U.S. ENVIRONMENTAL PROTECTION AGENCYREGION I

J.F. KENNEDY FEDERAL BUILDING, BOSTON, MA 02203-2211

MEMORANDUM

DATE: September 25, 1997

SUBJ: Human Exposures Controlled Determination- RCRIS Code CA725

FROM: Robert O'Meara, RFM

TO: Matthew R. HoaglandChief, RCRA Corrective Action Section

RE: EPA ID No.: CTD001166008Facility Name: Harper Leader, Inc.Facility Address: 1046 South Main Street, Waterbury,

Connecticut

Frank Gardner, On-Scene Coordinator, Office of Site Remediationand Restoration, Emergency Planning & Response Branch hasdetermined that, based on the information available/reviewed, andsubject to the limitations cited below and in the attached memo,there are no current unacceptable risks to humans due to releasesof contaminants at the subject facility subject to RCRACorrective Action, in accordance with the guidance sent toRegional Waste Management Directors by Michael Shapiro on July29, 1994. One or more of the following conditions, included inthe July 29, 1994 guidance, have been documented by fieldmeasurements and/or observations:

Remedial measures have been implemented with the resultthat all maximum contaminant concentrations detected orreasonably suspected are less than or equal to theirrespective action levels or do not exceed an Agencyspecified cleanup standard for the facility.

OR

There is no unacceptable human exposure to anycontaminant concentration above action levels that hasbeen detected or is reasonable suspected based oncurrent contaminant concentrations and current siteconditions. Although contamination remains at thefacility that may require further remediation, actionhas been taken or site conditions are otherwise suchthat unacceptable threats to human health from actualexposure to the contamination are not plausible basedon current uses of the site. Such actions may include

the use of physical barriers or institutional controls.

The above determination is documented in the attached memo fromFrank Gardner dated Sept. 25, 1997 and is based on the following:

There appears to be no potential for current direct humanexposure on-site, because the lagoon area has been cappedand contaminated surface soils and containers of hazardoussubstances have been removed from the Site. Groundwater inthe area is classified as GB, which means that it may beused for waste water disposal and would require treatmentbefore being used as a public water supply. According to CTDEP and the Waterbury Health Department, residences andbusinesses in the area are supplied by city water. Thenearest private drinking water supply well is 0.2 milesupgradient, and the nearest public drinking water supplywell is 2.8 miles upgradient. Therefore, the Harper LeaderSite meets the second criterion and should be assigned the"YE" code for Human Exposures Controlled (CA725).

Supervisory Signature : ̂ ^&Z*3f^w+**&2»-~{____________ Date:

RCRIS ENVIRONMENTAL INDICATORSEVALUATION MEMORANDUM

HARPER LEADER, INC. SITEWaterbury, Connecticut

(CTD001166008)

Prepared by:

Frank Gardner, On-Scene CoordinatorOffice of Site Remediation and RestorationEmergency Planning & Response Branch

September 25, 1997

Harper Leader, Inc. Site (CTD001166008)

I. Site Description

A. Facility Operations

Harper Leader, Inc. operated a metal plating and finishing facility located at 1046 South MainStreet, Waterbury, Connecticut from 1953 until 1988, when the company went out ofbusiness. The Harper Leader Site is located near the east bank of the Naugatuck River in anarea of mixed industrial, commercial, and residential properties. The Site consists of anapproximately 30,000 square foot abandoned building and a former metal hydroxide settlinglagoon on 2 acres of land. Other industries located in the area include ITW/WaterburyBuckle and Anaconda Brass. Figure 1 shows the geographic location of the facility andFigure 2 shows the layout of the site. The only known previous owner of the Site was theWaterbury Battery Company from approximately 1906 to 1949. The Waterbury BatteryCompany reportedly made copper oxide-zinc batteries and lead-acid batteries.

Harper Leader specialized in precious metals. Precious metals plated included gold, silver,platinum, and rhodium. Other plating operations at the Site involved copper, nickel, tin, lead,cadmium, and indium. Harper Leader also did stripping, chromating, electropolishing,burnishing, cleaning, tumbling, and descaling. Precious metal reclaiming included silverplating, scraping and melting to form ingots, and gold dissolution and reprecipitation. Thecompany also operated a small QA/QC laboratory at the Site. Waste generated at the Siteincluded acids, bases, spent solvents, waste oil, ion-exchange resins, metal solutions, andmetal hydroxide sludge.

From 1953 to 1969, waste from Harper Leader was discharged untreated directly into a citysewer, which reportedly flowed into the Naugatuck River. In 1969, the facility installed awaste water treatment system which included the metal hydroxide settling lagoon. The lagoonwas taken out of service in 1985 when the waste water treatment system was augmented toinclude a gravity settling unit, sand filter, and filter press. The company submitted a RCRAclosure plan/post-closure permit application which was deemed inadequate by the ConnecticutDepartment of Environmental Protection (CT DEP). The company went out of businesswithout fulfilling RCRA requirements for closure of the lagoon or its post-closure care.

The Site is currently abandoned, and the building is in an advanced state of decay. Piles ofgarbage and household debris, extensive graffiti, and numerous used hypodermic needlesscattered throughout the property illustrate that trespassing and unauthorized human activityare frequent. EPA conducted a fund-lead removal action at this Site from October 1996through January 1997. During this period, several violent crimes were committed in thevicinity. Armed security guards were used to ensure the safety of cleanup crews.

The following table identifies RCRA-regulated units, Solid Waste Management Units(SWMUs), and other Areas of Concern (AOCs) at the Site. The first seven were identified in

Harper Leader, Inc. Site (CTDOO1166008)

the RCRA Facility Assessment (RFA). The last two were found during the fund-leadSuperfund removal action conducted by EPA.

Area Name

1. SettlingLagoon

2. DrumStorage Area

3. Waste WaterTreatmentSystem

4. Tin-NickelPlating Area

5. Floor Sumpsand Trenches

Description

The 30'x90' metalhydroxide settlinglagoon was locatedat the south end ofthe property.

Drums of wastewere stored in anarea with a bermedconcrete floor.

Harper Leaderoperated a wastewater treatmentsystem in thenorthern part of thebuilding.

This plating line,also located in thenorthern part of thebuilding, wasreportedly notproperly bermed.

Several open floorsumps and trenchesare locatedprimarily in thenorthern part of thebuilding.o

Dates Used

1953-1985

1953-1996

1969-1988

1953-1988

unknown-present

Release Status

known releaseto soil andground water

Based on EPA's samplingresults, soils in the lagoonarea were contaminatedwith lead (2500 ppm), zinc(26000 ppm), copper(25000 ppm), and nickel(1700 ppm). Groundwater sampling by CTDEP in 1996 showed thatthe lagoon has releasedcopper (265 ppb), lead (15ppb), mercury (39 ppb).and zinc ( 1 750 ppb) to theground water.

low potential torelease

low potential torelease

known releaseto soil

A spill or a metal platingsolution in 1983 resultedin surface contamination(tin up to 100,000 ppmand lead up lo 4240 ppm).

potentialrelease tosubsurface

Sumps and trenches arepresent in the building.one of which may extendunder the paved area northof the building.

Actions TakenIn 1985, the facilityremoved the remainingsludge from the lagoonand disposed theexcavated materials off-site. As part of theSuperfund removalaction, EPA constructed asoil and asphalt cap overthe lagoon area.

All drums were shippedoff-site for disposalduring EPA's removalaction.

Harper Leader removed20 cubic yards ofcontaminated surface soil.Soil samples taken hereby EPA in 1995 and19% showed no residualcontamination.

Harper Leader, Inc. Site (CTD001166008)

Area Name

6. 2,000-GallonUndergroundStorage Tank(UST)

7. 10,000-Gallon UST

8. NickelHydroxideDisposal Area

9. Lead-ContaminatedSurface Soils

Description

This steel UST heldheating oil. It wasremoved in 1989,with the excavationleft open.

This steel UST heldheating oil. It isnow empty.

During EPA'sremoval action,nickel hydroxidesludge wasdiscovered buriedbetween the lagoonand the building.

Lead-contaminatedsurface soils werefound in twolocations at the Siteduring EPA'sremoval action.

Dates Used

unknown- 1989

1978-present

1970-1996

According to interviewswith a former owner ofthe facility, the nickelhydroxide sludge wasdisposed here inapproximately 1970.

unknown- 1996

Release Status

low potential torelease

During the removal action,EPA observations andsampling results did notindicate residualcontamination in theexcavation.

low potential torelease

known releaseto soil

During EPA's removalaction, a green nickelhydroxide dried sludgematerial was encounteredin the area between thelagoon and the building.Analysis of this materialindicated it containedapproximately 22% nickel.

known releaseto soil

During EPA's removalaction a site-wide surfacesoil sampling survey wasconducted along a 20-footgrid pattern for metalsconcentrations. Two areasof lead-contaminatedsurface soils were found(apart from the lagoonarea): one to the north ofthe building (up to 1000ppm) and one along thewest side of the building(up to 13,000 ppm).

Actions Taken

EPA excavated anddisposed of the sludgeand associatedcontaminated soils as partof its removal action.Interviews with formerowner Isidore Crossindicated that this was theonly area outside of thelagoon where hazardoussubstances were sodisposed.

EPA cleaned up both ofthese areas to CTRemediation Standardsduring the removal actionby excavating anddisposing of the lead-contaminated surfacesoils.

B. Facility Setting

1. Geology

The Site is located in the Naugatuck River valley. The soils are identified as Ur and Ud:urban land and udorthents, respectively. These are either paved areas (Ur) or artificial fill

Harper Leader, Inc. Site (CTD001166008)

and cut and borrow areas (Ud). The nearest undisturbed soils are the Hinckley gravelly-sandyloam, located on adjacent, less-developed properties. Overburden at the facility consists ofmedium to coarse-grained alluvial deposits and till. The bedrock beneath the property is theWaterbury Gneiss, a Cambrian grey to dark grey, fine to medium grained schist and gneiss.Depth to bedrock is at least 17 feet; the bedrock slopes steeply toward the river.

2. Hydrogeology

Depth to ground water at the facility is approximately 30 feet; ground water flows southwest,toward the Naugatuck River. Hydraulic conductivity is estimated at 1.22 to 1.89 feet/day andthe ground water velocity 0.125 feet/day. Ground water in this area is classified GB,indicating that it may be used for waste water disposal and would require treatment beforebeing used as a public water supply.

3. Surface Water

Harper Leader is located 750 feet northeast of the Naugatuck River, at the base of a hill thatrises to the east. Surface water runoff from the front of the property is channeled into twocatch basins and through the facility via a set of pipes. These pipes channel the water into thecatch basin on Harvester Road and from there to the Naugatuck River. Surface runoff at therear of the property runs southwest, across the site and into the Naugatuck River. HarperLeader also had a NPDES permit (No. CT0001791) to discharge waste water into theNaugatuck River. Before 1985, the waste water overflowed from the lagoon to the municipalstorm water runoff outlet on Harvester Road. After 1985, the waste water treatment systemhad a discharge pipe to the catch basin.

The Naugatuck River is classified SC/SB by CT DEP, indicating that the river iscontaminated with industrial pollutants. The Naugatuck flows at a rate of 202 cubic feet persecond at Thomaston. The 15-mile downstream pathway from Harper Leader ends atAnsonia, Connecticut, approximately 0.2 miles south of the Seymour town line. There are nosurface water intakes along the Naugatuck River downstream of Harper Leader. There are nodesignated fisheries along this section of the Naugatuck River. In the immediate vicinity ofthe Site, the river is channelized between and under various industrial buildings, making itrelatively inaccessible to the public. The Federal Emergency Management Agency (FEMA)Flood Insurance Rate Maps for Waterbury indicate that Harper Leader is located in Zone B,within the 500-year flood plain.

4. Potential Receptors

The former Harper Leader facility is abandoned and there are no workers on site. Thenearest residence is 50 feet from the northern site boundary; there are no fences or otherbarriers to site access. There are no schools or day care centers located within 200 feet of the

Harper Leader, Inc. Site (CTD001166008)

site. Table 10 summarizes the population distribution of residents located within a four-mileradius from Harper Leader.

RESIDENTS LIVING NEAR HARPER LEADER SITE

Distance from Property Estimated Population0.00-0.25 miles 1,9910.25-0.50 miles 4,0530.50-1.00 miles 12,9751.00-2.00 miles 45,4102.00-3.00 miles 36,7303.00-4.00 miles 36.567TOTAL: 137,727

The land in the vicinity of Harper Leader is industrialized, with some residences andapartment buildings and some commercial establishments. The nearest residence isapproximately 50 feet north of the property boundary. Other adjacent properties include achurch and a roller rink. The area is served by the City of Waterbury's municipal watersupply system. The following cities and towns are located within four miles of HarperLeader: Waterbury (population: 107,040), Watertown (20,308), Wolcott (13,573), Naugatuck(30,461), Middlebury (6,087), Prospect (7,599), and Cheshire (23,536).

ITW/Waterbury Buckle, an active RCRA TSD facility approximately 1,000 feet north ofHarper Leader has two ground water production wells. One of these wells is inactive, and theother is used for landscape irrigation. ITW/Waterbury Buckle also has a ground watermonitoring system in place which would be able to detect contamination coming from off-sitesources. The nearest private drinking water well, located from well completion reports at theWaterbury Department of Health, is situated approximately 0.2 miles east (upgradient) of theproperty. There are seven local public ground water supplies located in Naugatuck, Prospect,Wolcott, and Middlebury. The nearest of these is a Highland Heights Water Company well,2.8 miles southeast and upgradient of the Site.

C. Groundwater Monitoring System

Harper Leader installed seven monitoring wells (six in the shallow aquifer and one in thedeeper aquifer) on the southern half of the property, primarily around the surfaceimpoundment. The monitoring well network demonstrates that ground water flows southwest,toward the Naugatuck River. The upgradient well has consistently met applicable actionlevels. Downgradient wells have shown contamination associated with the former lagoon.Harper Leader sampled ground water from these wells from approximately 1984-1988.Monitoring ceased when the company went out of business in 1988. CT DEP sampled themonitoring wells in 1996, during EPA's removal action. The following table summarizes

Harper Leader, Inc. Site (CTD001166008)

exceedances of the Connecticut Remediation Standards (Surface Water Protection Criteria,since the ground water is classified as GB but recharges the Naugatuck River) applicable tothe area.

CONSTITUENT

Copper

Lead

Mercury

Zinc

Cyanide, amenable

CT DEP ACTIONLEVEL (ppb)

48

13

0.4

123

52

PEAK CONCENTRATION1984-1988 (ppb)

1,890

3,000

not sampled for

not sampled for

490

PEAK CONCENTRATION1996 (ppb)

265

15

39

1,750

ND

II. Environmental Indicator Findings and Supporting Arguments

Human Exposure Controlled (CA725)

Based upon the information contained in the references reviewed including environmentalsampling results, the site operations, and environmental setting (physical and demographic), itis suggested that Harper Leader can be classified as a site where human exposures arecontrolled (YE determination). Based upon guidance specified in the July 29, 1994 U.S. EPA"RCRIS Corrective Action Environmental Indicator Event Codes" memorandum (Guidance),one of the following two criteria must be met for a YE determination. These are:

1. Remedial measures have been implemented with the result that all maximumcontaminants detected or reasonably suspected are less than or equal to their respectiveaction levels (e.g., MCLs for groundwater, a 10 - 6 risk level for other contaminants,or any other number designated as the action level) or do not exceed an Agencyspecified cleanup standard for the facility, and/or

2. There is no unacceptable human exposure to any contaminant concentration aboveaction levels that had been detected or is reasonably suspected based on currentcontaminant concentrations and the current site conditions. Although contaminationremains at the facility that may require further remediation, action has been taken orsite conditions are otherwise such that unacceptable threats to human health from actualexposure to the contamination are not plausible based on current uses of the site. Suchactions may include the use of physical barriers or institutional controls (e.g., deedrestrictions or alternative water supply).

Harper Leader, Inc. Site (CTD001166008)

Harper Leader does not meet the first criterion since current groundwater monitoring datashows that copper, lead, mercury, and zinc are present in the groundwater above CT DEPRemediation Standards. However, there appears to be no potential for current direct humanexposure on-site, because the lagoon area has been capped and contaminated surface soils andcontainers of hazardous substances have been removed from the Site. Ground water in thearea is classified as GB, which means that it may be used for waste water disposal and wouldrequire treatment before being used as a public water supply. According to CT DEP and theWaterbury Health Department, residences and businesses in the area are supplied by citywater. The nearest private drinking water supply well is 0.2 miles upgradient, and the nearestpublic drinking water supply well is 2.8 miles upgradient. Therefore, the Harper Leader Sitemeets the second criterion and should be assigned the "YE" code for Human ExposuresControlled (CA725).

Groundwater Releases Controlled (CA750)

Based upon the information contained in the references reviewed including ground watermonitoring results, site operations and environmental setting (physical), it is suggested thatHarper Leader cannot be classified as a site where groundwater releases are controlled (YEdetermination) or where no releases to groundwater have occurred (NR determination). Basedupon the Guidance of July 29, 1994, one of the following two criteria must be met for a YEdetermination. These are:

1. An engineered system has been installed that is designed and operating (includingperformance monitoring) to effectively control further migration beyond a designatedboundary such as the engineered system, the facility boundary, a line upgradient ofreceptors, or the leading edge of the plume as defined by levels above the Agencyestablished action levels or clean-up standards, and/or

2. The Agency has determined that the groundwater clean-up objectives can be metwithout the use of an engineered system through the remedial measures selectedincluding facilities where the contamination will naturally attenuate.

Although the cap system installed by EPA during the removal action will likely minimizefurther migration of contaminants into the ground water, it may not prevent contaminantsalready in the ground water from migrating. Therefore, Harper Leader does not meet thefirst criterion. Based on the apparently substantial reductions in ground water contaminantswhen comparing the historical data (1984-1988) to the current data (1996), it appears thatnatural attenuation may eventually meet cleanup objectives without the use of an engineeredsystem. However, additional ground water quality data will need to be obtained in the futureto determine whether natural attenuation will result in the second criterion being met.Therefore, Harper Leader does not currently meet the second criterion.

Harper Leader, Inc. Site (CTD001166008)

Since Harper Leader does not satisfy either criteria for a YE determination, the CA750 eventcode should be left blank. According to the Guidance, "blank spaces or no entries shouldonly be interpreted to mean that the releases have not yet been determined at the facility, notthat the facility has uncontrolled releases."

III. Recommended Actions

The following actions are recommended to achieve a YE designation for event code CA750:

• Future property owners or CT DEP should continue to sample the monitoring wells atthe Site periodically so that trends in ground water can be tracked over time andcompared to historic data. If steady downward trends are observed that are likely toresult in Connecticut Remediation Standards being met by natural attenuation, this Sitemay then be assigned a "YE" designation, based on the second criterion, for "GroundWater Releases Controlled" (CA750) at such time.

Harper Leader, Inc. Site (CTDOO1166008)

FV. References

1. Final RCRA Facility Assessment, Harper Leader, Incorporated. Prepared for U.S.Environmental Protection Agency, by TRC Environmental Corporation. September1993.

2. Removal Program Preliminary Assessment/Site Investigation for Harper Leader, Inc.Site. Prepared for U.S. Environmental Protection Agency, by Roy F. Weston, Inc.Superfund Technical Assessment and Response Team. July 1995.

3. Health Consultation, Harper Leader Site/Surface Soil Contamination. Prepared by theConnecticut Department of Public Health under Cooperative Agreement with theAgency for Toxic Substances and Disease Registry. September 19, 1995.

4. Connecticut Remediation Standard Regulations. January 30, 1996.

5. Request for a Removal Action at the Harper Leader Site, Action Memorandum. FromFrank Gardner, On-Scene Coordinator to Linda M. Murphy, Director, Office of SiteRemediation and Restoration. September 19, 1996.

6. Groundwater Sampling Report, Harper Leader Facility. Prepared by the State ofConnecticut, Department of Environmental Protection. November 6, 1996.

7. Chronological Summary Report for the Harper Leader Site Superfund Removal Action.Prepared for U.S. Environmental Protection Agency Region I, by Roy F. Weston, Inc.Superfund Technical Assessment and Response Team. February 1997.

8. Federal Superfund Removal Action File, Harper Leader Site (Site ID 012X). U.S.Environmental Protection Agency, Region I, Office of Site Remediation andRestoration.

9. Dr. Dada Jabbour, Director of Hazardous Materials, Waterbury Health Department,pers. comm. September 22, 1997.

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