutes and said section: setting forth the scope of any such delegation; and WHEREAS, the Regulations of Connecticut Stare Agencies have been amended by adding Section 22a-2a.1, "Delegation of authority for the abatement of air pollution" and Section 22a-2a.2, "Delegation of authority for the abatement of water pulluti.on" ; and 'WHEREAS, for the purposes of Sections 22a-2.a-1 and 22a-2a-2 the designee is the ` local or district director of health appoiAted under the provisions of Sections 19a-200, 19a•2O1-, or: 19a-242 of the Connecticut Censral Statures; and 'vAiEREAS, the Director has submitted a request for delegation. within the soopes of Sections 22a-2a-I and 22a-2a-2 with the consent: of the Chief executive; officer f the City of Stamford by which the Director is employed; and WHEREAS, the 'hereinafter-mentioned designation of authority is with the consent of the City of Stamford; and NOW, THEREFORE, the Commissioner of Environmental. Protectiori dolls hereby delegate to the Director the following authority: 1. The authority to investigate certain existing or potential air pollution discharges ag described in Chapter 446a of the Connectiout General Statutes being limited to violations of sttanda.rds, criteria and other requirements pertaining to visible emissions, fugitive dust~, and odors contained in Sections 22a-174-18(sa,) , 22a-174-18(b) and 22a-174-23 of t' Regulations of Connecticut SCa Agencies; and l� V 1/ - - - 1iJhl 1 4 ' yi_t 1 1 : �;E: ?G=t,_;t=;C-.F) t�-4 rA-E . G=t06 SENT BY:D, E. F, Waste Bureau ; 6-14-90 ; 101*51AM ; 2035664924-+203 644 3781 ;# 7 2, The authority to investigate all points of existing or Potential Waste discharges as provided for in Section 22a-416 of the Conn-jec;ricut t,eneral Statutes being limited to sewerage systems for the treatment of domestic sewage which are owned by a person as defined in Section 22a.-423 of the Connecticut General. Statures, agriculture as define-d in Section 1-1(q) of the Connecticut General Statutes, blowdown from heating and cooling equipment, building floor drains, commercial laundry wastewater, cooling water (non-contact) , stormwater, swi=ing pool backwash, and water production wastewatar. A, Tho Director agreau as follows: 1.. To comply with all requirements set forth in Sections 22a-2a-I and. -- 22ae-2a•2 of the Regulations of Conneati:cut State Agencies; and 2. To make all reasonable efforts G's effectively and efficiently carry out the authority to investigate certain existing or potantia.l air pollution discharges as described in �,Chaptar 446c of the Connecticut Ceneral Statutes ba3ri$ limited to vical$#,Pns of standards, criteria and ocher requirements pertaining wtb ble emissions, fugitive dust, and odors contained in 22a-174.1.8(b) and 22a-1:74.23 of the Regulations of Connacti=cur Skate Agencies; and 5. To make all reason*,�Ie"efforts to effectively and efficiently carry out the authority to i'tvas igate all points of existing or potential waste discharges as provided for in Section 22a-416 of the Connecticut General Statutes being l mitad to sewerage systems for the treatment of domestic sewage which are owned by a person as defined in Section' 22a-423 of the Connecticut Gancral Statutes, agriculture as defined in Section 1-1(q) of the Connecticut General Statutes, blowdown from heating and cooling equipment, building floor drains, commercial laundry wastewater, coaling, water (non-contact) , stormwater, swimming pool backwash, and water production wastewater. 4. The contractor agrees and warrants that in the performance of this contract he Erill not discriminate or permit discrimination against any person or group of persons on .che grounds of race, color, religious creed, age, marital status, national origin., sex, mental retardation or physical disability, including, but not limited to, blindness, unless it is shown • by such contractor that such disability prevents performance of the work involved in any manner prohibited by the laws of the United States or of the State of Connecticut. If the contract is for a public works project, the contractor agrees and warrants that he will make good faith efforts to employ minority business enterprises as subcontractors and suppliers of = materials on such project. The contractor further agrees to provide the Commission on Human Rights and Opportunities with such information requested by the Commission concerning the employment practices and procedures of the contractor as relate to the provisions of this section and Section 46a-56. Ji_iil 14 9 0 1 : : 3 '2'0 3'5G64VD224 PH_ GF , 0C1 3 E N T BY',D, E, P, Waste Bureau 6-14-90 ; 10:52AM 2035664924-4203 644 3781 34- E, This Contract is subject to the provisions of Executive Order No. Seventeen ' of Governor.' Thomas J. Meskill promulgated February 15, 1971, and, as sa:h, thia t contrAet nay be cancelled, terminated or suspended by the contracting agency or the State Labor Commissioner for violation of or rorioomplinnoe with said Exacutive Order No. Seventeen, notwithstanding that the Labor ray not be a party to this contract. The parties to this contract, as pare of Uhe consideration hereof, agree that Executive Order No. Seventeen is incorporated herein by reference and made a part hereof. The parties agree to abide by said Executive order and agree that the contracting agency and the State labor Commissioner ahall have joint and several continuing jurisdiction in respect to contract performance in regard to listing All employment openings with the Connecticut State Employment Service. In witness whareof, the parties hereto have hereunto set their hands om the day and year indicated below: ATTEST J - Director of Ha,%Ith of the City of Stamford ~ Data u Mayor of the City af;StAmford t, Co=issioner of Enviroraental Protection J Approved as to form: Imo., Attorney General Dace: SENT BY-D. E, F, Waste Bureau 6-14-90 ; 10:52AM ; 2035654924i203 544 3781 ;# 9 = Rear 11-5-87 W1 FORM SEND TO: STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION ATTENTION JOHN CIMOCHOWSKI OR JURY BELAVAL LOCAL ASSISTANCE AND PROGRAM COORDINATION 165 CAPITOL AVENUE, HARTFORD, CONNECTICUT 06106 CASE NO. - W FOL•L 10N IMI1511GAIJO F2 WATER COMPLIANCE UNIT TOWN: DATE ALLEGED ,� -- - - -— SOURCE (Name and Address) TELEPHONE NUMBER LOCATION SITE LAND OWNER 2TATFAM OZ COMPLAINT Complaint Reeeivad by a Complaint Referred to s Dates INYEST,IGAT:1 glij1rogORT Description (Include Diagram if Necessary) JUri 14 ' 3:a : 1 : 50 20 56 9'24 Fi-6E 0 SENT BY:D, E, P, Waste Bureau � 6-14-90 ; 10:53AM 2035664924-+203 644 3781 410 kECEIVING STREM WATERSHED ACTION TO BE TAKEN AND/OR NEEDED TO ALLEVIATE CONDITION: INVESTIGATED BY DATE UNIT OR HEALTH DEPARTMENT TELEPHONE ITLMBER MAIL AMDUSS SAMPLES COLLECTED? IF Yes Describe on Separate Attached Sheet, O HUH 14 90 1 1 SENT BY:D, E, P, 6gaste Bureau ; 6-14-90 ; 10:53AM ; 2035664924-+203 644 3781 ;#11 -3- TIME SPENT IN INVESTIGATION SEND TO: STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION ATTENTION JOHN CIMOCHOWSKI OR JUDY BELAVAL• LOCAL ASSISTANCE AND PROGRAM COORDINATION 165 CAPITOL AVENUE, H4RTFORD, CONNECTICUT 06106 (Do not send copy to violator) ����*�������t������**��c��r���t��*��*�;�tststiF�r�F'�•�k�tk��������t�t��r�k�t��k�kr'c���s���tyti���e�t�r�kar,F�� DELEGATED CATEGORY CASE NUMBER IS THIS A FOLLOW-LIP INVESTIGATION? � IF YES,DATE OF ORIGINAL MESTICATION AMOUNT OF FIELD AND OFFICE TIME SPENT IN INVESTIGATION AMOUNT OF ADMINISTRATIVE TIME SPENT ii'tt'�r��ka��t1'�tsYtYeYSYst�tyYyY�Y'k�k�s���k7Ys��r7lsY�cs�ak�kvt�kot�tyirsktr��t�r�'d'tk'Actktk'�'��k kF�csksk�t�lr'rk��k'rk�1'�i's��rotst�ts�st�Etityk•�'tY+F+t FOLLOW-UP INVESTIGATION NEEDED? IF YES,SCHEDULED FOR - i ADDITIONAL COt-"BENTS: IS DEP ACTION RECOMMENDED? - EXPLAIN _i I_If] 14 90 1 1 . 59 — SENT BY:D, E, P, Waste Bureau 6-14-90 : 10:54AM 2035664924-+203 644 3781 412 ' *Requires DEP Attention Rev 5,/15/188 SEND TO: STATE OF CO'vNF:CTIOUT DEPARTIOENT OF EIV.1 ONMENTAL Yh�i1 t t.`I`ii ATTENTION 4O101 CIMOCHOWSK1 OR JUDY BEi \VAL. LOCAL ASSISTANCE AND PROGRAM COORDINATION 165 CAPITOL AVENUE, HART'F'ORD, CON0ECTI UT 061_06 AND TO: FACILITY OWNER DRY CLEANER INSPECTION FORM CASE NO. OWNER NAME OF FACILITY ADDRESS OF FACILITY TELEPHONE NUMBER BATE INSPECTED INSPECTOR'S N�-ME HEALTH I)EPT/"DISTR,ICT 1, Are There Any Floor Drains in the Dry Gleaning Area.? If yes, Where Are the Floor Drains Directed to? (Dye test if necessary) 2. Please Describe the Disposal Methods for the Following: a) Lint Filters b) Water from Water Separator �- Is Vater Used as a Prespotter c) Discliar a (bottom sediment) from the Still _Ti Ira 14 , 190 1 00 1�;_�;6E-14912-4 PAGE . C1 I SENT BY:D, E, P, waste Bureau 6-14-90 ;10254AM 2035664524-►203 644 3781 #13 —2- . 3. Please Describe Storage Conditions of Disposal Drum or Tarok Are Conditions Adequate ?__ Explain a) Is Storage Indcors or Outdohrs - ;> If Outdoors; 1) Is area Roofed? $ermed? ax Co_ 'r Uinecl ir. 5�:,,K• Manner? 4, Please Describe the Hauling Record: a) Name ai1d Address of Hauler 1) Is Hatiler Permitted? � b) Check Mauling Records 1) Mow Often is Material Hauled? 5, Is There Any Nun-Contact Cooling Water? a) If yes, How is it Discharged.? S. Check Air Vented from Cleaning area - Is 'There Any Drippage? Describe ----• - — - -- - - --�-- 7: Inspect tenting System from Still Area - Is There Any Drippage? Describe 8. Please Sample Any Still Discharge or Non-Contact Cooling Water Discharge, and Attach Results to This Form, A,M6 NI. OF FIELD AND OFFICE TIME SPENT IN INSPECTION AMOUNT OF ADMINISTRATIVE TIME ,56E4924 PNGE . r'i 1 1. SENT BY-D, E. P, Waste Bureau 6-14-90 1101,55AM 2035664924-r203 644 3781 ;#14 T • ♦ i�i ARRAS WHICH REQUIRE CORRECTION AREA CORRLCTION REQUIRED BY' DAtc -- - -- -- �----- Date - - -- -- _., - Dates Date -- ---- -- - - --- - - Date JLlH 14 ' 9 1:_ : 01 _Ei;; i-,.64 4 PAGE . 01 -1 SENT BY:D• E• P, Waste Bureau 6-14-90 ; 10:55AM 2035664924-y203 644 3781 415 Revised 12/9/87 i r r: itealth pepartment OBSERVATION OF AN A I R POLLUTION VIOLATION Violation N�, VISIBLE E.4ISSIONS u 3ect: The following constitutes a violation of the Administrative Regulations for the Abatement of Air Pollution 22a-174-18(a) (1) (ii ) (any rapacity. between 20% and 40% for greater than 5 minutes in any one hour) . At on , dense smoke of opacity was observeT emanating- fro the stack oTlFe aE-the above-cited premise for a duration of minutes, This constitutes a violation of Section 22a-174-18 (a) ( 1) ( aa of the Connecticut Administrative Regulations for the Abatement of Air Pollution which stipulates that a person may discharge air pollutants into the atmosphere for a period or periods aggregating not more than 5 minutes in any 60 minutes, provided that the air pollutants are of a shade or density not darker than 40 percent opacity. observation was made from by of the Healt Departmen . in was rom t e at approximately �mp . See also the attached investigation report . Please submit in writing to the address below, the details of any corrective action taken. or proposed corrective action including a schedule for completion of such action. A copy of this observation report including details of the investigation will be sent to the Air Compliance Unit of the Connecticut Department of Environmental Protection within fifteen days of this date. Responses on your behalf will be considered in recommendations made to the commissioner of Environmental Protection. This notice is issued pursuant to Public Act 237 and. Section 22a-2a-1 of the regulations of Connecticut State Agencies. DATED! DIRECTOR OF HEALTH TELEPHONE Recommendations for actions to be taken by the Connecticut Department of - - Environmental Protection: n Signed: Signed: I N;.'EST I ATOR RECTOR OF REALTH JUN 14 90— 1 `: 0 1 20 5664`-24 P H G E , 015 SENT BY*,D. E. P. Waste Bureau 6-14-90 ; 10:56AM 2035664924-+203 644 3781 415 - I WEST I GAT I ON REPORT FOR VISIBLE EM I S S I OILS For suspected VIOLA ons of 77a-M 'Ta-397) Company Name: Company Contact: Telephone.- Street Address: Town: Violated Sections 22a-174- A (a) (1) ( i ) ( ) Equipment Responsible: Con roi Equipment: Investigator' s Finding: Additional Reports Rendered Case Development History Investigated by: -- Director of Health - Signature: Date: JUN 14 9G� I : G�'� LU35664924- PA(_,E: . 016 SENT BY,*D, E, P. Waste Bureau 5-14-90 ; 10156AM 2035664924-Q03 644 3781 ;#17 NE SPENT ?r 1014 of AIF Pl?LLtl�i�si �I4LATLpNS SEND TO-. STATE OF CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION ATTENTION JOHN CIMOCHOWSKI OR JURY BELAVAL LOCAL ASSISTANCE AND PROGRAM COORDINATION - 165 CAPITOL AVENUE, HARTP'ORD, CONNECTICUT 06106 (Do not send copy to violator) RELEGATED CATEGORY VIOLATION CASE NUMBER IS THIS .A FOLLOW-UP INVESTIGATION? AMOUNT OF FIELD TIME SPENT IN INVESTIGATION AMOUNT OF OFFICE TIME SPENT IN INVESTIGATION - -- -- - �_ AMOUNT OF ADMINISTRATIVE TIME SPENT FOLLOW-UP INVESTIGATION NEEDED? ADDITIONAL COMMENTS: J U t1 14 ' 9 C1 1 E : i_1'_ 2035GG4:924 PAGE . 0 1 7 SENT BY:D, E, r, Waste Bureau 5-14-90 ; 10:57AM ; 2035654924-Q03 644 3731 cte� -L;3Gu J.4i ;1 W I 01sERVATION OF AN AIR POLLUTION VIOLATION ODORS ViOlat iotl No. E The following constitutes vice aticrt(s) - Regulations for the Abatement of Air Pollution 22a-174 -23-(a) (1) VIOLATIU - - While responding to a complaint , at on of the Health Department daticted a(n) (circle one extremety strop - verno µ strong - definite odor resew ing . The odor was etch-te ed at , a location downwin o e above-cited premise, but was not aetect-R-at Upwind of the premise. The odor, considering its nature, concentration, uration , and location is deemed objectionable. This constitutes a violation of Section 22a-174-23 (a) ( 1) of the Connecticut Administrative Regulations for the Abatement of Air Pollution which stipualtes that "no person shall emit or cause to be emitted into the outdoor air any substance which creates an objectionable odor beyond his property line. " See also the attached investigation report. Please submit in writing to the address below, the details of any corrective action taken, or proposed corrective action including a schedule for completion of such action. A copy of this observation report including details of the investigation will be sent to the Air Compliance Unit of Connecticut Department of Environmental Protection fifteen days from this date. Responses on your behalf will be considered in recommendations made to the Commissioner of Environmental Protection, This notice is issued pursuant to Public Act 237 and Section 22a-2a-I of the Regulations of Connecticut State Agencies. DATED: - DIRECTOR OF HEALTH TELEPHONE NUMBER: r Recommendations for actions to be taken by the Connecticut Department of Environmental Protection. Signed: Signed; J I_H 14 `It_i t = ; Ij 20-'_',566492 PHi.�E . 4J 1 t SENT BY:D, E, P, Waste Bureau 6-14-90 ; 10:58AM 2035564924-+203 544 3781 419 INVESTIGATION REPORT FOR CONTROL OF ODORS Suspected violations of 22a-174-23(a) ( 1) Company Name ; Company Contact: Telephone: Street Address: Town: Violated Sections 222a-174- 23 (a) ( 1) Equipment Responsible: Control Equipment; Investigator' s Finding: Additional Reports Rendered Case Development History: Investigated by: � _-- Director of Health.: Signature:_ Date: JU1-4 14 9i_+ 1 L 03 -- 2E135G6432 4 F'HGc . 019 SENT BY-D, E, P. Waste Bureau ; 6-14-90 ;10;58AM ; 2035664924-Q03 644 3781 ;#20 TIME SPEND" LN-1N'VF5TIGAj T0N o ISTC p0 Y.1l�2 YUL.ATIONS r SEMI? TO STATE OF CONNECTICU'T DEPARTMENT OF ENVIRONMENTAL PROTECTION ATTENTION JOHN CIMOO'HOWSKI OR JUDY EELAVAL LOCAL ASSISTANCE AND PROGRAM COORDINATION 16a CAPITOL AVENUE, HARTFORD, CONNECTICUT 06106 (Do not send copy to violator) DELEGATED CATEGORY VIOLATION CASE NUM.HER IS THIS A F011OW-UP INVESTIGATION? AMDUNT OF FIELD TIME SPENT IN INVESTIGATION AMOUNT OF OFFICE TIME SPENT IN INVESTIGATION AMOUNT OF ADMINIS I'RATIVE 'TTHE SPENT i FOLLOW-UP INVESTIGATION NEEDED? ADDITIONAL COMMENTS: J U N 14 ' 'S0 1 2 04 SENT BY-'B. E. F, +caste Bureau ; 6-i4-90 ; 10 59AM 2035564924-+203 644 3781 421 ,AAa STATE OF CONNE TI UT r DEPARTMENT OF ENVIRONMENTAL PROTECTION INSPECTION INFORMATION FOR DELEGATED CATEGORIES OF WATER POLLUTION PROBLEMS The following pages consist of information regarding complaint investigations for the six categories of water Pollution problems available for delegation to local Health Departments. A general description of the potential problem is included as well as recommendations for collection of information and samples. If there are any questions regarding investigations please contact the Water Compliance 'Unit, Additional training and informational meetings will be held with individual health deparetments as requested. Water Compliance Staff Contacts for Delegation of Authority: Richard Mason - Enforcement and Industrial Permits - 566-71" Tom L,inaley - Enforcement and Industrial Permits - Service Stations 566-5903 Robert Sannack. Chief' Field Inspector - 566-5903 Frank Ogonowski - Field Inspector (Service Stations, Floor Drains) - 566-5903 i P1�ots�: 16S Capitol Av+enuc HILrlfOrd, ConnMicu: 06106 tin Lqua! OppoFiuni{i,Emplovtr UH 14 IGi 7 : G_14 c4 3,5-6h4'1 a FA3E . i:l'� i SENT BY:D, E, P, Waste Bureau 5-14-90 f10.59AM 2035664924-+203 644 3761 ;#22 Tlie tee blowdcswrE ar k�Iaed.a some reairaulating of water as cppast+dall usually refersto a s a system .rt h whic there is anae t}'irn>a,�i g,yst'e.r. All of these asystetus are Product or non-contact systems. There is no other contaminant other than what chemicals may be water to prevent damage to t contact with a g he equipment, added 4o the A. w � Stall to me€£iugn size bailer w magnesium scale from bakir. ate.. is usually treated top •�.. treating the water S on the evaporator surfaces prevent calcium and maintain this sludge sin a Pteeipitste c The fluid go alcium and magnesium as Purpose of bottom. Wit, so it can be dxaif7ed a sludge and easily from the Sodium phosphate is the most common to precipitate calcium additive to the boiler. Its PH above �,� as trioalcfum is ne+<d.sd and may Phosphate. To force this reaction ash is organic additive �isy by used. �' hs much higher, To high keep the sludge fluid, an Some f°x'mulaClons ray, also include c the calcium, Magnesium iron and other metelhelstin $ agents such as gDTA to complex Sodium sulfite or hydrazine May oxygen scavengers to r+aduee t y b e teed in the surfaces. he degree of larger boiler systems as corrosion of the internal matal The valuma and frequency o f blown dt�� tsnce �„ � y discharge fluctuates t •° I s usuall or -mice a day, either m&nU&ll 3 hawe rs,r most boilers are y sma11 in the range of Ir7 to Y or autai�atic:aill IGO gallons per day �' and the volume The discharge can go to .the sancta used. to a leaching Q rY sewer,and depending streams, �io�.aev g system: The trend has been remove on the chemicals er many have been Permitted t to to them from storm drains due to o be discharged small other Permitted � � the small vclj'me, and because they to larger p _tee � charges, g rivers or y are often mixed with Three basic types of 0001.in& systems: - Once-through Coolie Open Recirculating8 vstem Closed 1Reciroulat S' g S oYystster, -- I• A once through use any once S system of non-contact wolf E el treatment, so ariviro cooling water does temperature affect an entai s not normally the receiving stream.. significance is related to their 0 Jut-,I 14 ' 9t' 1 c: ti5 0 .5664 94 Pf-�6E SENT BY:D, E, P. Waste Bureau ; 5-14-90 * 11 :00AM ; 2035554924-y203 544 3781 ;#23 The Departme� ,Itdoes sanitary sewers because they riot Pe�7xit Gha maJarltY of these ,in the sewer which could j are Uncontaminateduae E'ffl.�.ents t4 through cooling water G be Uaed for sewage Very sma11 up uydraulic capeCfty them to a stOrm an remain in he am sewer if it would be costly tics Of once drain or sirs contaminated. mere + or if there is a possibilit to redirect combined sewers no stream is v&"able Such as Y of them becoming recirculating, system May issue an Under to reduce the di n a �rban area With 8 flog through a 2• An open recirculating the water throe k g system is one which has a small g.. the equipment to be c reCirculates the majority of bleed-jiff to control the buildup and through a cooling continuously fed with clear P f dissolved solids. it tower, but evaporation, water to make up that IC is also amount lost through The most significant ., such as a chlorinated chemical additive to keep t• compound, or a complsX organic theme systems is a bi�dCtde p the system clean of slime growth, $anic compound, This is added There are a3sc, hu:�dredS Of farm�,latians for dis 6rsa agents, and. che�.atin g agents, p eta; anti-scaling but mange;lepoet permits most of Y be found to be thetoe se to be discharged to surface waters toxic to remain in small streams, 3. close d recirculating totally sraclosed ystems with compltes recirculation have no f however- ontin+sous discharge and �. results in them being she ligt�id, They are oe.�year during shutdown g dumped or drained on a scheduled basis ntenanct: This equi_Pment utilizes ve t` water, or no water a y high concentrations of , discharge concentrationall• They may use chroatates u chsrrFica.6s added to anti-freeze i is 1pPa) r soluble oils p t® 2000 rpm{acceptable f some of the piling is outdoors. � or in some cases alcohol or There should be no waters, or subsurface dramas on these systems depending on their c Systems, They might be 11 wed which . lead to surface Pexrait is required character, but most �_. to the sanity �; ired for discharge. ill need to be contract hauled.ry wee Tnspectioti Checklist 1. Inquire about 1!ind out volume and frequetnc a of heating or coaling System as Y Of discharge. Verify piping system. above. 2. Find out ghat if an frequencY cf additicra, P-.ecord chemical additives are chemical. vendor's name being added and 3. Of DEP. Co yhe Permit shou�a be avaick to see if dischargeis permitted through Water ComDliance Unit Palable at site, - SENT BY:D, E, F, waste Bureau 6-14-90 ;11 :00AM ; 2035654924-4203 644 3781 ;#24 a WQ susPact that residertla] pooh. filter back-aashea and pool draining$ have been' the sources of some of the fish kills which have beery investigate$ over the past several years. The backwash cont suspended Solids, to o er chlorine, and possibly low PH as a result of cha�nicai ,�aetion �,f al These discharges should not be directed to surf®ce water the chlorine. practice £s,r many local health deparCmersts to waters, it is standard discharged to a subsurface disposal system separates from she sews e the poal backwash to be This `is a good practice and could be adopted by all health departments, g system, However, many of the pool bottom drains from in-ground constructed to discharge directly to surface war pools have been the surface water if chlorine is stillpresente s, This may cause roxicity in has bfiComs depress due Y or if the pig of the pool water P o the use of chlorine, The bottom drains could be directed alit to the sanitary sewer with the approval Of the mun�.ci mjr surface waters$or storm drainsland llowed are&sto leach ar+t3 e e � dsurfaee away from rate, SENT BY:D. E, P, Waste Bureau 6-14-90 ;11 :01RM � 2035664924-E03 644 3781 ;#25 s ` WATER Thasfi waZdYs are generated from operationsrosor at drinking equipmoirsent. or from residential, at or industrial wateroduction equipment. W&S tewatars from residential treatment systems are not actively regulated by this Department. y Reservoir water is typically treated with aluminum sulfate to suspended particulate is and may remove sludge which is produced and the filtertcleanngs or for nbackw backwash al ha a re g• The a�.tzm be Settled in separate treatment facilities prior t4 their discharge quired to either the rese r�c>ir, the treatment system headworks or a receiving stream, ga back to These are the only treated effluents allowed to be dischargedtoa class AAsurface water. Some commercial and industrial facilities treat incoming grater for use in some procssses or in their boilers. Water softening equipment results in a periodic discharge of regeneration water which would have law or high solids, These need an approvad pH adjustment system at a minimum 8 pH and from the Department. and a permit JUN 14 190 t] BENT BY:B, E, P, Waste Bureau ; 6-14-90 ; 11 -*01AM 2035664024-4203 644 3761 426 �'l.AC�R b Aruc This is one of the races` ffeq uenty straight forward. to correct. Pxobleuts found and one of the most _ The department does not s.11ow any interior drains to - surface water$. There is too Much enter storm potential for a spill to occur or Pipes or waandown. The Department also prevents these Exam bean for floor subsurface system onnected to with the exception of restaurant or bathroom floor drains, a Floor theirs are approved for connection to the sanitarys treatment. The most cotmmon application is automobile service static. fuel staGio'ris ewer with body shops, rustproof operations and automotive dealerships. ns including The floor drainage from these operations may contain gasoline, oil, bra fluid, kerosene, any: coolant in addition to sand and 6 '?base d brake not be used for disposal of concentrated wastes, rit, rains should The Department rewires these Floor drains to be connected to a miniII;:m capaci t oil arid �' grin separator before discharge to a sanitary gallon or, in steak net se�rred }� a holding gams must be y sewer; a holding tank with high level alarm. The pumped by a 'licensed waste hauler. In many investigations, floor drains will determine their poi.n. of discharge, need to be dye tested to any location, will need i be gear ed with which are not acceptable in situations, groundwaters are contaminated andlineed t�inb�ed soil. In sons treated. C�zntaminated soil Mu t be analyzed and approved b the out and disposal at a sanitary landfill Y e Department for Floor drains may also be often results in floor drippi;�gssealed Permanentlyhowever th with concrete - "ling swept outside. is r� i U hd 14 ' 9 0 1 : : SENT BY:D,.-E, N, Waste Bureau ; 6-14-90 ; 11 :02AM ; 2035564924-�203 644 3781 ;#27 b w f The problems expsr"ced with these operations result from the dry cleaning Portion of the businase and not the detergent laundering portion. The main ground Potentialfor rollution comes from the Spillage or discharge of solvents to the the vast sa_ a—e or subrsurface disposal system. Tetrachloroedhyiene is used in the �rast majority of dry cleaning shops as the cleaning solvent. - Spillage may come from storage of the solvent in drums or tanks but more often a problem results from slcppixtess or disposal of lintfilterstcr the. water from a water separator. Used filters become Saturated with solvent and must be disposed of as a hazardous waste. Thev should be drummed and hauled away by a licensed hauler, Water separators are small. cannisters on some dry cleaning machines which remove water from the solvent. The water floats to the top of this cannister and dust periodically be removed. Since it is highly contaminated with solvent, it cannot b ' di$pcsed, o f at the -mite but should be disposed of with the lint filters or sep$ra.tely: . lf there is a water separator, the total volume is about one gallon per month. A. few of the newer machines are totall self without the need to damp the water &eparator. " contained There should be no f1oor drains within the dry cleaning area. Tura 14 1 90 1 L �jCi 20=56649'c'4 PAGE . 027 SENT BY:D, E, P, Waste Bureau ; 6-14-90 ; 11 ;02AM ; 2035664924-4203 644 3781 ;#28 a . s Y S.T, K WAT4B It is anticipated that most complaints under this category will refer to a stream or storm drainage system. The most common complaints received under this a category are concerns about discoloration and odors. In many cases, discoloration of a small stream or storm drainage ditch has resulted from natural conditions. This is usually in the form of brown iron solids on the bottom of the stream. Iron often leaches from soil in Connecticut and is oxidized to form a precipitate which settles out. Of course, iron is also a good indicator of leachate from a sanitary landfill, however, it is usually apparent from a knowledge of the area whether this is a potential source. The investigation should include a thorough inspection of the area upstream within a reasonable distance, to insure that no point source is present. IndividuAl ,judgement will need to be used however, in responding to a complaint about stream discoloration or odor, and no obvious source is noted, it is best to collect a sample of the water without bottom sediments, and have it analyzed for several parameters, The Department suggests that the following be tested for: PH Ammonia nitrogem Phosphate Iron Chlorides Surfactants Hydrocarbon Sc&n Coliform-Total and Fecal. In cases where the inspector feels that there is definitely a pollution --_ problem and it unsure of what to sample for, they should call the appropriate contact in the Water Compliance Unit prior to collection of the sample, SENT BY:D. E, P. Waste Bureau ; 6-14-90 ; 11 ,'03AM ; 2035664924-�203 644 3761 ;#29 r it, :9m C.ttNSEMCUT LAW JOLRNAL. Patree I98 Board shall rtate the reason for its denial of ouch reguan ti►nd Willy tht per• son of hi&1her right to add h�islher own statement to hisr'I►er ns penal data -_ ret5nrds. -- (a) Following such denial by the State Lsbrary Board,the person request- sub,correction shall be permitted to add a statement to his or her per• so Ll data record betting forth what that person believes to be an accurste, easaphda and relevant,version of the peraa W data is question.Such state- vmmU ahsll become a pert mmit part of the State Library Board personal data"m and&hall be discloss+d to any irAvkhol,agency or organization to which the disputed personal data is disclosed. (h) Uses to be =de of the nal data. (1) Employees of the Senate Board who are aeaigr ed personnel and M11 responsibilities use the personal data contained in the State Library 's personnel records in�g prrrerrotianb,rec,ta,�,icabt ns,trans- fers to another ency,rerir.,.y nt and other personnel acdm.Supervisors test the personal datta when promotion, =rtr emmling or disciplinary action sgsl=t such employee is contemplated,and for other employment- related purposes. {2) The State Library Board retains pertsonnel records amrding to sched- ules published by the Public Records Adrr,nisttator, State Library Board. (2) When an individual is asked to supply pmwnsa data to the State Library Board,the State Library Board shaII disclose to that ax4vidual,upon request, the name of the a enc and the division within the agency whie}�is request- ing the data, the 1eeuthority under which the agency is empowered to y collect and maintafn the personal&%,the in&idual's rifhts pertaining to such records tinder the Personal Data Act and the agency s regulations,the known consequences arising from supplying or rwfusing to supply the requested personal data,and the proposed use to be made of the requested personal data. i (4) Use of personal data stored by agencies at the State Records Center, West Street, Rooky Hill, is subject to the personal data regWations of the depositing agency. i DEPARTMENT OF VMRONMEN7AL PROTECTION Delegation of AuthoriV y�y 4 The Regulations of f onnecticcrt State Apaciess are amended by the addi- dQn of Sections 22$-2$-1 and 22a-2a,2 as follows: See. 22a.2a-1. Delegation of o4thoritty for the absttment of air pollution (a) Definitions ":Designee"means a Director of Health who has watered into a rnernot-2 . et tr! of agreement under this section. Ad Director of Health"means a local or district director of health appointed under the provisions of Sections 18a•200, 19a•201, or 19a-242 of the C,on- -- necticitt General Statutes, _ "District Department of Health" means a district departmnt of health established in accordance with mction 19a-2.41 of the GenerW Statutes, JLlN 14 90 1 2 0.9 2035664924 PAGE . %t'29 SENT BY:D. E, P, Waste Bureau ; 6-14-80 ;11 :04AM ; 2035664924-f203 644 3781 ;#30 ` B H►.UnCUT LAw ,ott�a�tL F`.b � 18, rsss i I investigution"meam nervation, irtguiry+.the callecdon of xamp)es for tr3Ialyr4 PM the r�of arty pertinent faetr relative to any Ming or Potential source o, air pouujion. o elution" ra the prWOnce in the outdoor�nosphere of one or Pollutants or any ambimdon thereof in Mx:h gtmbtm and of such aracYtGristi t And dunatioa as to be, or be Uely to be, Wuriosrs to public Welfa:r+e, to the health of hum", plant or animal life, or to property, or to reasorubly interfere with the e*yment of life and pr, y, (b) Scope of deleotion (1) The coritrY''Wonfr of ERT'm= atal man my by memorandum agreefrav ate nle Pursuant to these regulations delegate the authority to 8a e>d irtg or potential air pollution diaaharges as describedfnlu►pter 446c of the Conrectscut General Statutes to any Director of -"Wth, NO authority to investigate� lution originating from a �`i�}� or p ng b3'Or Potential�ar s of pool.i'� �enta°lity of ir�,e state st l be gran=b tb+e$e y - (2) The commissioner easy delegate to a is, of lid all or p o f the authority te' irvos�Gigate ViOlaborts of the rtandards, criteria and other requirements pertaining to Bible emissions, tsagftive dust,and odors con. ed in Sections 2u.174.11,24-174-18(a),�.174-18(b)and 2U.174-M of the Regulations of Coon+rtpcut State Agencies. (3) In carrying out delegat*d authority a deSiPft shall be considered an agent of the commissioner and "I have the arvestiPtory powers s d in won�.174-4(0 of the Regul&tions of C�aruaceticart State psi. (4) Within fifteen days of the detection of a Agencies. � daxd,criteria or other meted violation of any scan- �nt which the designee has been authorized to investigate,the designee#hall submit An invw4gative report to the com. rr�ssioner And to the fadlity owner, desert-b the «bpviolation And t.{♦p.h��'Ge methods by which hhiich it was detect d.The port xaa include recom• ��R i4:fip f• :�t° I a oI15^ by the Commissioner to abate the violation.Within h.t �s of tide p ifl esbPtive report the commissioner .shall send written n0tim Lo the designee desc:r%ing either the appropriate cow of sector, to abate the violation or a statement of why no action is neca&ury, in the event that further inv on by the department is required,the ooinrrlissiorter shall 50 not*the desigreee and mall,at the corn- �pletion of the inv0stigution,inform the designee in writing of any necessary anion. f (5) In addition to nod iv the corrra issioner of the detection of a suspected violation, as specified in subdivision (b)(4)the able effort in tight of all circurnstsr ces to co m shall make reason• by diacwsion with the 5aeility owner or suspecW violation (c) Procedures for operator. (1) .4 l}i�ior of H� �tioai icy+) Ain the r cd o3 these y `elegation of an or part of the author. five officer a the mutt reg-orations with the a nmnt of the chief exe~u cility or of the board of the district department of health by which the Dire Wr of Health is employed. The appli=nt shall _submit a request for del,eption of authority on forms provided by the corn, Missioner, The request shall includes the names of one or more staff mem- barr whO will be eonsidwvd as Alternate de4mm in the event of the ree4P&ti0ri or incaWi Son of the Director of Rea,ltk�, t JUN 14 12 10 c-03566492 1 PAGE . 03 SENT BY:D; E, N, Waste Bureau ; 6-14-90 ;11 :04AM ; 2035654924-;203 644 3781 ;#31 F@&MILI is. !906 C2N_S'ECI7CL' LAW JOLMNAL / f (22) In making a decision on am Application, the commissioner ahe11 cart,✓ alder all fact{tra which the commissioner deems relevant,including but not limited to: (A) the keel of etience and training of the spglia►nt sad Staff Members;the nature of the duties to be delegated and the fseities subject to rtier: in the► wru i.-) question; and (C) At kit thirty days prior to grantistg or denying a request for delega. don of authority,the commissioner Shall publish once,m a newspaper hay. # general circulation in the municipalities affected,notioe of(1);T a name and title of the person r*VCs ing such delegation(2)The Municipality(s) +affected by such a request and (3)The scope of the delegation r*Vested, Such notice shall a100 be sent to the chief executive officers of any affected municipalities and to the Conan im'oner of Health Services,Based upon the response to such notice the comraiasioner may determine that, it is in the best public interest to hold a public hearing prior to a proving or den •ng the request for delegation,Notice of:uch hearing sha11 publ,ahed at i oast �Phirey days before a hearing in a newspaper)�avirrg a substantial eircula- tion in the munisdpalli (s) afFeew. _ ��- (3) (A) The commisMoner shall notify the appl;rartt in writin of any deci- aion Onn pthe slppticat:iion and eh I state the r+ess=if an application is denied. U AA dum Ofplic tiob is approved the commiss:oner,aW prepare a memoran- agTeement which defines the scope of the delegation.The commis. r' Moner aid applicant shall both the memorandum of agreement. The 1 lnernorandum of agreement rnust�clude the effective and expiration dates { and may be valid for up to three years, M) Prior to the expiration of the memorandum of agreement, the com- missioner shall review the designee's perfornfa=of delegated duties,includ- ing but not limste:d to recordkeeping, reporting and ability to exercise investigatory authority in a timely and efficient==ner.If the commissioner Issati ed with the performar oe of the designee,the memorandumn of agm, scent shall be renewed for a period riot to��e�xased three years. r `5 •�Ir{.S t ti'•t^•i . . (4) An applicant or de4gnee shall no the co Sri the information provided in the application Within ten commissioner f of any change., (b) If the designee leaves em to randum of ment is auto P yment as Director of Health, the memo. e mab�y�pend4 unless an alternate desig. Me specified in Subdivision(c)(1)is available to faMl the requirements of the memorandum of agreement until 9 new Director of Health is appointed. The replacement Director of Health,when one is appointed, shall apply for approval as the new designee.The replacement sW apply for such approval on a farm provided by the commissioner.Upon approval of replacement,the'` =uTdsaioner shall alter the memos-w dum of s,greement as necessary. l (6) The Mope of delegation stated in a memorandum of agreement shall � not he rnstrued W esrtcotnpau authority for any provision of Chapter 4e6c Of the Connecticut ireneral Statutes which is"-, X d after the effective date of such agreement,The commissioner and a designee may,with the written consent of the chief executive officer of the muticipalitj or of the board of i the district department of health by which the designee is employed,amend a memorandum of agreement to include additional delegatior of authority at any time. (d) Training and standards of conduct for designees - (t) A designee may allow staff members to perform delegated duties,pro- vided that the designee overmes ud is ultimately reapinsiblt for the work. _iUH 14 90 1 1 G1 a SENT BY:D, E, P, Waste Bureau 6-14-90 111 :05AM ; 2035664924-►203 644 3781 ;#32 • ray +1'b tlONNECTIM"T LAW jol RxA.L Febn►�i 18 19Bb P (2) E4Wh dtsipee and aV suff members who will e Pedorm delegated dutiesSW complete ar, 'LwU �OVUM arid, U the oammiieaioner deems additional aottraes cc air pollution control. Such course$ aiay it,tli,► t, but not be lirniW to, the a truction in methods of administering &W eaford4 the lawTa, and technical (8) 1?t :gneee and tr�etrebers og their ho perform delegated duties sihall abide by the stLrA%rds Of conduct for acute employees contasrW in Chap ter 10 of the Connecticut funeral Statutas as amended. (e) ford, Andre g (1) Each design" sliatI MAiMia OMWly On which include.but are not limited to the followmF (A) lords of OOMPLLints received rogarding the mtegories of emiWons covexed by tlmeze regulktions. e ) Copies of all reports and reseealta of any inspecdoas made pwursuant to use tagulataoas. (C) Copies if laboratory rwWa s of an sa mples coDected during any inves. t4ation made pursuant to theses ons. (D) Copies of any p fr. t darrempondence. (2) Dwing the month of September of each year,a designee chill submit a Mort to the comnassiover summar' f the activities of the designee or r64 ni mbeft under the deleted& horny for the previous twelve months. Such reparU shall be on fortes provided by the corrmrtsissioner. At a mini• mum, the report trust include the number of irjunu= riap�tions conducted, and a ' tma the problems enoauntered in investigations. The report may ino#ude reconunend&tions for improvements tants in this state. in the regutsstion of air pollu- (f) Complaints reg�Lrdin,g delepted&gents The Commissioner is empowered to receive and investigate C.arnpWnts reprdfrig the conduct of delegated arntss and the efficiency of delegated PrQgt`ams.If,in the c0t=isaioner's dfBeretion,the consideration of� �sspen- Won for cause or revocation of delegation as d in section� (h of these�ulations is warranted,he Comm fs®ormer aiiali hold a - •„� �: ;.,•..,,,�, to llnde ng such action. At least g Prior cOMmissioner shall pro%ide¬ice at tur prior to mare gated agent, the Rt7r1 tl7 the delegated agent, to the chief executive officer of the r =dXp4 ry and to any person who has fltd a complaint relevant to the mgsary.Following such het�g the cam• rtiissioaer atmall decade to(1)aantaiue the delegation agreement or(2)modify the delegation agreement,and chill rovide notice of the decision to all par- .. ties in&s nutter. Such rsotice is faual decision of the commissioner. �6upensioa of delegation c0mmisaioner, may at the request of the designee or for cause, sus. Pend all or p&ft of any delegation agreement concluded pursunat to these h4ulabons for lob per ods as 66 w=qiniorw deems e man4rement of the del �'to achieve . (h) R oration of delegationThe authority. =rL ssaaner nutty revolve all or Part of a delegation o�authority upon Witten notice to the desiPee and the ehW executive officer of the munici- pality or the board of the district depu m at of health by which the des'net g• is employed,Revocation is effective upon receipt of such notice by both persons. r (i) Termination b chest A dew may all or pert of the delegated resp*='biUties upon th4ty days written notice tO the commoner and the chief ex ecrrtave aff- 9 JUha 1 ' 90 12: 110 `FE l'. 'L4 FAaE . tt: SENT BY:D. E, P. Waste Bureau ; 6-14-90 ; 11 ,06AM ; 2035664924-►203 644 3761 #33 Feb Ig, I098 C.ONNEMCUT LAW XVILr°AL P 23B i cer of the "suri4*ity or tht board of the district department of health by -which the designee is employed. R'Protram review e commissioner shall ma nt"n a record of the oast to the De Of Environmental Protection of Administeringthe Department r adminit- term the delegution p under this aettio t. roe regulations +m the eflec• =ve ate of wadon�m cone sha11 am=the bez rl5ts, including � any east reductions,and liabilities to the Department atthe delegation pro. dam, including.but not limited to the oasts speeded above,t,e nttrnber pf inspections conducted by designees,and the overall efte�veAess of deiega- tion in reducing air pollution in the state. See, 22a=2aa$, :DelegxUon of authority for the abatement of water pollution La) Definitions or purposes of this motion. " }ewdow n from FTeatirigd ding Equipment"means wastewaters generated by heating and cooling equipment that recycles water, "Building Floor Drain Wastewaters"means wastewaters generated from periodic whdown of floors, "Cctmrnercial 1--Und).wastewaters-means wastewater generated by laun- drornats and commercial laundries. "Cooling Water(Non-Contact)" means wastewater which has been used for Cooling poses which does not come into direct contact with a product or process. "Designee"Means a Director of Health who has entered into a mernoran• dum of agreement under this section. "Director of Health"me&=a local or district director of health appointed under the provisions of sections 19a-200, 19a-201a, or 19a-2d2 of the (;ery- era) Statutes: " strict Department of Health" mesons a district department of health established in accordance with section 18a-241 of the general Statutes. Doe;estic Sewage"means 30%,ge that consists of vrater and human excre- •::tions or other waterborne wastes incidental to the Feu den- tW boding or a non-residential buildingbut not inclu pp��r,t�'of a rewiring press water,cooling a-ater,wastewate from water Bung equipmen , COmmereW laundry wastewater, blowdown from heating or cooling it resent, water from collar or floor drains or surface water.from roofs equip. su-I face or ya+-d drains. , payed "Investigation,"means Observation, inquiry,the collection of samples for analysis or the recording of any pertinent fasts relative to any existing or potential source of pollution of the waters of the state which may or may not be operating under a permit issued by the commissioner. "Starrriw�atgr' 'means Rra,st ewater consisting of precipitation runoff gener- ated by residential, commercial, or industrial land use. Swimming Pool Hac"%ahl'rpm=wastea-aters generated from the back- I washing of swimming pool filters, "WRttr P-oduction Wastewater" means wastewater generated by the treatment of raw water for potable, industrial process,or commercial pro- cess use. - (b) Scope of delegation - (1) The commissioner stay by memorandum of s�g'reernent made pursuant to these regu,ations delegate elf or part of the authority to investigate all JUN 14 90 12 12 - - �'���SE4y'� 1 PAGE . G=133 SENT BY:D, E, P. Waste Bureau 6-14-90 ; 11 :06AM 2035664924-4203 644 3781 ;#34 f - Pair UB GONNECT1CL`J'_>rAW JOURNAL Febnaaj-, i$ �sse points of existing or potential waste disc-Urges as provided for in steed n 22.a-416 of the Ge General Statutes to my Director of Health. Delegation of such authority shall be limited to the following categories of wLsu material 1�o>,trres;(1)syera,,ga s - -o;t p atm domestic jwwagv Which W770Q 1 LA defined; �t}.inn�Jl. Generaltatut" ..�Si—�-- -�3 o e 2) ct neon section I-Iq of the General Statutes. (8)..Blowdowm fm erir,i;��.a��t,,,�,�n„� � - . metl�bi4 ��.�Fr �n'` n1i.#tAF7f9Wc$l�T tW'L7R. and crate uction-wastewaw. No authority to investigate any exixtar g or poteritu l source of pollution on inatin from a fadity or property owned by the state or any instrumentality of the lute aaall be granted by these ations. (2) Within. o�detection of a xuslwted violation originat< ing from a source that the designee has been authorized to investigate he or she shall submit a report to the commissioner describing the violation and recommending actions which the commissioner should take to abate the exist. trig or potential pollution, as provided for in Chapter t<bk of the General Statutes, The designee xhall provide the facility owner with a copy of any investigation report and recommendation, and shall discuss any suspected violation with the locality operator in an effort to g voluntary compliance, Witrsin t jMLsIaMpf the receipt of such an investigative re rt tise po titi fin. missioner shall send writp ce to the describin the co f + cs wM lie or EMS ns a, propnateti®t7l1T ep iQ IA irV�3 adt on In tine event t 'further investigation by the dep rtrnent is—'ir,:d,the commissioner shall so notily the designee and shall,at the eompletaon of the investiption,inform tie designee in wz-iting of his or her intended action. --($) For the purposes set forth in thane regulations,any designee shall be eon id€red an agent of &e c ommi5mloner. (c) Pr€ a-dares for delegations (1) A Db*ctor of Health may request delegation of all or part of the author- ity within the scope of these regulations with the consent of the chief execu• Live officer of the municipality or of the board of the district department of health by which he or she is employed.Applical on for delegation of author- iry shall be submitted on farms provided by the commissioner and shall incluue but need not be Iftnitai to the followmV. (A) the nameaddress a of use applicant and his or her nd phone number during normal business hours and in the extent of an emergencyy - .. M) the date of appointment of the applicant in accordance with sections 19n-200, 19a-201, or 19a-242 of the General Statutes; (C) the experience and training of the applicant which is related to the categories or investigation covered by this regulatio?i; (D) the name of each staff member who will be available to perform del ted dux ma es and the estited percentage of time that he or she will be �e to Spend on. those duties- (E) a summary of the experience and training of each staff member speci- fied in response to (D) above, including date ofappointment; (F) the names of one or more staff members who will be considered as alternate designees in the case of the resignation or incapacitation of the t Director of Health; `. ---` (G) a statement.that the applicant a ees that he or she and all staff mem. Bert `oho will be performing delegated duties will complete tree training wi � rered by subsection (d) o- this section; f i o . _TI_IIJ 14 90 1 12 t135664924 PHGE . 0334 SENT BY:D. E, P. Waste Bureau ; 6-14-80 ; 11 .07AM ; 2035664924-+203 644 3781 ;#35 &' Yg p$S {)ONNEC ICL7 LAIA' JOURNAt F`.pt 'rbti i ) "y additional information wlh ch the commissioner deems r*wuLry; � the signature of she applicant,and chief executive of of the manic ipality or the authorized signatum of the board of the district department of health by which he or she is empiged. (2) 1n making a decision on an application, the cominiimioner &Wl con sider a faLurs which he or she deem relevant,including but not lur,itted to: -JA) the level of expeakDce :aid draining of the applicant and his or her ARM and (E) the nature of dw duties to be delegated and the facilities mbjert to regulation in the munid*ity or district ins question. (C) At least thirty days prior to granting or denying a request for delega- tion of authority,the commissioner shall publish once,in a newspaper hay. ing general circulation in the municipalities affected,notice of(1)The name said title of the person requesting such delegation (2)The municipality(s) affeeted by such a mgwtst and (8)The scope of the delegation requested. such notice shall also be sent to the Commissioner of Hea)th Services.Based upon the response to such nadee the commissioner may determine that it _4- is in the best public interest to told a public hearing prior to approving or denying the eat for delegation.Notice of such hearing shall be published sit least thirty►days before the hearing is a newspgxr hzving a substantial osrculation in the m nicipalin affected. r- (3) (A) The comm-issioner notify the applicant in writing of the deci- aibn on the application and if the application is denied, 'shall state the res- i sons for the denial.If the commisaioner approves the application,he or she shall prepare a memorandum of agreement which shal)define the scope of ; the delegation,The tnernorand=of agreement shall be effective as stated therein or when signed by the commissioner and the designee, whichever is latter, and shall automatically expire as stated therein but no more than three yeah from the effective date, unless renewed by both pestles, ems.;�,,Xt ,;y:,+4 •r (1x) prior t4 the expiration or, the mernarandum of agrn3ent,the com- missioner "I review the Director of He&M's performance of delegated duties;including but not]united to record keepin ,reporting and ability to exercise investigation authority is a timely and a eient manner,If the com- missioner is satisfied witb the perfonnance cf the Director of Health, he or she shall renew the memorandum of agreement for a period not to exceed three years. (4) An applicant or,des4pw shall notify the commissioner of any changes in the information provided in accordance vdth subdivision(c)(1)of this sec- tion witlldn ter. days of MXb Chsatge, (5) If the designee leaves his or her employment as Director of Health, the memorandum of agreement shall automatically be suspended,unless w alternate designers as ppr'o-vided for in subparagraph(a)(1)(F)of these regu- lations is available to the requirements of the memorandum of agree• ment until a new Director of Health is appointed.The replacement Director of Health, when one is appointed, shall apply for such approval an a form provided by the commissioner and shall include,at a minimum,the inform- r tdon speed in subpa,rsVVhs(c)(1)(A)through(C),and(c)(1)(F),(C)and - (H)of this section,.upon approval of the replacement,the commissioner may aher the m*-morandurn of agreement as he or she deem mcessary.The Mtn- orandum of agreement shalt be effective as stated therein or when signed JI_IPJ 14 '0 1 1 = ,a35664924 F . 035 SENT BY:D. E. F. Waste Bureau ; 6-14-90 ; 11 :08AM ; 2035664924-+203 644 3781 436 J:%, s ,Y �r., .tit JLL, i.AK ji.)U _^.A1. ?fv2xn It )6bc, r r by the eomrrissioner and the designee, whichever is later, and shall auto. maucally expire as stated therein but-no more..thAr three years from the effeet3ve�la�x,rsu;leas.�newed.i��..laati?�ar�ies: (6) The �o'delegation stated in a memorandum of ment shall not be eonstr i to encompass authority for any provision of Chapter 446k which is adapted after the effective date of such agreement. The commis- sioner and a desigr*e rsay,with the written consent of the chief executive officer of toe municipality or of the board of the distriet departrnent of health by which he or the is employed, amend a memorandum of agreement to include additiorW delegation of authority at any time. (d) Trairiing✓and atwWwda of conduct for deaig ees (1) h de 'nee may allow his or her staff to perform delegated duties,pro• tided tot the desirm oversees and is u.1timately responsible for the work of Ftaff enema . da(2) Each deal- all members of his or her staff who will p ut Mmplete initial traiining Course and om. missioner deems necasiary;sddityana eons on wastewater and wastewater mumpmenz coristent with the delegation ,Agreement. Such courses may i ., a but not be limited to instruction in methods of admirals• . . tering and enforcing the water pollution control laws,and technical training: (3) Designees seed rnembers of their staffs who perform delegated duties shall abide by the standards of conduct for state employees contained in Chap- ter 10 of the Genes Sites, as amended. (e) Records d reporting (1) Each designee avail maintain orderly files at his or her central office which shall include but not be limited to the follo%ing- (A) Reeords of complaints received regarding the categories of discharges covered by thm regulations. } Copies of all reports and results of any insperjons made pursuant to these regrulations. iC) Copies of labor wwry rests of any samples of*caste or water colleen during any investigation made pursuant to theme regulations. ) Copies of any rerdment eorresponperce. (2) Daring the month of September of each year, a designee shall submit . a repo,%to the commissioner=Yimw izing the activities of the designee and his or her staff°under the delegated authority.The report shall be on a form provided by the commis6oftr aril shall include but not be limited to the num- ber of inspenaons conducted, and a summary of the problems encountered n invest tioms,T`t►e report may include recommendations for improvements ir,, erne regulation of the i3'P� of wastewater covered by the delega v. -ion acrnent. M Compltin$s reMding delegated age:uts T ie CcrfPMissiOW h empowered to receive and investigate complaints regairding the conduct of delegated agents, and the efficiency of delegated progrums.If,in the commissioners discretion,the,consideration of suspen- sion for cruse or revocation of delegation as described in subsection (g) or � ')'Of tl`,ese regulations is. wTwnted,the commissioner shall hold a hearing � prior to undertaking such.aotior,. At least thirty days prior to such hearing the commissioner shall proMe a notice of such hearing to the delegated vent, ate chief executive officer of the municipality} and to any person ." -r has filed a "ornplaint relevant to the inquiry. Following such hearing the commissioner shall deride to (1)continue the delegation agreement, (2) rnodi:y the delegation agreement,(8) suspend the delegation agreement i I TI_Ih.! 14 ' 90 1 ',_' : 1 =4 c'035664924 P A G E . O'`16 E SENT BY�D, E, P, Waste Bureau 5-14-90 111 :09AM ; 2035664924-4203 644 3781 ;#37 K rebrW7 is, ;MO COhniErMCL'r L.A� JOUP.NAL Pam Z"l8 / or revoke tine deleption agreement,snd"I provide notice of the deci• t sion to all parties in ttus matter.Such notice is the find decision of the com- txsis$iant:r. _ (g) guspenaian of deleption The Commissioner may at the request of tW desigtriee or for =Avee ass- pend all or part of any delegation agreement concluded iitim arit to these regulations for such periods as he or she deems necesary to"eve effec• tive =rAgement of the delepted authority, Re'rocAtion of delegation commissioner may revoke all or part of a delegation of authority upon written aotice to the Director of Health and the chief executive officer of the rnueleipality or the board of the district department of health by which he or she is employed.Revocation shall be effective upon reoaipt of such Mice by loth parties. _ (1) Termination by dei:�*.�ee A designee may re�inqui&d all or part of his or her delegated responsibili- bes upon thirty days aTitten notice to the commic for er arA tie chief execu• tive officer of the muniei*ity or the board of the district dent of health. by which he or she is employed. - - } °oggram review e cornmiWoner shall maintain a record of the cat to the Department of Envirarsmental Protection for admiriistering the delegation p under this section.Three years from the effective date of Otis section minis• stoner shall:u&w the beetiefits including any cost reductions and liabilities to the Depsrtment of the delegation program, includingbut not limited to f the costs specified above,the number of inspections conucted by designees, and the overall effectiveness of inspections conducted by designees,and the overall effectiveness of delegation in reducing pollution of the waters of the , statz. Statement of purpose-To provide for delegation of portions of the author- • W #� ;r;k- ity of the Commissioner of Environmental Protection to investigate certain existing and potential sources of ar.-and water pollution to those municipal and district Directors of Health who wish to have such authority. Re it known that the foreping rWslebons are adopted by the atoms d aewnq pursuant to Sac.92a•2a of the C*eive-ral Ststmtu,u amended by rubric Act No.227 o.the 1M3 Public Arts,Lfter publication in the Cow*ctimn Law Jourm on Deeembar 18, IM4,d the iwit a* � of theprcpaaal to adopt aeh re�utttiorst,and the iroidlr�of an a+3�ir#Sod hasrixrE on s th#Mh day of January, lM: Whuvfore,the forepiig m qu"om are hereby adopted,effeebw wber AW WM the Sacre- 5a Y at tht staff€, In WiUmn Whereof:Omober 2t, 19W Stanley J: Poe,i trrrr sW*r: � Approved by the Attorney General ra tic legal suffKWgy Mi rdows with Sic.4.109;as Gthdril Sta"'i—;Oetobeo 29, 1995: Approved by the Ljee latave RerWation Review Committee in*vwkLm with See.4-170, as unemled,a.the General 4u rAiLes' De amber 17, ISM Two certified cwpira received and filed,and one such My forwarded to On :miaaion on Official Legal Publications in accordance with Sec.4.172,ar pnended,of the Gehersl Stat- , Se°cra a*of t_m State: 26, 19M. 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