o^0SC^

# ** \ % 522 / UNITED STATES ENVIRONMENTAL PROTECTION AGENCY % REGION 1

5 Post Office Square, Suite 100 Boston, MA 02109-3912

Super fund Records Center SITE: Ra<s r^rh-BREAK: T. I OTHER:

Memorandum

Date: September 7,2016

Subject: Section 7 Consultation for the Endangered Species Act Rufa Red Knot Raymark Superfund Site, Stratford, Connecticut Operable Units 2, 3,4 and 6

To:

From:

Raymark Superfund Site File

James DiLorenzo, Remedial Project Manager J \)

EPA is in the process of cleaning up the Raymark Superfund Site located in Stratford, Connecticut. Currently, cleanup efforts are focused on four operable units that will be addressed under one Record of Decision (ROD) which EPA anticipates issuing in September, 2016. A description of the work is presented in Attachment A

Using U.S. Fish and Wildlife Service (USFWS) IPaC database to generally identify threatened or endangered species that may be present in the remediation area, the rufa red knot (calidris canutus rufa) was identified as being potentially present within the areas of remediation for OUs 2, 3,4 and 6. A map of those areas is attached as Figure 1-1.

The rufa red knot was listed as threatened under the Endangered Special Act (ESA) on January 12,2015, by USFWS. No critical habitat has been identified. Under section 7 of the ESA, a federal agency that, among other things, funds or otherwise authorizes activities that may affect a listed species must consult with the Fish and Wildlife Service to ensure that its actions are not likely to jeopardize the continued existence of any listed species. USFWS frequently asked questions regarding consultation also provides that a federal agency is not required to consult with the Services if it determines an action will not affect listed species or critical habitat. https://www.fws.g0v/endangered/what-we-do/faq.html#8

EPA, to satisfy its obligations under the Endangered Species Act, reviewed available literature and consulted with the State of Connecticut to assess potential impacts on the rufa red knot from the proposed remediation for OUs 2, 3, 4 and 6.

SEMS DocID 593243

The USFWS' New Jersey's Field Office's web page describes red knot migration: The primary wintering areas for the rufa red knot include the southern tip of South America, northern Brazil, the Caribbean, and the southeastern and Gulf coasts of the U.S. The rufa red knot breeds in the tundra of the central Canadian Arctic. Migrating red knots can complete non-stop flights of 1,500 miles or more, converging on vital stopover areas to rest and refuel along the way. Large flocks of red knots arrive at stopover areas along the Delaware Bay and New Jersey's Atlantic coast each spring, with many of the bird having flown directly from northern Brazil. The spring migration is timed to coincide with the spawning season of the horseshoe crab. Departure from the breeding grounds begins in mid-July and continues through August. https://www.fws.gov/northeast/nifield office/endangered/redknot.html

Information gathered by the USFWS to supplement the threatened listing was presented in a document prepared in November, 2014, entitled, "Rufa Red Knot Background Information and Threats Assessment". Citing a variety of sources, information is presented about feeding habits of the red knot.

During the migration period, although foraging red knots can be found widely distributed in small numbers within suitable habitats, birds tend to concentrate in those areas where abundant food resources are consistently available from year to year. Delaware Bay serves as the principal spring migration staging area for the red knot because of the abundance and availability of horseshoe crab eggs. Delaware Bay provides the final Atlantic coast stopover for a significant majority (50 to 80 percent) of the red knot population making its way to the arctic breeding grounds each spring. Horseshoe crabs and surface egg availability are not found in similar densities in other areas on the Atlantic coast, which may explain why shorebirds concentrate in the Delaware Bay. (citations omitted) https://www.fws.gov/northeast/redknot/pdf/20141125 REKN FL supplemental doc FINAL.pdf See pages 73-74.

According to the Connecticut Audubon Society, the red knot is a shorebird typically found in mud-flats along the Connecticut coastline during northbound and southbound migration. The red knot one of a number of shorebirds that passes through the State of Connecticut during migration, but does not breed locally.

Not known to occur at inland locations, Red Knots can be found on Connecticut's barriers beaches from mid-April to the end of May, and then again from July through mid-September. Sometimes non-breeding individuals may linger along Connecticut barrier beaches between migratory periods, and late individuals may pass through on southbound migration well into November. On rare occasions, individual stragglers may spend the winter on the Connecticut coast until spring. Look for this bird on some of the large barrier beach systems in Long Island Sound, especially the Milford Point Coastal Center, Sandy/Morse Point in West Haven, Griswold Point in Old Lyme, and Bluff Point in Groton.

2

These areas are all located outside the Stratford area. (See httpJ/www. ctaudubon. ors/2014/05/connecticut-audubon-societv-bird-finder-for-mav-23-red-knotMsthash.le3PUbxv.dpuf).

In addition to checking the USFWS database, EPA consulted with Connecticut DEEP about the presence of the rufa red knot in the remediation areas, particularly along Ferry Creek. According to the Bureau of Natural Resources, Wildlife Division, there are no records of rufa red knot occurring along Ferry Creek. The Bureau notes that Connecticut is not a significant migratory stopover location for this species but small numbers of birds are observed at beaches and mudflats along the coast in the spring and fall. See attached memo dated September 6, 2016, from Karen Zyko, CT DEEP, BNRWD, to Ron Curran, CT DEEP which was forwarded to Jim Dilorenzo, EPA. In addition, the Bureau has published the Shore Birds of Connecticut Guide which indicates that the Red Knot Sandpiper is "uncommon". (See http://www.ct.2Qv/deep/lib/deep/wildlife/pdf files/noneame/CTShorebirds.pdf).

Another source of sightings for the red knot is a database that allows people from all over the world to record their bird sightings. The USFWS's red knot page includes a link to this site, called e-bird, where observers can record their bird sightings. For the Town of Stratford, two sightings were recorded in one day in 2013 and three sighting were recorded on the same day in 2011 in or around the remediation areas. Figures 2 and 3 are maps showing these few sightings. http://ebird.org/ebird/map/redkno?neg=true&env.minX=&env.minY=&env.maxX=&env .maxY=&zh=false&gp=false&ev=Z&mr=l-

12&bmo=l&emo=12&vr=all&bvr=1900&evr=2016

There are no barrier beaches located within the area of the proposed cleanup actions at any of the Raymark OUs. The work at OUs 2 consists of installing new vapor ventilation systems or evaluating existing systems in current structures that are located in a developed residential and commercial area. Consolidation and capping at OU4 will be conducted at an inland, urban area adjacent to active railroad tracks away from any surface water or mudflats. Activities at OU6 consist of excavating and capping areas on non-contiguous commercial, recreational, and residential properties, located in a relatively urban area surrounded by other residential and commercial properties, with some wetland areas. The Ferry Creek portion of the cleanup (OU3) would be the most likely area for the rufa red knot to stop along its migration pathway in either the fall or the spring since there may be some mudflats during tidal cycles.

Given that the proposed work, other than that proposed at Ferry Creek, is not in areas with mudflats (or likely habitat for horseshoe crabs), that none of the remediation areas are located near barrier beaches, and that the rufa red knot is rarely sighted in the area of Ferry Creek and is determined to be uncommon and not a significant migratory stopover location by the State, EPA concludes that remediation of operable units 2, 3,4 and 6 will have "no effect" on the rufa red knot. If, during remedial design and remedial action any evidence of increased presence of the rufa red knot become apparent, EPA will revisit this conclusion.

3

References Cited:

USFWS IPaC Database: https://ecos.fws.gov/ipac/gettingStarted/index

USFWS Consultation/Frequently Asked Questions: https://www.fws.g0v/endangered/what-we-do/faq.htmi#8

USFWS' New Jersey's Field Office's web page: https://www.fws.gov/northeast/nifield office/endangered/redknot.html

Rufa Red Knot Background Information and Threats Assessment, Supplement to Endangered and Threatened Wildlife and Plants: Final Threatened Status for the Rufa Red Knot (Calidris canutus rufa) [Docket No. FWS-R5-ES-2013-0097; RINAY17], November 2014 https://www.fws.gov/northeast/redknot/pdf/20141125 REKN FL supplemental doc FI NAL.pdf

The Connecticut Audubon Society http://www. ctaudubon. or2/2014/05/connecticut-audubon-societv-bird-iinder-for-mav-23-red-knotMsthash.le3PUbxv.dpuf

Connecticut Department of Energy and the Environment, Bureau of Natural Resources and Wildlife Division publication Common Shore Birds of Connecticut An Identification Guide htlp://www. ct. gov/deep/lib/deep/wildlife/pdf files/nongame/CTShorebirds. pdf

Ebird database: http://ebird.org/ebird/map/redkno?neg=true&env.minX=&env.minY=&env.maxX=&env .maxY=&zh=false&gp=false&ev=Z&mr=l-12&bmo=18temo=12&vr=all&bvr=19008tevr=2016

4

Section 7 Consultation for the Endangered Species Act Rufa Red Knot Raymark Superfund Site, Stratford, Connecticut Operable Units 2, 3, 4 and 6

Attachment A Project Description

Site Background: The Site consists of nine distinct areas that have been contaminated as a result of manufacturing processes from the former Raymark Industries, Inc. facility, which was located at 75 East Main Street, Stratford, Fairfield County, Connecticut. Raymark operated at this location from 1919 until 1989. During the facility's 70 years of operation, it was common practice to dispose of its manufacturing waste as fill material to raise natural grades in low-lying areas at the facility. Raymark also offered manufacturing wastes as "free fill" to employees, residents, and the Town. As a result, Raymark waste has come to be located at various locations throughout the Town of Stratford, including residential properties and numerous commercial, recreational, and municipal properties. In addition, several wetland areas in proximity to Ferry Creek and the Housatonic River were also filled in with Raymark's manufacturing waste. Historical data suggest that a portion of Ferry Creek was diverted in the 1950s due to construction of Interstate 95. Groundwater underlying the Raymark facility and vicinity is contaminated by a variety of chemicals including a group of cleaning solvents that contain volatile organic compounds (VOCs). EPA has already addressed Raymark fill waste contamination at the former Raymark Industries, Inc. facility and many (mostly residential) properties.

OU2/Groundwater: Groundwater remediation, known as operable unit 2 (OU2), consists of contaminated groundwater migrating from the former Raybestos facility to the Housatonic River. An ecological risk assessment determined there was no actionable risk posed from groundwater discharge to surface water. The only route of exposure is future use of groundwater and potential vapor intrusion to overlying structures and residential homes.

Because the entire affected area used public water, the proposed cleanup remedy for OU2 addresses future use of groundwater through institutional controls in the form of a local ordinance, deed notices or other land use restrictions. The potential vapor intrusion risks to approximately 20 mostly residential properties is addressed by installing vapor ventilation systems. This work will be conducted at and within existing homes and other existing structures.

OU3/Upper Ferrv Creek: This OU runs from Interstate 95 to the Broad Street bridge in Stratford, CT. (Lower Ferry Creek will be addressed in a future proposed cleanup plan.) Raymark Waste was historically used to fill in nearby wetland areas and historical data show that a portion of the creek was diverted in the 1950s due to construction of Interstate 95. The creek channel and portions of the banks contain visible Raymark Waste. The OU3 (Upper Ferry Creek) area is estimated to encompass approximately seven acres, including approximately 1.2 acres of wetlands and 1.4 acres of open water.

The proposed cleanup remedy for OU3 addresses Raymark Waste contamination in sediment and soils by: excavating and removing the top two feet of sediment from the creek channel up to the mean high-level water mark, excavating and removing soil that meets the definition of Raymark Waste from the creek banks up to a depth of four feet; and excavating and removing wetland soil that meets the definition of Raymark Waste up to a depth of four feet. Some tree removal may be necessary. All excavated sediment and soil will be replaced with clean material, and excavated areas will be restored to original grade and revegetated with native species. Areas of steep banking will require the use of rip-rap. Excavated soil and sediment will be consolidated at OU4 or shipped to a licensed out-of-town disposal facility. The proposed cleanup action will restore disturbed and contaminated areas, including restoration of wetlands.

OU4/Ravbestos Memorial Ballfield: The Ballfield was in use from 1947 through 1987 and has since been abandoned. Prior to use as a ballfield, the area was disturbed and low-lying/wet areas filled in with Raymark Waste. All vegetation on site has grown in since the late 1980s and includes a mix of regional immature tree and shrub species, and grasses. The location does not provide robust wildlife habitat as it is surrounded to file north by a residential neighborhood, to the east by a street and the Town's Department of Public Works, to the south by a the Metro-North high-speed rail line, and to the west by the former Contract Plating facility (a Brownfields site where the contaminated facility building was recently demolished).

The proposed cleanup remedy for OU4 addresses Raymark Waste contamination in soil by: clearing vegetation, including tree removal, and removal of old infrastructure; constructing an access road from Longbrook Avenue through the former Contract Plating property (a Brownfields property) to the ballfield; consolidation of excavated sediment and Raymark Waste from OU3 and OU6 with the existing 111,000 cubic yards of Raymark Waste on OU4; construction of a permanent, low-permeability cap over the consolidation area to isolate contamination; construction of storm water management features; construction of a permanent or temporary visual and sound barrier along the boundary with Patterson Avenue, Clinton Avenue, and Cottage Place; and restoration of the property with vegetation and pavement as appropriate.

OU6/Additional Properties: OU6 consists of 22 non-contiguous commercial, recreational, and residential properties where Raymark Waste was used to fill low-lying areas. (Recreational properties include a boat launch and Wooster Park.) All properties are located in relatively urban areas, surrounded by other commercial properties or residential neighborhoods. Many of the properties are already developed and do not provide wildlife habitat. The undeveloped properties are road-side vacant lots of limited acreage.

The proposed cleanup remedy for OU6 addresses Raymark Waste contamination in soil at the various impacted properties by: excavating and removing soil that meets the definition of Raymark Waste to a depth of four feet; replacement of excavated soil with clean material; and restoration of excavated areas to pre-excavation grade and condition, including pavement or vegetation as appropriate. Any affected wetlands will be restored. Excavated soil and sediment will be consolidated at OU4 or shipped to a licensed out-of-town disposal facility.

Section 7 Consultation for the Endangered Species Act Rufa Red Knot Raymark Superfund Site, Stratford, Connecticut Operable Units 2,3,4 and 6

Attachment A Project Description

Site Background: The Site consists of nine distinct areas that have been contaminated as a result of manufacturing processes from the former Raymark Industries, Inc. facility, which was located at 75 East Main Street, Stratford, Fairfield County, Connecticut. Raymark operated at this location from 1919 until 1989. During the facility's 70 years of operation, it was common practice to dispose of its manufacturing waste as fill material to raise natural grades in low-lying areas at the facility. Raymark also offered manufacturing wastes as "free fill" to employees, residents, and the Town. As a result, Raymark waste has come to be located at various locations throughout the Town of Stratford, including residential properties and numerous commercial, recreational, and municipal properties. In addition, several wetland areas in proximity to Ferry Creek and the Housatonic River were also filled in with Raymark's manufacturing waste. Historical data suggest that a portion of Ferry Creek was diverted in the 1950s due to construction of Interstate 95. Groundwater underlying the Raymark facility and vicinity is contaminated by a variety of chemicals including a group of cleaning solvents that contain volatile organic compounds (VOCs). EPA has already addressed Raymark fill waste contamination at the former Raymark Industries, Inc. facility and many (mostly residential) properties.

OU2/Groundwater: Groundwater remediation, known as operable unit 2 (GU2), consists of contaminated groundwater migrating from the former Raybestos facility to the Housatonic River. An ecological risk assessment determined there was no actionable risk posed from groundwater discharge to surface water. The only route of exposure is future use of groundwater and potential vapor intrusion to overlying structures and residential homes.

Because the entire affected area used public water, the proposed cleanup remedy for OU2 addresses future use of groundwater through institutional controls in the form of a local ordinance, deed notices or other land use restrictions. The potential vapor intrusion risks to approximately 20 mostly residential properties is addressed by installing vapor ventilation systems. This work will be conducted at and within existing homes and other existing structures.

—OU3AJpper Ferrv Creek:~This QUruns from Interstate 95 to the Broad"Street bridge in — Stratford, CT. (Lower Ferry Creek will be addressed in a future proposed cleanup plan.) Raymark Waste was historically used to fill in nearby wetland areas and historical data show that a portion of the creek was diverted in the 1950s due to construction of Interstate 95. The creek channel and portions of the banks contain visible Raymark Waste. The OU3 (Upper Ferry Creek) area is estimated to encompass approximately seven acres, including approximately 1.2 acres of wetlands and 1.4 acres of open water.

The proposed cleanup remedy for OU3 addresses Raymark Waste contamination in sediment and soils by: excavating and removing the top two feet of sediment from the creek channel up to the mean high-level water mark, excavating and removing soil that meets the definition of Raymark Waste from the creek banks up to a depth of four feet; and excavating and removing wetland soil that meets the definition of Raymark Waste up to a depth of four feet. Some tree removal may be necessary. All excavated sediment and soil will be replaced with clean material, and excavated areas will be restored to original grade and revegetated with native species. Areas of steep banking will require the use of rip-rap. Excavated soil and sediment will be consolidated at OU4 or shipped to a licensed out-of-town disposal facility. The proposed cleanup action will restore disturbed and contaminated areas, including restoration of wetlands.

OU4/Ravbestos Memorial Ballfield: The Ballfield was in use from 1947 through 1987 and has since been abandoned. Prior to use as a ballfield, the area was disturbed and low-lying/wet areas filled in with Raymark Waste. All vegetation on site has grown in since the late 1980s and includes a mix of regional immature tree and shrub species, and grasses. The location does not provide robust wildlife habitat as it is surrounded to the north by a residential neighborhood, to the east by a street and the Town's Department of Public Works, to the south by a the Metro-North high-speed rail line, and to the west by the former Contract Plating facility (a Brownfields site where the contaminated facility building was recently demolished).

The proposed cleanup remedy for OU4 addresses Raymark Waste contamination in soil by: clearing vegetation, including tree removal, and removal of old infrastructure; constructing an access road from Longbrook Avenue through the former Contract Plating property (a Brownfields property) to the ballfield; consolidation of excavated sediment and Raymark Waste from OU3 and OU6 with the existing 111,000 cubic yards of Raymark Waste on OU4; construction of a permanent, low-permeability cap over the consolidation area to isolate contamination; construction of storm water management-features; construction of a permanent or temporary visual and sound barrier along the boundary with Patterson Avenue, Clinton Avenue, and Cottage Place; and restoration of the property with vegetation and pavement as appropriate.

OU6/Additional Properties: OU6 consists of 22 non-contiguous commercial, recreational, and residential properties where Raymark Waste was used to fill low-lying areas. (Recreational properties include a boat launch and Wooster Park.) All properties are located in relatively urban areas, surrounded by other commercial properties or residential neighborhoods. Many of the properties are already developed.and do not provide wildlife habitat. The undeveloped properties are road-side vacant lots of limited acreage.

The proposed cleanup remedy for OU6 addresses Raymark Waste contamination in soil at the various impacted properties by: excavating and removing soil that meets the definition of Raymark Waste to a depth of four feet; replacement of excavated soil with clean material; and restoration of excavated areas to pre-excavation grade and condition, including pavement or vegetation as appropriate. Any affected wetlands will be restored. Excavated soil and sediment will be consolidated at OU4 or shipped to a licensed out-of-town disposal facility.

0U2 Boundary

L«g«wid

FIGURE 1 • 1 SITE LOCATION AND

OPERABLE UNITS RAY MARK SUPERFUND SITE • OU3

STRATFORD CONNECTICUT

From: Kilborn, John Sent: Tuesday, September 06, 2016 12:47 PM To: Catri, Cindy Subject: Fw: Red knot - Ferry Creek, Stratford

FYI

JohnW. Kilborn Senior Enforcement Counsel U.S. Environmental Protection Agency Five Post Office Square, Suite 100 (Mail Code: OES04-3) Boston, MA 02109-3912

Tel: 617-918-1893

01! Fax: 617-918-0893 E-Mail: kilborn.john@epa.gov

FromiCurran, Ronald <Ronald.Curran@ct.gov> Sent: Tuesday, September 6, 2016 12:39 PM To: Kilborn, John; DiLorenzo, James Subject: FW: Red knot - Ferry Creek, Stratford

Please See Below.

From: Zyko, Karen Sent: Tuesday, September 06, 2016 12:30 PM To: Curran, Ronald <Ronald.Curran@ct.gov> Cc: Dickson, Jenny <Jenny.Dickson@ct.gov> Subject: Red knot - Ferry Creek, Stratford

Ron, We do not have any records of Red knot (Calidris canutus rufa) occurring along Ferry Creek in Stratford. Connecticut is not a significant migratory stopover location for this species, but small numbers of birds are observed at beaches and mud flats along the coast in the spring and fall. Feel free to contact me if you require more information.

Karen Zyko

Environmental Analyst

Department of Energy & Environmental Protection

Bureau of Natural Resources, Wildlife Division

79 Elm St, Hartford, CT 06106

860-424-33781 0 r

1

eBird Range Map—Red Knot f'i^rc X

Page 1 of 1

Submit Observations Explore Data My eBird Help Sign In or Register Language

Species:

S'WJ

Red Knot Date: ^ Year-Round, All Years ^

/ i

Easton

Location: Stratford, CT, United States «• , X r

<®\ I (T5)

*

M '*4 Trout Brook

Valley Reserve (u

i

1 >5 ® i ®

f

r &

(iJr)~

Trumbull

i © CD

t

Westfield Trumbull

m Weston

r

i I ® J '

f i

% s-i >- ®

Stratford Greenway

I % Fairfield, US-CT

# Ol

| © * ®

if

y

2013-05-19 2 Ai

® " , 2013-05-19 2 Jf V

\ \ Bridgeport BanKim 0''*

J3

<9 , W •

2) 0

0 k

© Westport

0 W

, Island •j \ S,8te(V».

SOUTHPORT

\ id) 9 /* \ S I

p|jf Fairfield

(Ho) Sti

9f o2

Sherwood Island .i* ;

; ,

O y j H <?

m

Zoom Tool

Full Species Range

Terrain

Street

Satellite

Hybrid

Explore Rich Media

Only show locations with photos, audio, or video

Show Points Sooner

Display points at broader scales when possible (2000 points max)

RECENT OLDER (30+DAYS)

Go gle TIP Click points to see sightings and checklists at that location

2 km

9 t

Map ctttMK0Ki£«>O>€

Q Birding Hotspot

Personal Location

http://ebird.org/ebird/map/redkno?neg=true&env.minX=&env.minY=&env.maxX=&env.m... 9/7/2016

eBird Range Map-Red Knot Page 1 of 1

Submit Observations Explore Data My eBird Help Sign In or Register Language

Species: Red Knot Date: ^ Year-Round, All Years 3

E as ton

Trout Brook Valley Wr i 1

' '< *' Preserve (js)

- I) X :

Location: Stratford, CT, United States V I

©V \ *

up*'

4

/ Westfield Trumbull»

®

' ®

Weston

V

f; © '

4 1

&

\

'®

s

y

® ; Jf f f

Sikorsky Meihoiift^

OBSE

'"1' '>tyrfield, US-C|

\ X DATE' £3 #

Br.dgepor&ypio-*r

r^ #

/* V

Zoom Tool

Full Species Range

Terrain

Street

Satellite

Hybrid

Explore Rich Media

Only show locations with

photos, audio, or video

Show Points Sooner

Display points at broader

scales when possible (2000

points max)

RECENT OLDER (30* DAYS)

Go gle TIP Click points to see sightings and checklists at that location

2 km

9 ?

Map (**»««{) Mi MQle

^ Birding Hotspot

Personal Location

http://ebird.org/ebird/map/redkno?neg=true&env.minX=&env.minY=&env.maxX=&env.m.. 9/7/2016