SDMS DocID 274209 Via E-Mai anl d Certified Mail Return ...

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ONE CONGRESS STREET SUITE 1100 (Mail Code SES)

BOSTON MA 02114-2023

SDMS DocID 274209

Via E-Mail and Certified Mail Return Receipt Requested

July 27

Earl W Phillips Jr Esq Rich Fil Esq Robinson amp Cole LLP 280 1 rumbul l Street Hartford CT 06103-3597

RE Durham Meadows SF Site Partial Work UAO to the Durham Manufacturing Company Docket No 01-2007-0113

Dear Earl and Rich

Enclosed is a First Amended Unilateral Administrative Order for Remedial Design Sampling and Vapor Intrusion Remedial Action (EPA CERCLA Docket No 01-2007shy0113) and its appendices This Amended Order is being issued to the Durham Manufacturing Company (Durham) for performance of work on property owned by Durham EPA amended the original Order at your request to address issues you raised during the Order conference and subsequently regarding the original Order

Pursuant to Section XXIX of the enclosed Order the Order became effective today

As you know EPA is issuing this Order after a lengthy mediated negotiation and many discussions You have had a chance to review and comment upon the attached Statement of Work to the Order Given our negotiations we expect that Durham will commence work as soon as possible

We have received your letter of July 26 2007 and will respond at a later date

We look forward to resolving this matter and to completing sampling this season Please contact me at 617-918-1893 with any questions

Earl W Phillips Jr Esq Rich Fil Esq Page 2 of 2

W Kilborn 5enior Enforcement Counsel

Enclosures

cc Addie Fiske DOJ Anni Loughlin EPA Addie Fiskc USDO1 Jack Loonev CT Ad

FIRST AMENDED UNILATERAL ADMINISTRATIVE ORDER FOR REMEDIAL DESIGN SAMPLING AND VAPOR INTRUSION REMEDIAL ACTION

DURHAM MEADOWS SUPERFUND SITE

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 1-EPA NEW ENGLAND

ONE CONGRESS STREET BOSTON MA 02114-2023

In The Matter Of ) )

The Durham Meadows Superfund Site ) )

The Durham Manufacturing Company ) Respondent ) US EPA Docket No

)CERCLA 01-2007-0113 )

Proceeding Under Section 106(a) of the Comprehensive ) Environmental Response Compensation and Liability Act of ) 1980 as amended (42 USC 9606(a)) )


I INTRODUCTION AND JURISDICTION

1 This Order directs Respondent to perform remedial design sampling to support the design of a portion of the remedy described in the Record of Decision for the Durham Meadows Superfund Site dated September 30 2005 This Order also directs Respondent to perform a partial Remedial Action to address vapor intrusion at a building located on Respondents property This Order is issued to Respondent by the United States Environmental Protection Agency (EPA) under the authority vested in the President of the United States by section 106(a) of the Comprehensive Environmental Response Compensation and Liability Act of 1980 as amended (CERCLA) 42 USC 9606(a) This authority was delegated to the Administrator of EPA on January 23 1987 by Executive Order 12580 (52 Fed Reg 2926 January 29 1987) and further delegated to EPA Regional Administrators on September 13 1987 by EPA Delegation No 14-14-B and redelegated to the Director Office of Site Remediation and Restoration by EPA Region 1 Order No 1200 dated June 30 1995

II DEFINITIONS

2 Unless otherwise expressly provided herein terms used in this Order that are defined in CERCLA or in regulations promulgated under CERCLA shall have the meaning assigned to them in the statute or its implementing regulations Whenever terms listed below are used in this Order or in the documents attached to this Order or incorporated by reference into this Order the following definitions shall apply

a CERCLA shall mean the Comprehensive Environmental Response Compensation and Liability Act of 1980 as amended 42 USC 9601 et seq

b Contractor shall mean the company or companies retained by Respondent to undertake and complete the Work required by this Order Each contractor and subcontractor shall be qualified to do those portions of the Work for which it is retained

c Day shall mean a calendar day unless expressly stated to be a working day Working day shall mean a day other than a Saturday Sunday or Federal holiday In computing any period of time under this Order where the last day would fall on a Saturday Sunday or Federal holiday the period shall run until the end of the next working day

d DMC shall mean the Durham Manufacturing Company

e DMC Study Area shall mean the property on which the Durham Manufacturing Company facility is currently located at 201 Main Street Town of Durham Connecticut and any contiguous areas of soil andor overburden groundwater contamination as generally depicted in Exhibit 1 to the SOW

f EPA shall mean the United States Environmental Protection Agency and any successor departments or agencies of the United States

g EPA Hazardous Substance Superfund shall mean the Hazardous Substance Superfund established by the Internal Revenue Code 26 USC sect 9507

h National Contingency Plan or NCP shall mean the National Contingency Plan promulgated pursuant to Section 105 of CERCLA 42 USC 9605 codified at 40 CFR Part 300 including any amendments thereto

i Order shall mean this Order (Docket No CERCLA 01-2007-0113) and all Appendices attached hereto including Appendix 1 (SOW) The term Order includes all documents or workplans developed pursuant to the Order or SOW and all such submittals are incorporated into this Order

j Paragraph shall mean a portion of this Order identified by an arabic numeral

k Performance Standards shall mean those cleanup standards standards of control and other substantive requirements criteria or limitations identified in the Record of Decision and Statement of Work that the Work required by this Order must attain and maintain

1 Record of Decision or ROD shall mean the EPA Record of Decision relating to the Site signed on September 30 2005 by the Director of the EPA Region 1 Office of Site Remediation and Restoration and all attachments thereto

m Remedial Action or RA shall mean those activities to be undertaken by Respondent to implement a portion of the ROD in accordance with the SOW other than Remedial Design

n Remedial Design or RD shall mean those activities to be undertaken by Respondent to develop the final plans and specifications for the Remedial Action pursuant to the ROD and in accordance with the SOW

o RCRA shall mean the Solid Waste Disposal Act as amended 42 USC sectsect 6901 et seq (also known as the Resource Conservation and Recovery Act)

p Respondent shall mean the Durham Manufacturing Company and its successors and assigns

q Response Costs shall mean any costs incurred by the United States with respect to the Site pursuant to 42 USC 9601 et seq including but not limited to direct costs indirect costs enforcement costs and accrued interest incurred by the United States and the State to perform or support response actions at the Site Response costs include but are not limited to any oversight response costs

r Statement of Work or SOW shall mean the Statement of Work for Remedial Design Sampling and Vapor Intrusion Remedial Action at the Durham Manufacturing Company as set forth in Appendix 1 to this Order The Statement of Work is incorporated into this Order and is an enforceable part of this Order

s Section shall mean a portion of this Order identified by a roman numeral and includes one or more Paragraphs

t Site shall mean the Durham Meadows Superfund Site generally located along Main Street in the Town of Durham Connecticut as described in the Record of Decision

u Site-wide Groundwater Study Area shall mean the groundwater in the bedrock aquifer within the limits of the Site as well as residential areas impacted by groundwater

contamination from the source areas

v State shall mean the State of Connecticut

w United States shall mean the United States of America

x Work shall mean all activities Respondent is required to perform under this Order and any activities required to be undertaken pursuant to Sections VII through XXIV and Sections XXVI and XXVIII of this Order

III FINDINGS OF FACT EPA has determined that

3 The Durham Meadows Superfund Site is located in the Town of Durham Middlesex County Connecticut and includes an area of groundwater contamination generally centered on Main Street The Site includes historic Main Street in Durham center and contains industrial and residential properties The Site is generally bounded by Talcott Lane to the north Brick Lane Ball Brook and Allyn Brook to the East Allyn Brook to the south and wetlands west of Maple Avenue to the west

4 The Site includes Respondents manufacturing facility located at 201 Main Street

5 Hazardous substances have been released at or from the Site Such substances include without limitation volatile organic compounds (VOCs) such as trichloroethene (also known as trichloroethylene or TCE) 111-trichloroethane (also known as 111-TCA or TCA) xylene benzene methylene chloride toluene and tetrachloroethene (PCE) VOCs have been detected in soil and groundwater at the DMC property and at other locations within the Site and in residential drinking water wells within the Site

6 Pursuant to Section 105 of CERCLA 42 USC sect 9605 EPA placed the Durham Meadows Superfund Site on the National Priorities List (NPL) set forth at 40 CFR Part 300 Appendix B by publication in the Federal Register on October 4 1989

7 As a result of the release or threatened release of hazardous substances EPA has undertaken response actions at or in connection with the Site under Section 104 of CERCLA 42 USC sect 9604 and will undertake response actions in the future The State has also taken actions at or in connection with the Site to respond to hazardous waste or hazardous materials

8 EPA performed a remedial investigation pursuant to CERCLA and the NCP The remedial investigation report (RI Report) dated June 2005 summarized Site conditions and related potential human health and ecological risks

9 EPA performed a baseline human health risk assessment pursuant to CERCLA and the

NCP The baseline risk assessment report dated June 2005 summarized potential human health risks associated with Site-related contamination

10 EPA pursuant to CERCLA and the National Contingency Plan 40 CFR Part 300 performed a feasibility study of potential cleanup options and a feasibility study report (FS Report) was issued in June 2005 The FS Report presented the remedial alternatives evaluated to address Site conditions and potential risks

11 Based on the information and conclusions contained in the RI and FS Reports EPA also prepared a Technical Impracticability Evaluation Report (TI Evaluation) issued June 2005 pursuant to EPAs Technical Impracticability Guidance and the National Contingency Plan 40 CFR Part 300 The purpose of the TI Evaluation was to evaluate the practicability of returning groundwater to its beneficial use

12 Based on the information and conclusions contained in the baseline human health risk assessment RI and FS Reports as well as the TI Evaluation EPA issued a proposed plan (the Proposed Plan) on July 9 2005 The Proposed Plan presented EPAs recommended cleanup approach for the Site and summarized the options and information considered for the publics review and comment A notice and comment period published in the Federal Register followed the release of the Proposed Plan and concluded on August 12 2005 After the notice and comment period concluded EPA considered all comments received before finalizing selection of the remedial action plan The remedial action plan was finalized in a detailed Record of Decision (ROD) for the Site which was issued on September 30 2005 The ROD documents the selected cleanup remedy for the Site Appendix D of the ROD summarizes EPAs response to comments received during the notice and comment period for the Proposed Plan The RI Report FS Report the baseline risk assessment report the TI Evaluation and the ROD are part of the administrative record for this Order The ROD is incorporated into this Order and these Findings of Fact by reference

A Sources of Contamination and Primary Contaminants

13 At the DMC Study Area Respondent has manufactured and currently manufactures metal boxes and displays among other items Respondent has used various solvents during its operations including without limitation TCE (from the 1940s through the present) 111-TCA (from 1973-1976) and methylene chloride (used from 1976 through the present) In 1982 solvent usage was approximately 1000 gallons per month and the wastewater stream was approximately 4000 gallons per month

14 In 1951 Respondent installed a 750-gallon settling tank to receive wastewater and paint sludge from wet paint spray booths and a caustic stripper tank Approximately 500 gallons per year of sludge were pumped from the tank Supernatant in the tank was discharged into a ditch located in the DMC Study Area Approximately 1200 gallons of water per week moved through the settling tank to the ditch as a result of cleaning operations of the wet paint spray booths

15 An aeration pond was constructed in 1960 to receive non-contact cooling water from the degreasing and spot-welding operations and storm water from drains located around the parking lot and roof

16 In 1974 Respondent replaced the 750-gallon tank with a 5000-gallon tank which continued to receive wastewater and sludge from the wet paint spray booths and caustic stripper Water was eventually drained into a leaching field located in the DMC Study Area

17 From approximately 1974 through 1978 Respondent used unlined sludge drying beds in its wastewater treatment operations Accumulated paint sludge from the settling tank was directed into one of two drying beds approximately twice a year The sludge was dug out of the drying beds by hand approximately once a year drummed and taken to the DurhamMiddlefield landfill for disposal

18 Based on analytical data from extraction well EX-6 on the DMC Study Area a methylene chloride spill occurred in the area sometime in the mid-1990s

19 The primary contaminants in soil at the DMC Study Area include chlorinated VOCs such as TCE PCE and methylene chloride and non-chlorinated VOCs such as ethylbenzene toluene total xylenes and MTBE Primary contaminants in overburden (shallow) groundwater at the DMC Study Area include chlorinated VOCs such as TCE PCE and methylene chloride and non-chlorinated VOCs such as benzene ethylbenzene toluene and total xylenes Chlorinated VOCs detected in deeper bedrock groundwater wells at the DMC Study Area include TCE PCE 111-TCA 11-DCA 11-dichloroethene (11-DCE) 12-dichloroethene (12-DCE) cisshy12-dichloroethene (cis- 12-DCE) methylene chloride and vinyl chloride

20 A primary source of groundwater contamination in the Site-wide Groundwater Study Area includes spills past waste disposal practices andor other Site activities at the DMC Study Area The overburden soils impacted by this Study Area are another likely source of groundwater contamination in the bedrock aquifer

21 The primary contaminants in the Site-wide Groundwater Study Area are VOCs primarily chlorinated solvents (PCE TCE and 111-TCA) VOCs detected included solvents used in the industrial processes at the DMC Study Area Daughter compounds that likely result from the degradation of the primary chlorinated solvents were also detected in bedrock groundwater including cis-12-DCE trans-12-dichloroethene 11-DCE 11-DCA and vinyl chloride

B Exposure Pathways and Risks

22 Exposure to the contaminants described above in Paragraph 19 at the DMC Study Area presents a significant risk to human health if left untreated As described in the Section G of the ROD EPAs generally acceptable risk range for site-related exposure is 10-4 to 10-6 (1E-04 to

1E-06 or 1 in 10000 to 1 in a million) In assessing the potential for non-cancer adverse effects a hazard quotient (HQ) is calculated An HQ less than or equal to 1 (1E+00) indicates that toxic noncarcinogenic effects from a given chemical are unlikely

23 The unacceptable levels of cancer risk and non-cancer hazard caused by the actual or threatened release from the Site of the hazardous substances identified in Paragraphs 19 and 21 result in the following increased risks

a The excess lifetime cancer risk estimate for the current and future commercial worker for exposure to contaminants contained in untreated groundwater (by ingestion and dermal contact) from the DMC Study Area supply well (DMC 1) is 2E-04 and the estimated non-cancer risk is a hazard index of 5

b The excess lifetime cancer risk estimate for the future resident that may come to be located at the DMC Study Area and potentially exposed to contaminants contained in indoor air (by inhalation) following untreated vapor migration from overburden groundwater is 8E-03 and the estimated non-cancer risk is a hazard index of 4

c The estimated non-cancer risk for the future construction worker for exposure to contaminants contained in untreated shallow groundwater (by dermal contact) at the DMC Study Area is a hazard index of 30 and

d The excess lifetime cancer risk estimates for current and future residential exposure to contaminants contained in untreated groundwater (by ingestion dermal contact and inhalation) in the Site-wide Groundwater Study Area as household water range from 2E-04 to 3E-02 and the estimated non-cancer risks range from 2 to 900

24 Shallow and deeper groundwater at the DMC Study Area exhibits elevated concentrations of the contaminants described above in Paragraph 19 The levels of untreated groundwater contaminants exceed federal and state drinking water levels The levels of untreated groundwater contaminants also exceed state and federal levels related to the volatilization of contaminants into indoor air Soil at the DMC Study area exceeds direct contact and pollutant mobility criteria established by the States Remediation Standard Regulations The presence of these elevated levels of contaminants if not addressed poses an unacceptable level of risk to human health

25 A zone of groundwater contamination extends off of the DMC Study Area primarily to the south and southwest VOC concentrations in untreated groundwater exceeding federal and state drinking water levels extend off of the DMC Study Area and have impacted residential drinking wells in this area The presence of VOCs poses an unacceptable level of risk to human health namely through residential household water exposure to untreated groundwater

26 A range of health effects is associated with exposure to the primary contaminants

detected at the DMC Study Area and in the Site-wide Groundwater Study Area Benzene and vinyl chloride are known human carcinogens methylene chloride 11 -DCE PCE and TCE are probable or possible human carcinogens The effects of exposure to other contaminants (ethylbenzene 111-TCA and toluene) include eye nose and throat irritation nausea loss of coordination liver and kidney damage central nervous system damage and teratogenic effects

C Selected Remedy

27 The ROD sets forth the selected remedy for the Site which is detailed and described therein

28 This Order requires soil and groundwater sampling to support the remedial design of the excavation and off-site disposal of hot spot areas of soil contamination which is a portion of the remedy for the DMC Study Area Such remedial action will significantly reduce the risk posed to construction workers through direct contact of contaminants in groundwater immediately upon completion of the excavation and will reduce the concentrations of contaminants in groundwater by removing ongoing sources of contamination

29 This Order also requires that a sub-slab depressurization system be installed under the main manufacturing building at the DMC Study Area to mitigate the potential threat of the intrusion of contaminated vapors into the building

D Identification of Respondent

30 Respondent is a corporation organized under the laws of the State of Connecticut with its principal place of business in Durham Connecticut

31 Respondent is the owner of the property at 201 Main Street Durham Connecticut and has been the owner of such property since 1922

32 Respondent has operated a manufacturing facility on the DMC Study Area since 1922

33 By letter dated November 30 1993 EPA notified Respondent of its potential liability with respect to the Site

34 By letter dated April 7 2006 EPA notified Respondent of a sixty-day period to participate in formal negotiations to reach a settlement to conduct or finance response actions at the Site and to reimburse EPA for its response costs

35 In performing response actions at the Site EPA has incurred and will continue to incur response costs at or in connection with the Site

IV CONCLUSIONS OF LAW AND DETERMINATIONS

Based on the Findings of Fact set forth above and the Administrative Record supporting this Order EPA has determined that

36 The DMC Study Area is a facility as defined in section 101(9) of CERCLA 42 USC 9601(9)

37 The Respondent is a person as defined in section 101(21) of CERCLA 42 USC 9601(21)

38 The Respondent is a liable party as defined in section 107(a) of CERCLA 42 USC 9607(a) and is subject to this Order under section 106(a) of CERCLA 42 USC 9606(a)

39 The substances listed in paragraphs 5 and 19 are found at the DMC Study Area and are hazardous substances as defined in section 101(14) of CERCLA 42 USC 9601(14)

40 The hazardous substances listed in paragraphs 5 and 19 have been and continue to be released at andor from the DMC Study Area into the soil and groundwater

41 The disposal and migration of hazardous substances at andor from the DMC Study Area and the potential for future migration of hazardous substances from the DMC Study Area are a release as defined in section 101(22) of CERCLA 42 USC 9601(22)

42 The actual and threatened release of one or more hazardous substances from the facility may present an imminent and substantial endangerment to the public health or welfare or the environment The overall factual basis for this imminent and substantial endangerment is contained in the Findings of Fact and is supported by documents maintained in the Administrative Record

43 The actions required by this Order are necessary to protect the public health welfare and the environment

44 The actions specified in this Order shall be done promptly and properly by Respondent and will be consistent with the NCP and performed in accordance with the terms of this Order and SOW

V NOTICE TO THE STATE

45 On June 25 2007 prior to issuing this Order EPA notified the State of Connecticut that EPA would be issuing this Order

10

VI ORDER

46 Based on the foregoing and the administrative record Respondent is hereby ORDERED to comply with the following provisions including but not limited to all attachments to this Order all documents incorporated by reference into this Order and all schedules and deadlines in this Order attached to this Order or incorporated by reference into this Order

VII NOTICE OF INTENT TO COMPLY

47 Respondent shall provide not later than five (5) days after the effective date of this Order written notice to EPAs Remedial Project Manager (RPM) stating whether it will comply with the terms of this Order If Respondent does not unequivocally commit to perform the Work as provided by this Order it shall be deemed to have violated this Order and to have failed or refused to comply with this Order Respondents written notice shall describe using facts that exist on or prior to the effective date of this Order any sufficient cause defenses asserted by Respondent under sections 106(b) and 107(c)(3) of CERCLA The absence of a response by EPA to the notice required by this paragraph shall not be deemed to be acceptance of Respondents assertions

VIII PARTIES BOUND

48 This Order shall apply to and be binding on the Respondent and its directors officers employees agents successors and assigns No change in the ownership corporate status or other control of Respondent shall alter the Respondents responsibilities under this Order

49 Respondent shall provide a copy of this Order to any prospective owners or successors before a controlling interest in Respondents assets property rights or stock are transferred to the prospective owner or successor Respondent shall provide a copy of this Order to each contractor sub-contractor laboratory or consultant retained to perform any Work under this Order within five days after the effective date of this Order or on the date such services are retained whichever date occurs later Respondent shall also provide a copy of this Order to each person representing Respondent with respect to the Site or the Work and shall condition all contracts and subcontracts entered into hereunder upon performance of the Work in conformity with the terms of this Order With regard to the activities undertaken pursuant to this Order each contractor and subcontractor shall be deemed to be related by contract to the Respondent within the meaning of section 107(b)(3) of CERCLA 42 USC 9607(b)(3) Notwithstanding the terms of any contract Respondent is responsible for compliance with this Order and for ensuring that its contractors subcontractors and agents comply with this Order and perform any Work in accordance with this Order

50 Not later than sixty (60) days prior to any transfer of any real property interest in any property included within the Site Respondent shall submit a true and correct copy of the transfer document(s) to EPA and shall identify the transferee by name principal business address and

11

effective date of the transfer

IX INCORPORATION OF DOCUMENTS

51 All appendices and attachments to this Order and subsequent modifications to such appendices and attachments are incorporated into this Order and are enforceable under it Any and all other plans specifications schedules and other documents required by the terms of this Order (including its appendices and attachments) and subsequent modifications to such plans specifications schedules and other documents shall be incorporated herein and enforceable hereunder

X WORK TO BE PERFORMED

52 Respondent shall finance and perform at a minimum the Work specified in the SOW attached to this Order (Appendix 1) consistent with the ROD All activities required by this Order shall be conducted in accordance with CERCLA the NCP EPA policies and procedures as amended and the SOW EPA at its discretion may perform some or all of the actions identified in the ROD and SOW

53 EPA may modify the SOW if such modification is determined by EPA to be necessary to attain the Performance Standards set forth herein or for the protection of public health welfare or the environment Upon written consent of the Director of the Office of Site Remediation and Restoration EPA Region 1 such modification to the SOW shall become enforceable under this Order

54 Respondent shall cooperate with EPA in providing information regarding the Work to the public As requested by EPA Respondent shall participate in the preparation of such information for distribution to the public and in public meetings which may be held or sponsored by EPA to explain activities at or relating to the Site

55 The Work performed by Respondent pursuant to this Order shall at a minimum achieve the Performance Standards specified in the Statement of Work

56 Notwithstanding any action by EPA Respondent remains fully responsible for achievement of the Performance Standards in the Statement of Work Nothing in this Order or in EPAs approval of the Statement of Work or in any work plans required by the SOW or approval of any other submission shall be deemed to constitute a warranty or representation of any kind by EPA that full performance of the Remedial Design or Remedial Action will achieve the Performance Standards set forth in the ROD or in the Statement of Work Respondents compliance with such approved documents does not foreclose EPA from seeking additional work to achieve the applicable Performance Standards

12

A Designation of Project Coordinator Contractor and Remedial Project Manager

57 Within ten (10) days after the effective date of this Order Respondent shall designate a Project Coordinator and shall submit the name address telephone number and technical qualifications of the Project Coordinator to EPA for review and approval Respondents Project Coordinator shall be responsible for overseeing Respondents implementation of this Order and all aspects of the Work If Respondent wishes to change its Project Coordinator Respondent shall provide written notice to EPA five (5) days prior to changing the Project Coordinator of the name and qualifications of the new Project Coordinator Respondents selection or change of a Project Coordinator shall be subject to EPA approval If EPA disapproves of a selected Project Coordinator Respondent shall retain a different Project Coordinator and shall notify EPA for EPA approval of that persons name and qualifications within ten (10) days following EPAs disapproval Receipt by Respondents Project Coordinator of any notice or communication from EPA relating to this Order shall constitute receipt by Respondent The Project Coordinator shall not be an attorney for the Respondent

58 All aspects of the Work to be performed by Respondent pursuant to this Order shall be under the direction and supervision of a Supervising Contractor the selection of which shall be subject to approval by EPA Within ten (10) days after the effective date of this Order Respondent shall notify EPA in writing of the name and qualifications of the Supervising Contractor including primary support entities and staff proposed to be used in carrying out Work under this Order If at any time Respondent proposes to use a different Supervising Contractor Respondent shall notify EPA and shall obtain approval from EPA before the new Supervising Contractor performs any Work under this Order

59 EPA will review Respondents selection of a Supervising Contractor according to the terms of this paragraph and Section XV of this Order If EPA disapproves of the selection of the Supervising Contractor Respondent shall submit to EPA within thirty (30) days after receipt of EPAs disapproval of the Supervising Contractor previously selected a list of Supervising Contractors including primary support entities and staff that would be acceptable to Respondent EPA will thereafter provide written notice to Respondent of the names of the Supervising Contractors that are acceptable to EPA Respondent may then select any approved Supervising Contractors from that list and shall notify EPA of the name of the Supervising Contractor selected within twenty-one (21) days of EPAs designation of approved project managers

60 Respondent shall notify EPA of the names and qualifications of any contractors or subcontractors retained to perform the Work under this Order at least five (5) business days prior to commencement of such Work

61 The EPA retains the right to disapprove of any or all of the contractors andor subcontractors retained by Respondent If EPA disapproves of a selected contractor or subcontractor Respondent shall retain a different contractor or subcontractor within thirty (30) days of EPAs disapproval

13

62 The United States shall not be held out as a party to any contract entered into by or on behalf of the Respondent in carrying out the Work

63 EPA will appoint a Remedial Project Manager (RPM) who shall have the authority to be on Site at all times including when Work is being undertaken pursuant to this Order

64 EPA has the unreviewable right to change its Remedial Project Manager If EPA changes its Remedial Project Manager EPA will inform Respondent in writing of the name address and telephone number of the new Remedial Project Manager

65 EPAs RPM shall have the authority lawfully vested in a Remedial Project Manager (RPM) and On-Scene Coordinator (OSC) by the NCP or any similar provisions in future amendments or revisions to the NCP EPAs RPM shall have authority consistent with the NCP to halt any work required by this Order and to take any necessary response action

66 The absence of the RPM from the Site shall not be cause for stoppage of work

67 The employees agents consultants contractors and authorized representatives of EPA and the State shall also have the authority to be on the Site at all times when the Work is being performed and to engage in activities relating to enforcement of this Order

B Remedial Design Sampling

68 Respondent shall perform the Remedial Design groundwater and soil sampling and other related activities (such as the submission of reports) according to the requirements and schedule set forth in the SOW Respondent shall submit to EPA all plans submittals and other deliverables required under the SOW in accordance with the approved schedule for review and approval pursuant to Section XV (EPA Review of Submissions) Upon approval by EPA all plans and documents associated with any Remedial Design sampling activities shall be incorporated into this Order as a requirement of this Order and shall be an enforceable part of this Order

C Remedial Action for Vapor Intrusion

69 Respondent shall install a sub-slab depressurization system that addresses the entire foundation of the main manufacturing building at the DMC Study Area and perform other related activities (such as the submission of reports) according to the requirements and schedule set forth in the SOW Respondent shall submit to EPA all plans submittals and other deliverables required under the SOW in accordance with the approved schedule for review and approval pursuant to Section XV (EPA Review of Submissions) Upon approval by EPA all plans and documents associated with any activities relating to the sub-slab depressurization system shall be incorporated into this Order as a requirement of this Order and shall be an enforceable part of this Order

14

D Off-Site Shipments

70 Before shipping any hazardous substances pollutants or contaminants from the Site to any off-Site location Respondent shall first obtain EPAs certification that the proposed receiving facility is operating in compliance with the requirements of CERCLA Section 121(d)(3) and 40 CFR 300440 Respondent shall only send hazardous substances pollutants or contaminants from the Site to an off-Site facility that complies with the requirements of the statutory provision and regulations cited in the preceding sentence Respondent shall provide EPA with advance notice of the proposed receiving facility(ies) at least three weeks prior to the expected date of shipment

E Certification of Completion

71 Within thirty (30) days after Respondent concludes that the Work has been fully performed and the Performance Standards for such actions have been attained Respondent shall so notify EPA and shall schedule and conduct a pre-certification inspection to be attended by Respondent and EPA (For the purpose of this subsection the term Work shall not include operation and maintenance) The pre-certification inspection shall be followed by a written report submitted within thirty (30) days of the inspection by a registered professional engineer and Respondents Project Coordinator certifying that the Work has been completed in full satisfaction of the requirements of this Order If after completion of the pre-certification inspection and receipt and review of the written report EPA determines that the Work or any portion thereof has not been completed in accordance with this Order EPA shall notify Respondent in writing of the activities that must be undertaken to complete the Work and shall set forth in the notice a schedule for performance of such activities Respondent shall perform all activities described in the notice in accordance with the specifications and schedules established therein If EPA concludes following the initial or any subsequent certification of completion by Respondent that the Work has been fully performed in accordance with this Order EPA may notify Respondent that the Work has been fully performed EPAs notification shall be based on present knowledge and Respondents certification to EPA and shall not limit Respondents obligation to perform operation and maintenance pursuant to the SOW or otherwise EPAs right to perform periodic reviews pursuant to section 121 (c) of CERCLA 42 USC 962 l(c) or to take or require any action that in the judgment of EPA is appropriate at the Site in accordance with 42 USC 9604 9606 or 9607

XI FAILURE TO ATTAIN PERFORMANCE STANDARDS

72 In the event that EPA determines that additional response activities are necessary to meet applicable Performance Standards EPA may notify Respondent that additional response actions are necessary

73 Unless otherwise stated by EPA within thirty (30) days of receipt of notice from EPA that additional response activities are necessary to meet any applicable Performance Standards

15

Respondent shall submit for approval by EPA a work plan for the additional response activities The plan shall conform to the applicable requirements of Sections X XVII and XVIII of this Order Upon EPAs approval of the plan pursuant to Section XV Respondent shall implement the plan for additional response activities in accordance with the provisions and schedule contained therein

XII EPA PERIODIC REVIEW

74 Under section 121(c) of CERCLA 42 USC 962l(c) and any applicable regulations EPA may review the Site periodically Respondent shall conduct the requisite studies investigations or other response actions as determined necessary by EPA in order to permit EPA to conduct the review under section 121 (c) of CERCLA As a result of any review performed under this paragraph Respondent may be required to perform additional Work or to modify Work previously performed

XIII ADDITIONAL RESPONSE ACTIONS

75 EPA may determine that in addition to the Work identified in this Order and attachments to this Order additional response activities may be necessary to protect human health and the environment If EPA determines that additional response activities are necessary EPA may require Respondent to submit a work plan for additional response activities EPA may also require Respondent to modify any plan design or other deliverable required by this Order including any approved modifications

76 Unless otherwise directed by EPA within thirty (30) days after receiving EPAs notice that additional response activities are required pursuant to this Section Respondent shall submit a work plan for the response activities to EPA for review and approval Upon approval by EPA the work plan is incorporated into this Order as a requirement of this Order and shall be an enforceable part of this Order Upon approval of the work plan by EPA Respondent shall implement the work plan according to the standards specifications and schedule in the approved work plan Respondent shall notify EPA of its intent to perform such additional response activities within seven (7) days after receipt of EPAs request for additional response activities

XIV ENDANGERMENT AND EMERGENCY RESPONSE

77 In the event of any action or occurrence during the performance of the Work which causes or threatens to cause a release of a hazardous substance or which may present an immediate threat to public health or welfare or the environment Respondent shall immediately take all appropriate action to prevent abate or minimize the threat and shall immediately notify EPAs RPM and the Regional Duty Officer of the Emergency and Planning and Response Branch EPA Region I If EPAs RPM is not available Respondent shall notify the Emergency Planning and Response Branch Region I United States Environmental Protection Agency (800) 424-8802 Respondent shall take such action in consultation with EPAs RPM and in accordance with all applicable provisions of this Order including but not limited to the Health and Safety

16

Plan developed pursuant to the SOW and approved there under To the extent that the Site Health and Safety Plan does not cover the particular situation Respondent shall develop and submit a response plan to EPA within ten (10) days The provisions of Section XV apply to the submission of any such response plan except that the time period for resubmission after disapproval shall be five (5) days rather than twenty (20) days unless extended by EPA In the event that Respondent fails to take appropriate response action as required by this Section and EPA takes that action instead Respondent shall reimburse EPA for all costs of the response action not inconsistent with the NCP Respondent shall pay the response costs in the manner described in Section XXIV of this Order within thirty (30) days of Respondents receipt of demand for payment of the costs incurred

78 Nothing in the preceding paragraph shall be deemed to limit any authority of the United States a) to take all appropriate action to protect human health and the environment or to prevent abate respond to or minimize an actual or threatened release of hazardous substances on at or from the Site or b) to direct or order such action or seek an order from the Court to protect human health and the environment or to prevent abate respond to or minimize an actual or threatened release of hazardous substances on at or from the Site

XV EPA REVIEW OF SUBMISSIONS

79 After review of any deliverable plan report or other item which is required to be submitted for review and approval pursuant to this Order EPA after reasonable opportunity for review and comment by the State may (a) approve the submission (b) approve the submission with conditions (c) disapprove the submission and direct Respondent to re-submit the document after incorporating EPAs comments (d) disapprove the submission and develop or modify the submission or perform all or any part of the response action (e) take any other action EPA is legally authorized to take and deems appropriate or (f) a combination of (a) - (e) above As used in this Order the terms approval by EPA EPA approval or a similar term means the action described in subparagraphs (a) or (b) of this Paragraph

80 In the event of approval or approval with conditions by EPA Respondent shall proceed to take any action required by the plan report or other item as approved or conditionally approved by EPA

81 Upon receipt of a notice of disapproval in Paragraph 79(c) Respondent shall within twenty-one (21) days or such longer time as specified by EPA in its notice of disapproval correct the deficiencies and resubmit the plan report or other item for approval Notwithstanding the notice of disapproval Respondent shall proceed at the direction of EPA to take any action required by any non-deficient portion of the submission

82 If any submission is not approved by EPA Respondent shall be deemed to be in violation of this Order

83 Upon approval or conditional approval or modification by EPA following disapproval

17

of a plan report or other item it shall be incorporated into and shall become enforceable under this Order

XVI PROGRESS REPORTS AND REPORTING

84 In addition to the other deliverables set forth in this Order Respondent shall provide monthly progress reports to EPA with respect to actions and activities undertaken pursuant to this Order as required by the SOW until completion of the Work The progress reports shall be submitted on or before the 10th day of each month following the effective date of this Order Respondents obligation to submit progress reports continues until EPA gives Respondent written notice under Paragraph 71 At a minimum these progress reports shall (a) describe the actions which have been taken toward achieving compliance with this Order during the previous month (b) include a summary of all results of sampling and tests and all other data received or generated by Respondent or its contractors or agents in the previous month (c) identify all work plans plans and other deliverables required by this Order completed and submitted during the previous month (d) describe all actions including but not limited to data collection and implementation of work plans which are scheduled for the next six weeks and provide other information relating to the progress of construction including but not limited to critical path diagrams Gantt charts and PERT charts (e) include information regarding percentage of completion unresolved delays encountered or anticipated that may affect the future schedule for implementation of the Work and a description of efforts made to mitigate those delays or anticipated delays and (f) include any modifications to the work plans or other schedules that Respondent have proposed to EPA or that have been approved by EPA If requested by EPA Respondent shall also provide briefings for EPA to discuss the progress of the Work In addition Respondent shall submit in electronic form all reports and other deliverables Respondent are required to submit pursuant to the provisions of this Order

85 Respondent shall notify EPA of any change in the schedule described in the monthly progress report for the performance of any activity including but not limited to data collection and implementation of work plans no later than seven (7) days prior to the performance of the activity

86 Upon the occurrence of any event during performance of the Work that Respondent is required to report pursuant to Section 103 of CERCLA or Section 304 of the Emergency Planning and Community Right-to-Know Act (EPCRA) Respondent shall within 24 hours of the onset of such event orally notify the EPA RPM or in the event that the EPA RPM is not available the Emergency Planning and Response Branch Region I United States Environmental Protection Agency (800)-424-8802 These reporting requirements are in addition to the reporting required by CERCLA Section 103 or EPCRA Section 304

87 Within twenty (20) days of the onset of such an event Respondent shall furnish to EPA a written report signed by the Respondents Project Coordinator setting forth the events which occurred and the measures taken and to be taken in response thereto Within thirty (30) days of the conclusion of such an event Respondent shall submit a report setting forth all actions taken in response thereto

18

88 Respondent shall submit three (3) copies of all plans reports and data required by the SOW or any other approved plans to EPA in accordance with the schedules set forth in such plans Respondent shall simultaneously submit one (1) copy of all such plans reports and data to the State In addition Respondent shall submit in electronic form all reports and other deliverables Respondent are required to submit pursuant to the provisions of this Order

89 All reports and other documents submitted by Respondent to EPA (other than the monthly progress reports referred to above) which purport to document Respondents compliance with the terms of this Order shall be signed by an authorized representative of the Respondent

XVII QUALITY ASSURANCE SAMPLING AND DATA ANALYSIS

90 Respondent shall use quality assurance quality control and chain of custody procedures for all treatability pre-design design compliance and monitoring samples in accordance with EPA Requirements for Quality Assurance Project Plans (QAR5) (EPA240B-01003 March 2001) Guidance for Quality Assurance Project Plans (QAG-5) (EPA600R-98018 February 1998) and subsequent amendments to such guidelines upon notification by EPA to Respondent of such amendment Amended guidelines shall apply only to procedures conducted after such notification Prior to the commencement of any monitoring project under this Order Respondent shall submit to EPA for approval a Quality Assurance Project Plan (QAPP) that is consistent with the SOW the ROD the NCP and applicable guidance documents

91 Respondent shall ensure that EPA personnel and their authorized representatives are allowed access at reasonable times to all laboratories utilized by Respondent in implementing this Order In addition Respondent shall ensure that such laboratories shall analyze all samples submitted by EPA (if any) pursuant to the QAPP for quality assurance monitoring

92 Respondent shall ensure that the laboratories it uses for the analysis of samples taken pursuant to this Order perform all analyses according to accepted EPA methods Accepted EPA methods consist of those methods which are documented in current Contract Laboratory Program Statements of Work (CLP SOW) and any amendments made thereto during the course of the implementation of this Decree however upon approval by EPA the Respondent may use other analytical methods which are as stringent as or more stringent than the CLP-approved methods

93 Respondent shall ensure that all laboratories it uses for analysis of samples taken pursuant to this Order participate in an EPA or EPA-equivalent QAQC program Respondent shall only use laboratories that have a documented Quality System which complies with ANSIASQC E4-1994 Specifications and Guidelines for Quality Systems for Environmental Data Collection and Environmental Technology Programs (American National Standard January 5 1995) and EPA Requirements for Quality Management Plans (QAR-2) (EPA240B-01002 March 2001) or equivalent documentation as determined by EPA EPA may consider laboratories accredited under the National Environmental Laboratory Accreditation Program (NELAP) as meeting the Quality System requirements

19

94 Respondent shall ensure that all field methodologies utilized in collecting samples for subsequent analysis pursuant to this Order will be conducted in accordance with the procedures set forth in the QAPP approved by EPA

95 Respondent shall notify EPA not less than fourteen (14) days in advance of any sample collection activity unless shorter notice is agreed to by EPA At the request of EPA Respondent shall allow split or duplicate samples to be taken by EPA or its authorized representatives of any samples collected by Respondent with regard to the Site or pursuant to the implementation of this Order In addition EPA shall have the right to take any additional samples that EPA deems necessary including samples deemed necessary as part of EPAs oversight of Respondents implementation of the Work

96 Respondent shall simultaneously submit to EPA and the State three (3) copies and one (1) copy respectively of the results of all sampling andor tests or other data obtained or generated by or on behalf of Respondent with respect to the Site andor the implementation of this Order unless EPA agrees otherwise

97 If relevant to any proceeding validated sampling data generated in accordance with the QAPP(s) and reviewed and approved by EPA shall be admissible as evidence without objection in any proceeding under this Order

XVIII COMPLIANCE WITH APPLICABLE LAWS

98 All activities by Respondent pursuant to this Order shall be performed in accordance with the requirements of all Federal and state laws and regulations EPA has determined that the activities contemplated by this Order are consistent with the National Contingency Plan (NCP)

99 Except as provided in section 121(e) of CERCLA and the NCP no permit shall be required for any portion of the Work conducted entirely on-Site Where any portion of the Work requires a Federal or state permit or approval Respondent shall submit timely applications and take all other actions necessary to obtain and to comply with all such permits or approvals

100 This Order is not and shall not be construed to be a permit issued pursuant to any Federal or state statute or regulation

101 The Work performed by the Respondent pursuant to this Order must at a minimum satisfy all applicable or relevant and appropriate federal and state standards requirements criteria or limitations as specified in the ROD and as required under Section 121 (d) of CERCLA

102 All remedial activities must meet or attain all location chemical and action-specific applicable or relevant and appropriate federal and state standards requirements criteria and limitations (ARARs) identified in the ROD the SOW and by EPA prior to notification of completion of Work and must attain all Performance Standards identified in the ROD the SOW

20

and by EPA prior to notification of completion of Work

103 The Respondent shall include in all contracts or subcontracts entered into for work performed under this Order provisions stating that such contractors or subcontractors including their agents and employees shall perform all activities required by such contracts or subcontracts in compliance with all applicable laws and regulations

XIX SITE ACCESS AND INSTITUTIONAL CONTROLS

104 Commencing on the effective date of this Order Respondent shall provide the United States the State and their representatives including EPA and its contractors and subcontractors with access at all reasonable times to any property owned by Respondent within the Site for the purpose of conducting any activity related to this Order including but not limited to the following activities

(1) monitoring the Work (2) verifying any data or information submitted to the EPA (3) conducting investigations relating to contamination at or near the Site (4) obtaining samples (5) assessing the need for planning or implementing additional response actions

at or near the Site (6) assessing implementation of quality assurance and quality control practices as

defined in the approved Quality Assurance Project Plans (7) inspecting and copying records operating logs contracts or other documents

maintained or generated by Respondent or their agents consistent with Section XX (DataDocument Availability)

(8) assessing Respondents compliance with this Order and (9) determining whether the Site or other property is being used in a manner that

is prohibited or restricted or that may need to be prohibited or restricted by or pursuant to this Order

105 Respondent shall obtain or use its best efforts to obtain Site access agreements for Respondent and Respondents authorized representatives and contractors from the present owner(s) of any property where access is needed to conduct the Work and also for the United States and the State within thirty (30) days of the effective date of this Order Such agreements shall specify that Respondent is not EPAs the United States or the States representative with respect to liability associated with Site activities Respondent shall save and hold harmless the United States and its officials agents employees contractors subcontractors or representatives for or from any and all claims or causes of action or other costs incurred by the United States including but not limited to attorneys fees and other expenses of litigation and settlement arising from or on account of acts or omissions of Respondent its officers directors employees agents contractors subcontractors and any persons acting on its behalf or under its control in carrying out activities pursuant to this Order including any claims arising from any designation of Respondent as EPAs authorized representatives under section 104(e) of CERCLA Copies of such access agreements shall be provided to EPA prior to Respondents initiation of field

21

activities Respondents best efforts shall include providing reasonable compensation as necessary If access agreements are not obtained within the time referenced above Respondent shall immediately notify EPA of its failure to obtain access Subject to the United States nonshyreviewable discretion EPA may use its legal authorities to obtain access for Respondent may perform those response actions with EPA contractors at the property in question or may terminate the Order if Respondent cannot obtain access agreements If EPA performs those tasks or activities with contractors and does not terminate the Order Respondent shall perform all other activities not requiring access to that property and shall reimburse EPA for all costs incurred in performing such activities Respondent shall integrate the results of any such tasks undertaken by EPA into its reports and deliverables Respondent shall reimburse EPA pursuant to Section XXIV of this Order for all response costs (including attorney fees) incurred by the United States to obtain access for Respondent

106 Lack of access shall not excuse or justify failure to perform any activity or to meet any deadline not requiring or directly dependent upon such access

107 Notwithstanding any provision of this Order the United States retains all of its access authorities and rights under CERCLA and any other applicable statutes and regulations

XX DATADOCUMENT AVAILABILITY

108 Respondent shall provide to EPA and the State upon request copies of all documents and information within its possession andor control or that of its contractors or agents relating to activities at the Site or to the implementation of this Order including but not limited to sampling analysis chain of custody records manifests trucking logs receipts reports sample traffic routing correspondence or other documents or information related to the Work Respondent shall also make available to EPA for purposes of investigation information gathering or testimony its employees agents or representatives with knowledge of relevant facts concerning the performance of the Work

109 Respondent may assert a claim of business confidentiality covering part or all of the information submitted to EPA pursuant to the terms of this Order under 40 CFR 2203 provided such claim is not inconsistent with section 104(e)(7) of CERCLA 42 USC 9604(e)(7) or other provisions of law This claim shall be asserted in the manner described by 40 CFR 2203(b) and substantiated by Respondent at the time the claim is made Information determined to be confidential by EPA will be given the protection specified in 40 CFR Part 2 If no such claim accompanies the information when it is submitted to EPA it may be made available to the public by EPA or the State without further notice to the Respondent Respondent shall not assert confidentiality claims with respect to any data related to site conditions sampling or monitoring

110 Respondent shall maintain for the period during which this Order is in effect an index of documents that Respondent claim contain confidential business information The index shall contain for each document the date author addressee and subject of the document Upon written request from EPA Respondent shall submit a copy of the index to EPA either in writing or electronically

22

XXI RETENTION OF RECORDS

111 Until ten (10) years after EPA provides notice pursuant to Paragraph 71 Respondent shall preserve and retain all records and documents in its possession or control including the documents in the possession or control of its contractors and agents on and after the effective date of this Order that relate in any manner to the Site At the conclusion of this document retention period Respondent shall notify the United States at least ninety (90) calendar days prior to the destruction of any such records or documents and upon request by the United States Respondent shall deliver any such records or documents to EPA

112 Until ten (10) years after EPA provides notice pursuant to Paragraph 71 of this Order Respondent shall preserve and shall instruct its contractors and agents to preserve all documents records and information of whatever kind nature or description relating to the performance of the Work Upon the conclusion of this document retention period Respondent shall notify the United States at least ninety (90) days prior to the destruction of any such records documents or information and upon request of the United States Respondent shall deliver all such documents records and information to EPA

113 All data factual information or documents submitted to EPA by or on behalf of the Respondent may be made available for public inspection unless the Respondent demonstrates that the data factual information or documents satisfy the business confidentiality requirements of 40 USC sect 9604(e)(7)(E) and (F)

XXII NOTIFICATIONS AND SUBMITTALS

114 All communications whether written or oral from Respondent to EPA shall be directed to EPAs Remedial Project Manager Respondent shall submit to EPA three (3) copies of all documents including plans reports and other correspondence which are developed pursuant to this Order and shall send these documents by overnight mail unless EPA notifies Respondents Project Coordinator in writing of a change

EPAs Remedial Project Manager is

Anni Loughlin United States Environmental Protection Agency 1 Congress Street Suite 1100 (Mailcode HBT) Boston MA 02114-2023 Telephone (617) 918-1273 Facsimile (617) 918-0273 Email loughlinanniepagov

No informal advice guidance suggestions or comments by EPA regarding reports plans specifications schedules or any other writing submitted by the Respondent shall be construed as relieving the Respondent of its obligation to obtain such formal approvals as may be required

23

herein

Submissions directed to the State shall go to

Martin Beskind Connecticut Department of Environmental Protection 79 Elm Street Hartford CT 06106-5127

XXIII DELAY IN PERFORMANCE

115 Any delay in performance of this Order that in EPAs judgment is not properly justified by Respondent under the terms of this paragraph shall be considered a violation of this Order Any delay in performance of this Order shall not affect Respondents obligations to fully perform all obligations under the terms and conditions of this Order

116 Respondent shall notify EPA of any delay or anticipated delay in performing any requirement of this Order Such notification shall be made by telephone to EPAs RPM within forty eight (48) hours after Respondent first knew or should have known that a delay might occur Respondent shall adopt all reasonable measures to avoid or minimize any such delay Within five (5) business days after notifying EPA by telephone Respondent shall provide written notification fully describing the nature of the delay any justification for delay any reason why Respondent should not be held strictly accountable for failing to comply with any relevant requirements of this Order the measures planned and taken to minimize the delay and a schedule for implementing the measures that will be taken to mitigate the effect of the delay Increased costs or expenses associated with implementation of the activities called for in this Order is not a justification for any delay in performance

XXIV REIMBURSEMENT OF RESPONSE COSTS

117 Respondent shall reimburse EPA upon written demand for all response costs incurred by the United States in overseeing Respondents implementation of the requirements of this Order or in performing any response action that Respondent fails to perform in compliance with this Order including but not limited to the following direct and indirect costs time and travel of EPA personnel and associated indirect costs contractor costs cooperative agreement costs compliance monitoring costs costs of collection and analysis of split samples costs of inspecting Work activities costs of Site visits costs arising out of disputes relating to this Order costs of review and approval or disapproval of reports costs associated with community relations and costs incurred in connection with obtaining Site access EPA may submit to the Respondent on a periodic basis an accounting of all response costs incurred by the United States with respect to this Order EPAIS certified Agency (Integrated) Financial Management System summary data or such other summary as certified by EPA shall serve as basis for payment demands

118 Respondent shall within thirty (30) days of receipt of each EPA accounting remit a certified or cashiers check for the amount of those costs Interest shall accrue from the later of

24

the date that payment of a specified amount is demanded in writing or the date of the expenditure The interest rate is the rate established by the Department of the Treasury pursuant to 31 USC sect 3717 and 4 CFR sect10213

119 Checks shall be made payable to the Hazardous Substances Superfund and shall include the name of the Site the Site identification number the account number and the title of this Order Checks shall be forwarded to

US Environmental Protection Agency Superfund Accounting

PO Box360197M Pittsburgh PA 15251

120 Respondent shall send copies of each transmittal letter and check to the EPAs RPM

XXV ENFORCEMENT AND RESERVATIONS

121 EPA reserves the right to bring an action against Respondent under section 107 of CERCLA 42 USC 9607 for recovery of any response costs incurred by the United States related to this Order or the Site and not reimbursed by Respondent This reservation shall include but not be limited to past costs direct costs enforcement costs indirect costs the costs of oversight the costs of compiling the cost documentation to support oversight cost demand as well as accrued interest as provided in section 107(a) of CERCLA

122 Notwithstanding any other provision of this Order at any time during the response action EPA may perform its own studies complete the response action (or any portion of the response action) as provided in CERCLA and the NCP and seek reimbursement from Respondent for its costs or seek any other appropriate relief

123 Nothing in this Order shall preclude EPA from taking any additional enforcement actions including modification of this Order or issuance of additional Orders andor additional remedial or removal actions as EPA may deem necessary (including without limitation the remedy provided for in the ROD) or from requiring Respondent in the future to perform additional activity pursuant to CERCLA 42 USC 9606(a) et seq or any other applicable law Respondent shall be liable under CERCLA section 107(a) 42 USC 9607(a) for the costs of any such additional actions

124 Notwithstanding any provision of this Order the United States hereby retains all of its information gathering inspection and enforcement authorities and rights under CERCLA RCRA and any other applicable statutes or regulations

125 Respondent shall be subject to civil penalties under section 106(b) of CERCLA 42 USC 9606(b) of not more than $32500 for each day in which Respondent willfully violates

25

or fails or refuses to comply with this Order without sufficient cause In addition failure to properly provide responses or action under this Order or any portion hereof without sufficient cause may result in liability under section 107(c)(3) of CERCLA 42 USC 9607(c)(3) for punitive damages in an amount at least equal to and not more than three times the amount of any costs incurred by the Fund as a result of such failure to take proper action

126 Nothing in this Order shall constitute or be construed as a release from any claim cause of action or demand in law or equity against any person for any liability it may have arising out of or relating in any way to the Site

XXVI NO RELEASE OF LIABILITY

127 Nothing herein shall constitute or be construed as a satisfaction or release of any person from liability for any conditions or claims arising as a result of past current or future activities at the Site including but not limited to any and all claims of the United States for response costs money damages and interest under Section 107(a) of CERCLA 42 USC sect 9607(a) or any other applicable statute or the common law

128 Notwithstanding compliance with the terms of this Order the Respondent may be required to take such further actions as may be necessary to protect public health or welfare or the environment or as may be otherwise necessary or appropriate under applicable provisions of the law This Order requires performance of only a portion of the Site remedy provided for in the ROD Nothing in this Order shall be deemed to be full performance of the remedial actions set forth in the ROD

XXVII NO PREAUTHORIZATION

129 Nothing in this Order shall constitute or be construed as preauthorization of a CERCLA claim within the meaning of CERCLA sect111 42 USC sect 9611 or Section 300700(d) of the NCP 40 CFR sect300700(d)

XXVIII ADMINISTRATIVE RECORD

130 Upon request by EPA Respondent shall submit to EPA all documents related to the performance of the response action for possible inclusion in the administrative record file The administrative record index for this Order is attached as Appendix 2

XXIX EFFECTIVE DATE AND COMPUTATION OF TIME

131 This Order shall be effective on the date that the Order is signed by the Director of the Office of Site Remediation and Restoration All times for performance of obligations under this Order shall be calculated from that effective date unless the Order (including the SOW) specifies otherwise The Order issued in this matter dated June 27 2007 is withdrawn and this

26

Order supersedes the Order dated June 27 2007

XXX OPPORTUNITY TO CONFER

132 A conference regarding this Order has already occurred and this Order is being issued after and as a result of that conference

XXXI SEVERABILITY

135 If any provisionauthority of this Order or the application of this Order to any party or circumstance is held invalid by any judicial or administrative authority the application of such provision(s) to other parties or circumstances and the remainder of the Order shall remain in force and shall not be affected thereby

XXXII UNITED STATES NOT LIABLE

136 The United States by issuance of this Order assumes no liability for any injuries or damages to persons or property resulting from acts or omissions by Respondent or its directors officers employees agents representatives successors assigns contractors or consultants in carrying out any action or activity pursuant to this Order Neither EPA nor the United States may be deemed to be a party to any contract entered into by Respondent or its directors officers employees agents successors assigns contractors or consultants in carrying out any action or activity pursuant to this Order

So Ordered this^lkday tof V^y 2007 ~

amp_ fc faies T Owens III Director )ffice of Site Remediation and Restoration

US Environmental Protection Agency Region I

27

APPENDIX 1 TO UNILATERAL ADMINISTRATIVE ORDER

STATEMENT OF WORK FOR REMEDIAL DESIGN SAMPLING AND VAPOR INTRUSION REMEDIAL ACTION

AT THE DURHAM MANUFACTURING COMPANY STUDY AREA DURHAM MEADOWS SUPERFUND SITE

I INTRODUCTION AND PURPOSE

This Statement of Work (SOW) defines the response activities and deliverable obligations that the Respondent is obligated to perform in order to implement the Work required under the Unilateral Administrative Order (Order) for the Durham Manufacturing Company property at the Durham Meadows Superfund Site in Durham Connecticut The activities described in this SOW are based upon the United States Environmental Protection Agency (EPA) Record of Decision (ROD) signed by the Director of the Office of Site Remediation and Restoration New England Region on September 30 2005 and the administrative record for the UAO

II DEFINITIONS

The Site shall mean the definition of Site as provided in Section II of the Order Other definitions provided in the Order are incorporated herein by reference In addition the following definitions shall apply to this SOW

A The Durham Manufacturing Company Study Area or DMC Study Area shall mean the property on which the Durham Manufacturing Company (DMC) facility is currently located at 201 Main Street Town of Durham Connecticut and any contiguous areas of soil andor overburden groundwater contamination as generally depicted in Exhibit 1

B EPA shall mean the United States Environmental Protection Agency

C CT DEP shall mean the Connecticut Department of Environmental Protection

D Respondent shall mean the Durham Manufacturing Company

E Respondents Certification shall mean the following statement To the best of my knowledge after thorough investigation I certify that the information contained in or accompanying this submission is true accurate and complete I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment for knowing violations

Statement of Work for DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007 Durham Connecticut of 30

F The ROD shall mean the Record of Decision for the Site issued on September 30 2005

G CT RSR PMCs and DECs shall mean the Connecticut Remediation Standard Regulations Pollutant Mobility Criteria for GAGAA groundwater classification areas and the IndustrialCommercial Direct Exposure Criteria

H The Eastern Area shall mean the potential source area at the DMC Study Area that includes the former leach field and areas east of the former leach field (as shown generally on Exhibit 1)

I The WS-20 Area shall mean the proposed soil excavation area at the DMC Study Area that is located to the east of the main building (as shown generally on Exhibit 1) generally centered around well WS-20

J The Northwest Corner Area shall mean the proposed soil excavation area at the DMC Study Area that is located generally near the northwest corner of the main manufacturing building at the westerly end of the DMC Study Area (as shown generally on Exhibit 1)

III SELECTED REMEDY

The ROD describes the remedy for the Site For the DMC Study Area specifically the ROD provides for soil excavation and off-site disposal of hot spot areas in order to address risks to human health from contamination in overburden (shallow) groundwater and to address source contamination Institutional controls primarily in the form of Environmental Land Use Restrictions (ELURs) as defined in the CT Remediation Standard Regulations (RSRs) andor by local ordinance will also be required to prevent unrestricted future use or use of contaminated groundwater EPA has selected other remedies for other portions of the Site

Components of the remedy to be performed by the Respondent pursuant to the Order and this SOW include Remedial Design Sampling of soil and groundwater at the DMC Study Area to more fully define the lateral and vertical extent of soil contamination and the installation of a sub-slab system to depressurize the area under the entire foundation of the main manufacturing building at the DMC Study Area

Sections IV and V discuss the Performance Standards and Sampling Plan for Remedial Design Sampling activities at the DMC Study Area Sections VI and VII discuss the Performance Standards and Plans to address activities related to the installation of a sub-

Statement of Work for DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007 Durham Connecticut Page 2 of 30

slab depressurization system for the main manufacturing building at the DMC Study Area

IV PERFORMANCE STANDARDS for REMEDIAL DESIGN SAMPLING

This section defines the Performance Standards for Remedial Design Sampling at the DMC Study Area

The Respondent shall conduct Remedial Design Sampling in order to provide all information required to design construct operate monitor and maintain the remedy at the DMC Study Area in compliance with Section L of the ROD all applicable or relevant and appropriate (ARAR) standards cited in the ROD and all Performance Standards for the components of the DMC Study Area remedy Remedial Design Sampling activities include sampling of groundwater and soil analysis and validation of data and tabulation and evaluation of data The Respondent shall comply with all requirements of the Order and this SOW

The DMC Study Area remedy addresses contamination in overburden (shallow) groundwater at the DMC Study Area through soil excavation as described in the ROD The focus of this remedy is removing the Volatile Organic Compounds (VOCs) and possible Dense Non-Aqueous Phase Liquid (DNAPL) contamination in the overburden soils that are likely acting as continual sources of groundwater contamination These sources are located at the degreasing and former solvent storage area at the Northwest Corner Area the WS-20 Area and potentially in the Eastern Area

The Respondent shall conduct groundwater and soil sampling to determine the extent of groundwater hot spots and the extent of soil contamination acting as a source to ongoing groundwater contamination Groundwater hot spots are considered those areas demonstrating high concentrations of VOCs and the likely presence of DNAPL Initial investigations shall focus around the Northwest Corner Area the WS-20 Area and the Eastern Area

The Respondent shall collect data that supports remedial activities and allows for the design of a soil excavation remedy that (i) removes source areas to the maximum extent practicable (with the goal of meeting Interim Cleanup Levels for groundwater in the DMC Study Area as outlined in Table 42 of the ROD) and (ii) removes any soils exceeding CT RSR PMCs and DECs The Respondent shall conduct groundwater and soil sampling work reasonably concurrently The Respondent shall perform groundwater sampling to determine the extent of groundwater hot spots and provide information required to develop a post-remedial long-term groundwater monitoring plan The Respondent shall perform soil sampling to fully define the vertical and lateral extent of


soil with VOCs in excess of the CT RSR PMCs and DECs as well as to determine the extent of soil which if removed would be considered RCRA listed waste whether any soil contains RCRA characteristic waste based on TCLP analysis and potentially applicable disposal requirements and limitations such as RCRA land disposal restrictions

A General Requirements

Prior to implementation of any on-site field work the Respondent shall submit to EPA for its approval a field schedule that allows for EPA andor CT DEP oversight and split sampling

The Respondent shall conduct a survey of all sampling locations

The Respondent shall determine whether acquisition of access to neighboring properties is needed and take steps to acquire such access as necessary Initially access to the property located north of DMCs main manufacturing building will be required the Respondent shall make best efforts to obtain access and notify EPA immediately if access is denied

The Respondent shall determine the placement of utilities in areas to be sampled or where monitoring wells will be installed and take the appropriate steps to ensure the safety of the field team and on-site DMC workers The Respondent shall ensure that utilities are not disrupted during field sampling by creating andor updating a utility map prior to the start of any field work

To the extent that the Respondent generates investigation-derived waste the Respondent shall characterize and dispose of such waste in accordance with local State and Federal regulations Prior to any off-site transport of waste facilities selected for off-site disposal must be deemed acceptable by EPA as required pursuant to 40 CFR 300440

The Respondent shall provide copies of all raw data field notes boring logs detection limits data validation information or any other data collected to EPA and CT DEP

B Groundwater Sampling

The Respondent shall inspect all existing overburden groundwater monitoring wells within the DMC Study Area in order to determine whether they are in a condition adequate to perform low-flow groundwater sampling The Respondent


shall replace any unusable existing groundwater monitoring well with a new well located reasonably close to such unusable existing well The Respondent shall submit their evaluation of the viability of existing wells construction details of any unusable existing wells and the approximate location and construction details of any replacement wells to EPA for review and approval EPA approval shall be required prior to the Respondent sampling any existing or replacement groundwater monitoring wells or installing any replacement wells

In addition to replacing any unusable existing wells five groundwater wells shall be required to investigate the Eastern Area EPA in conjunction with CT DEP shall determine the exact location of the required groundwater wells in the Eastern Area

The Respondent shall conduct all new or replacement well installation in a manner that ensures continuous soil samples can be collected for screening during drilling (such as with direct push technology or a hollow stem auger) and where appropriate sampled During well installation soil shall be visually examined for evidence of DNAPL If DNAPL is visible in soil the Respondent shall conduct dye testing on the affected soil (using Sudan IV or similar dye) The Respondent shall also perform continuous screening of soil samples using a photoionization detector (PID) During screening the soil will be split open and the PID probe placed in the opening and covered with a gloved hand Any specific soil interval that indicates a PIC reading gt100 parts per million total detectible organic vapors will undergo further dye testing (using Sudan IV or similar dye)

Upon EPA approval the Respondent shall conduct groundwater sampling of the usable existing wells the replacement wells and the five new wells in the Eastern Area in a single sampling event

Groundwater sampling shall be conducted using low flow sampling techniques as described in EPA Region I Low Stress (low flow) Purging and Sampling Procedure for the Collection of Ground Water Samples from Monitoring Wells dated July 30 1996 Groundwater samples shall be analyzed for VOCs by EPA method 5242 or SW-846 method 8620 All groundwater sampling results shall be validated pursuant to Attachment A

During groundwater sampling the Respondent shall visually observe for the presence of DNAPL Dye testing (using Sudan IV or similar dye) or screening of the wells with an interface probe shall be performed where DNAPL is visually observed in groundwater (The absence of DNAPL observations or negative test results however does not rule out the presence of DNAPL)

Statement of Work for DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007

pa9e 5 of 30 Durham Connecticut

Additional investigation including additional soil sampling in the Eastern Area may be required after reviewing data from groundwater well sampling

C Soil Sampling

Substantially concurrent with groundwater sampling Respondent shall conduct soil borings and soil sampling on a grid pattern at the Northwest Corner Area and the WS-20 Area to define the extent of soil contamination exceeding the CT RSR PMCs and DECs As stated above additional soil sampling in the Eastern Area may be required after reviewing data from groundwater well sampling

The Respondent shall collect soil samples in a grid pattern Soil samples shall continue outwards as defined below in all directions (both laterally and vertically) until samples do not exceed CT RSR PMCs and DECs or until a building foundation is encountered If samples from the final row of the grid areas defined below exceed either CT RSR PMCs or DECs additional soil sampling shall be required unless a building foundation is encountered The Respondent shall submit the proposed grid and locations of soil borings and soil sampling to EPA for review and approval EPA approval shall be required prior to the Respondent implementing soil boring and soil sampling activities

At the Northwest Corner Area the Respondent shall collect samples in a grid The initial round of soil sampling shall include three rows of borings The first row of samples shall start five feet from the outer northern wall of the building The row shall contain five or six sampling locations spaced 30 feet apart the number of sampling locations in each row should be determined based on past data allowing a buffer zone to ensure the lateral edges of the contaminated zone to the east and west are fully defined The row shall begin at approximately the western edge of the building and extend at least 150 feet to the east The row shall be repeated northward every 15 feet subject to obtaining access from abutters (The second row shall be 20 feet from the building wall and the third row shall be 35 feet from the building wall) The borings shall extend to the east and west as necessary to define the lateral extent of exceedances of the CT RSR PMCs and DECs

At the WS-20 Area the Respondent shall advance radial soil borings centered around well WS-20 with radial spokes extending in the four compass directions Samples shall be taken in 10 foot intervals with the first iteration being four borings and the successive iterations being eight borings with iterations spaced 10 feet apart The initial round of soil sampling shall include


both rings (the inner ring 10 feet removed from WS-20 with four borings and the outer ring 20 feet removed from WS-20 with eight borings)

At each boring location the Respondent shall collect three to four samples The Respondent shall determine sample depths by where higher VOC concentrations may be anticipated at the interface between the fill and the ablation till at the interface between the ablation till and the till at the water table and just above the bedrock surface (EPA Remedial Investigation Figures 34-2 and 34-3 indicate that the fill layer is typically two feet deep the ablation till varies from approximately three to eight feet in depth and till is on the order of 10 foot depth The water table depth is approximately 10 feet and bedrock depth approximately

20 feet) Where the ablation tilltill interface is close to the water table separate samples may not be required and three samples per boring location may be sufficient Observation and field screening of sample cores indicating soil with staining or high levels of VOCs may take precedence in selecting sample collection depth locations as described above

The Respondent may elect to conduct one additional round of Remedial Design sampling to more accurately delineate soil exceeding the CT RSR PMCs and DECs as long as such sampling does not delay the remedial action The Respondent shall propose the additional round of sampling to EPA and CT DEP The Respondent shall not conduct an additional round of sampling without receiving EPA approval

Respondent may also elect to collect concurrent samples during work being performed under this SOW provided such samples are analyzed within the appropriate holding times and otherwise comply with this SOW Any concurrent samples collected during the sampling planned as part of this SOW shall not require EPA approval but Respondent shall provide written notice of such sampling at least three days after such sampling occurs

Any additional or concurrent sampling shall be tighter (ie within an area between a sampling location meeting the CT RSR PMCs and DECs and another sampling location not meeting such soil standards) and no closer than five feet outward from a soil sample location not meeting the CT RSR PMCs or DECs Sampling depths intervals and protocols shall be similar to those required by this SOW The Respondent shall provide the results of all data to EPA and CT DEP

The Respondent shall advance all soil borings using direct-push techniques The Respondent shall visually observe the soil for the presence of DNAPL and perform continuous screening of soil samples and dye testing as necessary as


described in Section IVB Respondent shall use standard EPA Region I QAQC and data validation procedures as well as CT DEPs Guidance for Collecting and Preserving Soil and Sediment Samples for Laboratory Determination of Volatile Organic Compounds dated February 28 2006 The Respondent shall provide copies of all raw data field notes boring logs detection limits and data validation information to EPA and CT DEP

The Respondent shall analyze each soil sample for VOCs using EPA SW-846 8260

The Respondent shall have the option to perform laboratory analysis of soil samples iteratively so long as all samples are analyzed within the prescribed 14 day holding time and standard EPA Region I QAQC and data validation procedures are met For the WS-20 area the inner ring samples shall be analyzed first results would then determine which samples obtained from the second ring of borings if any need to be analyzed based upon a comparison to the CT RSR PMCs and DECs Similarly for the main manufacturing building area samples obtained from the first row near the building shall be analyzed first Results will dictate which samples from the second row if any should be analyzed based upon a comparison to the CT RSR PMCs and DECs In the same manner results of the second row samples shall determine which samples from the third row of borings if any will need to be analyzed

The Respondent may determine compliance with CT RSR PMCs through SPLP or TCLP analysis

Based on the results of the soil VOC analysis if Respondent so elects the Respondent shall submit a plan for the collection of additional soil samples for laboratory analysis for disposal parameters (TCLP metals pH flashpoint reactive cyanide reactive sulfide [EPA SW-846 methods]) from a subset of the soil borings

V REMEDIAL DESIGN SAMPLING PLAN

As described in this SOW the Respondent shall develop a final Remedial Design Sampling Plan for the remedy for the DMC Study area that meets the Performance Standards specified in Section IV of this SOW Section VA describes the Respondents responsibilities for selecting a contractor Section VB describes the Respondents responsibilities for submitting deliverables during Remedial Design Sampling activities Section VC describes the Respondents responsibilities for conducting Remedial Design Sampling Project Meetings


A Contractor Selection

All work performed by the Respondent pursuant to the Order and this SOW shall be carried out under the oversight of a qualified Supervising Contractor and Project Coordinator the selection of which shall be subject to disapproval by EPA Within ten (10) days after the effective date of the Order the Respondent shall notify EPA in writing of the names and qualifications of the Supervising Contractor and the Project Coordinator they propose to use in carrying out all work required under this section of the SOW If EPA disapproves the Supervising Contractor or the Project Coordinator it shall so notify the Respondent and Respondent shall submit the name and qualifications of another Supervising Contractor or Project Coordinator

B Deliverables

The Respondent shall submit to EPA and CT DEP the required deliverables as stated herein for each of the Remedial Design Sampling activities Except where expressly stated otherwise in this SOW each deliverable shall be subject to review and approval or modification or disapproval by EPA in accordance with Section XV of the Order

1 Progress Reports

On the 1 Oth working day of every month beginning in the month EPA approves the Supervising Contractor and until completion of all work required pursuant to the Order and this SOW the Respondent shall submit Progress Reports to the EPA and CT DEP in accordance with Section XVI of the Order The reports shall summarize all activities that have been conducted in the preceding month and activities planned for the next month The Progress Reports shall also identify any significant problems encountered andor changes to the schedule and shall summarize all the results of sampling and tests and all other data received by the Respondent within the relevant month

2 Remedial Design Sampling Workplan

Statement of Work for DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007 Durham Connecticut shy Page 9 of 30

Within 30 days after EPA approval of the Supervising Contractor the Respondent shall submit a Remedial Design Sampling Workplan with Respondents certification

The Remedial Design Sampling Workplan shall include

1 a detailed description of all activities to be undertaken in connection with the Remedial Design Sampling a statement of the purpose and objectives of each activity and an identification of the specific activities necessary to complete each activity

2 a proposed schedule for completion of all Remedial Design Sampling activities and deliverables and

3 a Remedial Design Sampling Project Operations Plan (POP) for any fieldwork to support investigations to take place during Remedial Design Sampling The Remedial Design Sampling POP shall be prepared in accordance with Attachment A of this SOW and shall include at a minimum

A Site Management Plan (SMP)

B Sampling and Analysis Plan (SAP) which includes

1) Quality Assurance Project Plan (QAPP) and

2) Field Sampling Plan (FSP) and

C Site-specific Health and Safety Plan (HSP)

The Respondent shall include proposed schedules in the Remedial Design Workplan for conducting the sampling work with review and approval by EPA

Within 30 days after the Respondent receives EPA approval or modification of the Remedial Design Sampling Workplan and POP the Respondent shall initiate the sampling activities in accordance with the Remedial Design Sampling Workplan and the schedules set forth therein

The Remedial Design Sampling Workplan and POP shall be consistent with Section L of the ROD this SOW and all EPA guidance then in effect


3 Draft Remedial Design Sampling Report

Within 30 days of the conclusion of all Remedial Design Sampling activities the Respondent shall submit to EPA and CT DEP a Draft Remedial Design Sampling Report for review and approval or modification by EPA The Draft Remedial Design Sampling Report shall include at a minimum the results of all field investigations

In the Draft Remedial Design Sampling Report the Respondent shall also estimate the volume of soil exceeding the CT RSR PMCs or DECs

4 bull Final Remedial Design Sampling Report

Within 30 days of receiving EPAs approval or modification of the Draft Remedial Design Sampling Report the Respondent shall submit a Final Remedial Design Sampling Report incorporating all revisions required by EPA EPA may at its sole discretion determine that a Final version of the report is not required

C Remedial Design Sampling Project Meetings

The Respondent and their Supervising Contractor shall meet with EPA and CT DEP prior to the start of field work to discuss the status of the Remedial Design Sampling Plan and the anticipated schedule for field work and to discuss any potential issues associated with the field work Subsequent meetings shall occur on a schedule approved by EPA or at the request of EPA The Respondent shall immediately notify EPA of any issues that arise during field work such as unusual events or deviations from the SOW or Remedial Design Sampling Workplan that may require a meeting

VI PERFORMANCE STANDARDS for REMEDIAL DESIGN AND REMEDIAL ACTION ACTIVITIES TO ADDRESS POTENTIAL VAPOR INTRUSION RISKS

This section defines the performance standards for Remedial Design and Remedial Action activities required to address potential vapor intrusion risks at the DMC Study Area specifically the installation of a sub-slabsystem (SSDS) to depressurize the area under the entire foundation of the main manufacturing building at the DMC Study Area (hereafter referenced as the Structure indicated on Exhibit 1 as the Main Manufacturing Building)


Prior to implementation of any on-site field work the Respondent shall submit to EPA for its approval a field schedule that allows for EPA andor CT DEP oversight

To the extent that the Respondent generates investigation-derived waste during performance of any field work the Respondent shall characterize and dispose of such waste in accordance with local State and Federal regulations Prior to any off-site transport of waste facilities selected for off-site disposal must be deemed acceptable by EPA as required pursuant to 40 CFR 300440

The Respondent shall provide copies of all raw data field notes boring logs detection limits data validation information pilot test data and results or any other data collected to EPA and CT DEP

The Respondent shall conduct Remedial Design and Remedial Action activities necessary to design construct operate monitor and maintain the SSDS in compliance with Section L of the ROD all applicable or relevant and appropriate (ARAR) standards cited in the ROD and all Performance Standards for the components of the DMC Study Area

The Respondent shall achieve generally accepted performance standards for sub-slab depressurization systems including

bull the SSDS shall be designed and installed in a manner that shall achieve and maintain an adequate negative pressure field under the entire foundation of the Structure

bull all materials and techniques shall comply with or exceed industry standards andor normal practices and

bull all work must be conducted in compliance with all applicable mechanical electrical building plumbing energy and fire prevention codes

In designing the SSDS the Respondent shall also review and evaluate the following references and incorporate relevant aspects consistent with this SOW

bull ASTM E 2121 -03 Standard Practice for Installing Radon Mitigation Systems in Existing Low-Rise Residential Buildings or more recent revisions to this standard as appropriate

bull EPA Radon Reduction Techniques for Existing Detached Houses Technical Guidance (Third Edition) for Active Soil Depressurization Systems EPA625Rshy93011 dated October 1993

bull EPA Handbook Sub-Slab Depressurization for Low-Permeability Fill Material Design amp Installation of a Home Radon Reduction System EPA6256-91029 dated July 1991


The Respondent shall develop a Pre-Design SSDS Plan for Investigation and Pilot Testing (Pre-Design SSDS Plan) for the collection of information required to properly design the SSDS The Pre-Design SSDS Plan shall include a proposal for baseline monitoring of differential pressure to account for reasonably anticipated worst-case and seasonal conditions and shall include pilot tests as necessary to assess sub-slab communication and potential blocked areas

As part of the Pre-Design SSDS Plan the Respondent shall determine the necessary structural improvements and other preparatory activities necessary for the Structure (Such structural improvements may include but not be limited to sealing of cracks in slabs walls andor at the slabwall interface addressing earthen floor areas sealing of sumps and annular spaces around utility pipes and modification of floor drains as necessary)

As part of the Pre-Design SSDS Plan the Respondent shall also determine the placement of utilities (including feed lines or other sub-slab installations) in areas requiring investigation andor where SSDS installation activities may occur and take the appropriate steps to ensure the safety of the field team and on-site DMC workers The Respondent shall ensure that utilities are not disrupted during field sampling by creating andor updating a utility map prior to the start of any field work EPA approval shall be required prior to the Respondent performing any activities pursuant to the Pre-Design SSDS Plan

Upon completion of activities required in the Pre-Design SSDS Plan the Respondent shall develop a Remedial Design for the SSDS (SSDS RD) to include a Remedial Action plan for construction implementation and testing of the SSDS and an Operation and Maintenance (OampM) Plan for the SSDS

The Respondent shall customize an appropriate SSDS as part of the SSDS RD This effort includes determining the exact number and location of suction points as well as the location of support infrastructure including vent piping and the fan(s) and determining adequate power supply and alarm system elements

Upon approval of a Final SSDS RD by EPA the Respondent shall install the SSDS consistent with this SOW

The Respondent shall pressure test the SSDS and shall conduct any necessary changes or improvements to the system until the SSDS achieves and maintains an adequate negative pressure field under the entire foundation of the Structure The Respondent shall certify to EPA when it deems the system to be operational and functional


The Respondent shall conduct all necessary operation and maintenance of the SSDS required to maintain the effectiveness of the SSDS pursuant to the OampM Plan OampM activities shall include but not be limited to periodic inspections of the SSDS periodic pressure testing of the SSDS repair or replacement of fans and piping as necessary condensate management for piping and repair of cracks in the Structures slab as necessary

Further investigation and remediation of potential vapor intrusion risks may be required in other areas on the DMC Study Area pending results of soil and groundwater sampling (at the secondary building on the DMC property for example)

VII PLANS for REMEDIAL DESIGN AND REMEDIAL ACTION ACTIVITIES TO ADDRESS POTENTIAL VAPOR INTRUSION RISKS

The Respondent shall develop all plans required for Remedial Design and Remedial Action (RDRA) activities required to address potential vapor intrusion risks at the DMC Study Area specifically the design and installation of a SSDS that meets the Performance Standards specified in Section VI of this SOW Section VILA describes the Respondents responsibilities for selecting a contractor Section VIIB describes the Respondents responsibilities for submitting deliverables during all RDRA activities required to address potential vapor intrusion risks Section VIIC describes the Respondents responsibilities for conducting Project Meetings related to RDRA activities required to address potential vapor intrusion risks



Alternatively the Respondent may designate the same Supervising Contractor and Project Coordinators as provided under Section VA of this SOW

B Deliverables


The Respondent shall submit to EPA and CT DEP the required deliverables as stated herein for each of the RDRA activities Except where expressly stated otherwise in this SOW each deliverable shall be subject to review and approval or modification or disapproval by EPA in accordance with Section XV of the Order

1 Progress Reports

On the 10th working day of every month beginning in the month EPA approves the Supervising Contractor and until completion of all work required pursuant to the Order and this SOW the Respondent shall submit Progress Reports to the EPA and CT DEP in accordance with Section XVI of the Order The reports shall summarize all activities that have been conducted in the preceding month and activities planned for the next month The Progress Reports shall also identify any problems encountered andor changes to the schedule and shall summarize all the results of sampling and tests and all other data received by the Respondent

The Respondent may combine Progress Reports required under this section with the Progress Reports required under section VB

2 Pre-Design Sub-Slab Depressurization System Plan for Investigation and Pilot Testing

Within 30 days after EPA approval of the Supervising Contractor the Respondent shall submit a Pre-Design SSDS Plan for Investigation and Pilot Testing (Pre-Design SSDS Plan) with Respondents certification

The Pre-Design SSDS Plan shall include

1 a detailed description of all activities to be undertaken in connection with the Pre-Design SSDS Investigation and Pilot Testing a statement of the purpose and objectives of each activity and an identification of the specific activities necessary to complete each activity

2 a proposed schedule for completion of all Pre-Design SSDS activities and deliverables and

3 a Pre-Design SSDS Project Operations Plan (POP) for any fieldwork to support investigations to take place during Pre-Design Sampling The Pre-Design Sampling POP shall be prepared in


accordance with Attachment A of this SOW and shall include at a minimum

A Site Management Plan (SMP) and

B Site-specific Health and Safety Plan (HSP)

The Respondent may amend the SMP and HSP required under section VB to address the requirements of this section

The Respondent shall include proposed schedules in the Pre-Design SSDS Plan for conducting the investigative and pilot test work with review and approval by EPA

Within 30 days after the Respondent receives EPA approval or modification of the Pre-Design SSDS Plan and POP the Respondent shall initiate the activities in accordance with the Pre-Design SSDS Plan and the schedules set forth therein

The Pre-Design SSDS Plan and POP shall be consistent with Section L of the ROD this SOW and all EPA guidance then in effect

3 Draft Remedial Design for the SSDS Remedial Action Plan and Operation amp Maintenance Plan

Within 30 days of the conclusion of all Pre-Design SSDS activities the Respondent shall submit to EPA and CT DEP a Draft Remedial Design (RD) SSDS for review and approval or modification by EPA The Draft SSDS RD shall include at a minimum the results of all SSDS investigations and pilot tests The SSDS RD shall also include a Remedial Action (RA) Plan for construction implementation and testing of the SSDS and an Operation and Maintenance (OampM) Plan for the SSDS

The Respondent shall amend the POP elements required under section VIIB2 as necessary to address the requirements of this section

The Respondent shall include proposed schedules in the SSDS RD RA and OampM Plans for constructing implementing and testing the SSDS and implementing the OampM Plan with review and approval by EPA


4 Final SSDS Remedial Design Remedial Action Plan and Operation amp Maintenance Plan

Within 30 days of receiving EPAs approval or modification of the Draft SSDS RD RA and OampM Plans the Respondent shall submit Final SSDS RD RA and OampM Plans that incorporate all revisions required by EPA EPA may at its sole discretion determine that Final versions of the plans are not required

Within 30 days after the Respondent receives EPA approval or modification of the Final SSDS RD RA and OampM Plans the Respondent shall initiate the activities in accordance with the SSDS RD RA and OampM Plans and the schedules set forth therein

The SSDS RD RA and OampM Plans and POP shall be consistent with Section L of the ROD this SOW and all EPA guidance then in effect

C SSDS Project Meetings

The Respondent and their Supervising Contractor shall meet with EPA and CT DEP prior to the start of field work to discuss the status of the Pre-Design SSDS Plan and the anticipated schedule for field work and to discuss any potential significant issues associated with the field work The Respondent and their Supervising Contractor shall also meet with EPA and CT DEP prior to the start of SSDS construction to discuss the anticipated schedule for construction activities and to discuss any potential issues associated with these activities Subsequent or other additional meetings shall occur on a schedule approved by EPA or at the request of EPA The Respondent shall notify EPA of any significant issues that arise during field work or construction work that may require a meeting

VIII SUBMISSIONS REQUIRING AGENCY APPROVAL

A All plans deliverables and reports identified in the SOW for submittal to EPA and the CT DEP shall be delivered to EPA and CT DEP in accordance with the Order and this SOW

B Any plan deliverable or report submitted to EPA for approval shall be printed using two-sided printing and marked Draft on each page and shall include in a prominent location in the document the following disclaimer Disclaimer This document is a DRAFT document prepared by the Respondent under a government UAO This document has not undergone formal review by the EPA The

Statement of Workfor DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007 Durham Connecticut Page 17 of 30

opinions findings and conclusions expressed are those of the author and not those of the US Environmental Protection Agency and the Connecticut Department of Environmental Protection

C Approval of a plan deliverable or report does not constitute approval of any model or assumption used by the Respondent in such plan deliverable or report


ATTACHMENTA PROJECT OPERATIONS PLAN

Before any field activities commence the Respondent shall submit several site-specific plans to establish procedures to be followed by the Respondent in performing field laboratory and analysis work These site-specific plans include the

A Site Management Plan (SMP) B Sampling and Analysis Plan (SAP) and C Health and Safety Plan (HSP)

These plans shall be combined to form the Project Operations Plan (POP) The components of the POP are described in A through C herein

The format and scope of each Plan shall be modified as needed to describe the sampling analyses and other activities that are clarified as the work progresses EPA may modify the scopes of these activities at any time during work performed pursuant to this SOW at the discretion of EPA in response to the evaluation of sampling results changes in sampling requirements and other developments or circumstances


The Site Management Plan (SMP) shall describe how the Respondent will manage the project to complete the Work required at the Site The overall objective of the Site Management Plan is to provide EPA and CT DEP with a written understanding and commitment of how various project aspects such as access security contingency procedures management responsibilities waste disposal budgeting and data handling are being managed by the Respondent Specific objectives and provisions of the Site Management Plan shall include but are not limited to the following

1 Provide a map and a list of properties the property owners and addresses of owners to whose property access may be required

2 Establish necessary procedures to delineate sampling areas and activities and ensure safety of DMC workers

3 Establish necessary procedures and provide sample letters to land owners to arrange field activities and to ensure EPA and CT DEP are informed of access-related problems and issues

4 Provide for the security of government and private property on the Site


5 Prevent unauthorized entry to the Site which might result in exposure of persons to potentially hazardous conditions

6 Secure access agreements for all properties where field work is required

7 Communicate to EPA CT DEP and the public the organization and management of all work activities including key personnel and their responsibilities

8 Provide a list of contractors and subcontractors of the Respondent for all work required under this SOW and a description of their activities and roles

9 Provide for the proper disposal of materials used and wastes generated during all work activities (eg drill cutting extracted groundwater protective clothing disposable equipment) These provisions shall be consistent with the off-site disposal aspects of SARA RCRA and applicable state laws The Respondent or its authorized representative or another party acceptable to EPA shall be identified as the generator of wastes for the purpose of regulatory or policy compliance

10 Provide plans and procedures for organizing and presenting the data generated and for verifying its quality before and during the Remedial Design Sampling activities These plans shall include a description of the computer database management systems that are compatible with hardware available to EPA Region I personnel for handling media-specific sampling results obtained before and during the Remedial Design Sampling activities The description shall include data input fields examples of data base management output from the coding of all Remedial Design Sampling data appropriate quality assurancequality control to ensure accuracy and capabilities of data manipulation To the degree possible the data base management parameters shall be compatible with the EPA Region I data storage and analysis system

B Sampling and Analysis Plan (SAP)

The Sampling and Analysis Plan (SAP) shall consist of both (1) a Quality Assurance Project Plan (QAPP) that describes the policy organization functional activities and the quality assurance and quality control protocols necessary to achieve the data quality objectives dictated by the intended use of the data and (2) the Field Sampling Plan (FSP)


that provides guidance for all fieldwork by defining in detail the sampling and data-gathering methods to be used on a project Components required by these two plans are described below

The SAP shall be the framework of all anticipated field activities (eg sampling objectives evaluation of existing data standard operating procedures) and contain specific information on all field work and analysis (eg sampling locations and rationale sample numbers and rationale analyses of samples) During the Remedial Design Sampling activities the SAP shall be revised as necessary to cover each round of field or laboratory activities Revisions or a statement regarding the need for revisions shall be included in each deliverable describing all new field work

The purpose of the SAP is to ensure that sampling data collection activities will be comparable to and compatible with previous data collection activities performed at the Site while providing a mechanism for planning and approving field activities The overall objectives of the two documents comprising the SAP are as follows

1 to document specific objectives procedures and rationales for fieldwork and sample analytical work

2 to provide a mechanism for planning and approving Site and laboratory activities

3 to ensure that sampling and analysis activities are necessary and sufficient and

4 to provide a common point of reference to ensure the comparability and compatibility of all objectives and the sampling and analysis activities

To achieve this last objective the SAP shall document all field and sampling and analysis objectives as noted above as well as all data quality objectives and specific proceduresprotocols for field sampling and analysis

The following critical elements of the SAP shall be described for each sample medium (eg ground water soil and soil vapor) and for each sampling event

1 sampling objectives (eg engineering related well yields zone of influence performance monitoring demonstration of attainment five year review etc)


2 data quality objectives including data uses and the rationale for the selection of analytical levels and detection limits (see Guidance on Systematic Planning using the Data Quality Objectives Process EPA QAG-4 (EPA240-B-06001) February 2006 Data Quality Objectives Decision Errors Feasibility Trials (DEFT) Software QAG-4D (EPA240B-01007 September 2001) and Final Guidance Data Usability in Risk Assessment (Part A) (publication 92857-09A April 1992 PB92shy963356) Guidance for Data Usability in Risk Assessment (Part B) (publication 92857-09B May 1992 PB92-963362)

3 site background update including an evaluation of the validity sufficiency and sensitivity of existing data

4 sampling locations and rationale

5 sampling procedures and rationale and references

6 numbers of samples and justification

7 numbers of field blanks trip blanks and duplicates

8 sample media (eg ground water surface water soil sediment air and buildings facilities and structures including surfaces structural materials and residues)

9 sample equipment containers minimum sample quantities sample preservation techniques maximum holding times

10 instrumentation and procedures for the calibration and use of portable air soil- or water-monitoring equipment to be used in the field

11 chemical and physical parameters in the analysis of each sample

12 chain-of-custody procedures must be clearly stated (see EPA NEIC Policies and Procedures Manual EPA 3309-78 001-R May 1978 revised May 1986)

13 procedures to eliminate cross-contamination of samples (such as dedicated equipment)


14 sample types including collection methods and if field and laboratory analyses will be conducted

15 laboratory analytical procedures equipment and detection limits

16 equipment decontamination procedures

17 consistency with the other parts of the Work Plan(s) by having identical objectives procedures and justification or by cross-reference

18 analysis from each medium of selected analytes as approved by EPA and

19 for any limited field investigation (field screening technique) provisions for the collection and laboratory analysis of parallel samples and for the quantitative correlation analysis in which screening results are compared with laboratory results

The SAP shall allow for notifying EPA at a minimum three weeks before field sampling or monitoring activities commence The SAP shall also allow split replicate or duplicate samples to be taken by EPA (or their contractor personnel) At the request of EPA the Respondent shall provide these samples in appropriately pre-cleaned containers to the government representatives Identical procedures shall be used to collect the Respondents and the parallel split samples unless otherwise specified by EPA Several references shall be used to develop the SAP for example

1 Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (OSWER Directive 93553-01 EPA540G-89004 October 1988)

2 Test Methods for Evaluating Solid Waste PhysicalChemical Methods (EPA Pub SW-846 Third Edition or most recent update)

3 EPA Requirements for Quality Assurance Plans OAR-5 fEPA240Bshy01003) March 2001

4 Region I EPA-New England Quality Assurance Project Plan Program Guidance April 2005

5 Guidance on Systematic Planning using the Data Quality Objectives Process EPA QAG-4 (EPA240-B-06001) February 2006


6 Data Quality Objectives Decision Errors Feasibility Trials (DEFT) Software QAG-4D (EPA240B-01-007) September 2001)

7 Systematic Planning A Case Study for Hazardous Waste Site Investigations EPA QACS-1 (EPA240B-06004) February 2006

8 Guidance for Preparing Standard Operating Procedures (SOPs) EPA QAG-6 (EPA600B-07001) April 2007

9 Region I EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses Revised December 1996

10 Data Quality Assessment A Reviewers Guide EPA OAG-9R (EPA240B-06002) Feb 2006

11 Data Quality Assessment Statistical Methods for Practitioners EPA QAG-9S (EPA240B-06003) Feb 2006

12 EPA Requirements for Quality Management Plans QAR-2 (EPA 240Bshy01002) March 2001 and

13 Guidance for Quality Assurance Project Plans QAG-5 (EPA240Rshy02009) December 2002

BI QUALITY ASSURANCE PROJECT PLAN (QAPP)

The Quality Assurance Project Plan (QAPP) shall document in writing the site-specific objectives policies organizations functional activities sampling and analysis activities and specific quality assurancequality control activities designed to achieve the data quality objectives (DQOs) of the Remedial Design Sampling activities The QAPP developed for this project shall document quality control and quality assurance policies procedures routines and specifications

Project activities throughout the Remedial Design Sampling activities shall comply with the QAPP QAPP sampling and analysis objectives and procedures shall be consistent with EPA Requirements for Quality Assurance Plans (QAR-5) and appropriate EPA handbooks manuals and guidelines including Guidance for Quality Assurance Project Plans QAG-5 (EPA240R-02009) December 2002 Region I EPA-New England Quality Assurance Project Plan Program Guidance April 2005 and Guidelines Establishing Test Procedures for the Analysis of Pollutants (40 CFR Part 136)


Compendium of Methods for the Determination of Toxic Organic Compounds in Ambient Air (EPA-6004-84-041 April 1984)

All the QAPP elements identified in EPA QAR-5 and EPA QAG-5 must be addressed

As indicated in EPA QAR-5 and EPA QAG-5 a list of essential elements must be considered in the QAPP for the Remedial Design Sampling activities If a particular element is not relevant to a project and therefore excluded from the QAPP specific and detailed reasons for exclusion must be provided

Information in a plan other than the QAPP may be cross-referenced clearly in the QAPP provided that all objectives procedures and rationales in the documents are consistent and the reference material fulfills requirements of EPA QAR-5 and EPA QAG-5 Examples of how this cross reference might be accomplished can be found in the Guidance for the Data Quality Objectives Process QAG-4 (EPA600R-96055) and the Data Quality Objectives decision Errors Feasibility Trials (DEFT) Software QAG-4D (EPA240B-01007) EPA-approved references or equivalent or alternative methods approved by EPA shall be used and their corresponding EPA-approved guidelines should be applied when they are available and applicable

Laboratory QAAC Procedures

The QAQC procedures and Standard Operating Procedures (SOPs) for any laboratory (both fixed and mobile) used during the Remedial Design Sampling activities shall be included in the Respondents QAPP When this work is performed by a contractor to a private party each laboratory performing chemical analyses shall meet the following requirements

1 be approved by the State Laboratory Evaluation Program if available

2 have successful performance in one of EPAs National Proficiency Sample Programs (ie Water Supply or Water Pollution Studies or the States proficiency sampling program)

3 be familiar with the requirements of 48 CFR Part 1546 contract requirements for quality assurance and

4 have a QAPP for the laboratory including all relevant analysis This plan shall be referenced as part of the contractors QAPP

Data Validation Procedures


The Respondent is required to certify that a representative portion of the data has been validated by a person independent of the laboratory according to the Region I EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses Revised December 1996 (amended as necessary to account for the differences between the approved analytical methods for the project and the current Contract Laboratory Program Statements of Work (CLP SOW)) A data validation reporting package as described in the guidelines cited above must be delivered at the request of the EPA project manager Approved validation methods shall be contained in the QAPP

The independent validator shall not be the laboratory conducting the analysis and should be a person with a working knowledge of or prior experience with EPA data validation procedures The independent validator shall certify that the data has been validated discrepancies have been resolved if possible and the appropriate qualifiers have been provided

Data Package Requirements

The Respondent must require and keep the complete data package and make it available to EPA on request in order for EPA to conduct an independent validation of the data The complete data package shall consist of all results the raw data and all relevant QAQC information The forms contained in the data validation functional guidelines must be utilized to report the data when applicable Raw data includes the associated chromatograms and the instrument printouts with area and height peak results The peaks in all standards and samples must be labeled The concentration of all standards analyzed with the amount injected must be included AH internal and external laboratory sample tracking information must be included in the data package An example data package deliverable is listed below

1 a summary of positive results and detection limits of non-detects with all raw data

2 tabulate surrogate recoveries and QC limits from methods 3500 and 8000 in SW-846 and all validation and sample raw data

3 tabulated matrix spikematrix spike duplicate recoveries relative percent differences spike concentrations and QC limits from methods 3500 and 8000 in SW-846 and all validation and sample raw data


4 associated blanks (trip equipment and method with accompanying raw data for tests)

5 tabulated initial and continuing calibration results (concentrations calibration factors or relative response factors and mean relative response factors differences and relative standard deviations) with accompanying raw data

6 tabulated retention time windows for each column

7 a record of the daily analytical scheme (run logbook instrument logbook) which includes samples and standards order of analysis

8 the chain of custody for the sample shipment groups DAS packing slip DAS analytical specifications

9 a narrative summary of method and any problems encountered during extraction or analysis

10 tabulated sample weights volumes and solids used in each sample calculation

11 example calculation for positive values and detection limits and

12 SW-846 method 3500 and 8000 validation data for all tests

The forms contained in Chapter 1 of SW-846 (Second Edition 1982 as amended by Update I April 1984 and Update II April 1985) or the current CLP SOW forms must be utilized to report the data when applicable

B2 Field Sampling Plan (FSP)

The objective of the Field Sampling Plan is to provide EPA and all parties involved with the collection and use of field data with a common written understanding of all field work The FSP should be written so that a field sampling team unfamiliar with the Site would be able to gather the samples and field information required Guidance for the selection of field methods sampling procedures and custody can be acquired from the Compendium of Superfund Field Operations Methods (OSWER Directive 93550shy14 EPA540P-87001) December 1987 which is a compilation of demonstrated field techniques that have been used during remedial response activities at hazardous waste sites The FSP shall be site-specific and shall include the following elements


1 Site Background If the analysis of the existing Site details is not included in the Work Plan or in the QAPP it must be included in the FSP This analysis shall include a description of the Site and surrounding areas and a discussion of known and suspected contaminant sources probable transport pathways and other information about the Site The analysis shall also include descriptions of specific data gaps and ways in which sampling is designed to fill those gaps Including this discussion in the FSP will help orient the sampling team in the field

2 Sampling Objectives Specific objectives of sampling effort that describe the intended uses of data must be clearly and succinctly stated

3 Sampling Location and Frequency This section of the FSP identifies each matrix to be collected and the constituents to be analyzed Tables shall be used to clearly identify the number of samples the type of sample (water soil etc) and the number of quality control samples (duplicates trip blanks equipment blanks etc) Figures shall be included to show the locations of existing or proposed sample points

4 Sample Designation A sample numbering system shall be established for the project The sample designation should include the sample or well number the sample round the sample matrix (eg surface soil ground water soil boring) and the name of the Site

5 Sampling Equipment and Procedures Sampling procedures must be clearly written Step-by-step instructions for each type of sampling that are necessary to enable the field team to gather data that will meet the Data Quality Objectives (DQOs) A list should include the equipment to be used and the material composition (eg Teflon stainless steel) of equipment along with decontamination procedures

6 Sampling Handling and Analysis A table shall be included that identifies sample preservation methods types of sampling jars shipping requirements and holding times Examples of paperwork such as traffic reports chain-of-custody forms packing slips and sample tags filled out for each sample as well as instructions for filling out the paperwork must be included Field documentation methods including field notebooks and photographs shall be described


Each Field Sampling Plan submitted as a part of the Project Operations Plan for the Remedial Design Sampling activities shall be sufficiently detailed to carry out the study and shall provide data needed to address the objective of the study and to complete the study Each study shall be designed to achieve a high performance on the first attempt Each work plan shall be related (by cross-references) to the other requirements in the Project Operations Plan

C Health and Safety Plan (HSP)

The objective of the site-specific Health and Safety Plan is to establish the procedures personnel responsibilities and training necessary to protect the health and safety of all on-site personnel during all work activities The plan shall provide procedures and plans for routine but hazardous field activities and for unexpected Site emergencies

The site-specific health and safety requirements and procedures in the HSP shall be updated based on an ongoing assessment of Site conditions including the most current information on each medium For each field task during all work performed under this SOW the HSP shall identify

1 possible problems and hazards and their solutions

2 environmental surveillance measures

3 specifications for protective clothing

4 the appropriate level of respiratory protection

5 the rationale for selecting that level and

6 criteria procedures and mechanisms for upgrading the level of protection and for suspending activity if necessary

The HSP shall also include the delineation of exclusion zones on a map and in the field The HSP shall describe the on-site person responsible for implementing the HSP for the Respondents representatives at the Site protective equipment personnel decontamination procedures and medical surveillance The following documents and resources shall be consulted

1 OSHA e-HASP Software - Version 10 September 2003 (wwwoshagovdepetoolsehaspindexhtmn


2 Hazardous Waste Operations and Emergency Response (Department of Labor Occupational Safety and Health Administration (OSHA) 29 CFR Part 1910120) and

3 Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities Appendix B (NIOSHOSHAEPA 1986)

OSHA regulations at 40 CFR 1910 which describe the routine emergency provisions of a site-specific health and safety plan and the OSHA e-HASP Software shall be the primary references used by the Respondent in developing and implementing the Health and Safety Plan

The measures in the HSP shall be developed and implemented to ensure compliance with all applicable state and Federal occupational health and safety regulations The HSP shall be updated at the request of EPA during the course of the Remedial Design Sampling activities and as necessary


m nlliU degdegdeg

[13 DMCWell Industrial Waste Gallery Elevation Contours Sludge Drying Beds 20 Feel Contour Interval

Roads- (771 Wetland --Hydrology Eg Pond

B3 Hot SpotAreas irirparcel Boundary

n Manufacturing Building 1 Sue indicates potential source areas Historical features are underlined and italicized 032005

METCALFampEDDY AECOM

APPENDIX 2 to UAO

Durham Meadows NPL Site Administrative Record

Unilateral Administrative Order (UAO) for Remedial Design Sampling and Vapor Intrusion Remedial Action

Index

UAO Dated 3mamp 2007 Released tee 2007

Prepared by EPA New England

Office of Site Remediation amp Restoration

Introduction to the Collection

This is the administrative record file for the Durham Meadows Superfund Site Durham CT Unilateral Administrative Order (UAO) for Remedial Design Sampling and Vapor Intrusion Remedial Action issued to the Durham Manufacturing Company June 2007 The file contains site-specific documents and a list of guidance documents used by EPA staff in selecting a response action at the site

The administrative record file is available for review at

EPA New England Office of Durham Public Library Site Remediation amp Restoration 7 Maple Avenue (OSRR) Records and Information Center Durham CT 06422 1 Congress Street Suite 1100 (HSC) (860) 349-9544 (phone) Boston MA 02114 http wwwdurhamlibrarvlionincorg (by appointment) 617-918-1440 (phone) 617-918-1223 (fax) wwwepa govregionO 1 superfundresourcerecordshtm

Questions about this administrative record file should be directed to the EPA New England site manager

This Administrative Record for the UAO shall consist of all documents and Guidance contained in the Durham Meadows NPL Site Administrative Record for the Record of Decision (ROD) issued on September 2005 (SDMS Document Number 237381) except for the documents listed below

67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216

6262007 AR Collection 11839

ARFORUAO AR Coffection QA Report

For External Use

10 ENFORCEMENTNEGOTIATION

251611 SPECIAL NOTICE LETTER RDRA NEGOTATION START - DURHAM MANUFACTURING CO

Author SUSAN STUDLIEN US EPA REGION 1- OFFICE OF SITE REMEDIATION amp RESTOSATION

Addressee MCHARDH PATTERSONDURHAM MANUFACTURING CO

Doc Type LETTER

273581 NOTIFICATION OF PENDING ISSUANCE OF AN ADMINISTRATIVE ORDER BY EPA FOR PERFORMANCE A PORTION OF THE SELECTED REMEDY

Author JOHN W KILBORN US EPA REGION 1

Addressee JACKLOONEY CT OFFICE OF THE ATTORNEY GENERAL

Doc Type LETTER

273S82 ACKNOWLEDGEMENT OF RECEDt OF NOTTFICATION OF PENDING ISSUANCE OF AN ADMINISTRATIVE ORDER BY EPA FOR PERFORMANCE A PORTION OF THE SELECTED REMEDY

Author JACKLOONEY CT OFFICE OF THE ATTORNEY GENERAL

Addressee JOHN W KILBORN US EPA REGION1

Doc Type MEMO

Page 1 of2

Doc Date 04072006 ttafPmgeK 128

File Break 1006

UocDate06252007

FOeBieaJk WQ7shy

DocDate 06252007 ltrf Pages 1

FBeBreakt 1007


ARFORUAO Page 2 of 2

AR Collection QA Report

For External Use

237381

20 RECORDS MANAGEMENT

INDEX TO RECORD OF DECISION (ROD) ADMINISTRATIVE RECORD

Author US EPA REGION1

Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40

Number of Documents in Collection

INDEX OF GUIDANCE

US Amriy Corps of EngineersUS Environmental Protection Agency (USACEUSEPA) 2000 Guide to Developing and Documenting Co6t Estimates During the FeasibiKty Study EPA 540shyR-00-002 July 2000

US Environrnental Protection Agency (USEPA) 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA USEPA Office of Solid Waste and Emergency Response WashingtonDfC Interim Final October 198amp

US Environmental Protection Agency (USEPA) 1989 Rsfc Assessment Guidance for Superftnd Volume I Human Health Evaluation Manual Part A Interim Final EPA5401 89002 December 1989

U S Environmental Protection Agency (USEPA) 1989 Region I Laboratory Data Validation Functional Guidelines for Evaluating Inorganics Analyses 1989

US Environmental Protection Agency (USEPA) 1990 National Oil and Hazardous Substances Pollution Contingency Plan (National Contingency Plan) Code of Federal Regulations Title 40 Part 300 Federal Register Volume 55 Number 46 pp 8666 et seq March 91990

US Environmental Protection Agency (USEPA) 1991 Risk Assessment Guidance for Superfund Volume I Human Health Evaluation Manuel Supplemental GuidanceStandard Default Exposure Factors Interim Final 92858-3 March 251991

US Environmental Protection Agency (USEPA) 1991 Rote of Baseline Risk Assessment in Superfund Remedy Selection Decisions Office of Solid Waste and Emergency Response Washington DC OSWER Directive 93550-30 Memo from Don R Clay April 221991

US Environmental Protection Agency (USEPA) 1991 Design and Construction of RCRACERCLA Final Covers US Environmental Protection Agency Office of Emergency Research and Development Washington DCEPA6254-91P25 May 1991

US Environmental Protection Agency (USEPA) 1991 Risk Assessment Guidance for Superfund Volume I Human Health Evaluation Manual Part B Development of Risk-Based Preliminary Remediation Goals Interim Final 92857-01B December 1991

bull bull - bull

US Environmental Protection Agency (USEPA)I1992 Supplemental Guidance to RAGS Calculating the Concentration Term Office of Solid Waste and Emergency Response Washington DC Publication 92857-081 May 1992

U S Environmental Protection Agency (USEPA) 1992 EPA Handbook ofRCRA Groundwater Monitoring Constituents Chemical and Physical Properties 40 CFRPart 264 Appendix IX September 1992

US Environmental Protection Agency (USEPA) 1993 Provisional Guidance for Quantitative Risk Assessment of Polycyclic Aromatic Hydrocarbons Office of Research and Development Washington DC EPA600R-93laquo)89 July 1993

US Environmental Protection Agency (USEPA) 1993 Guidance for Evaluating the Technical Impracticabilityof Ground-Water Restoration -Interim Final Officeof Spljd Waste and Emergency Response Washington DC Directive 92342-25 September 1993

US Environmental Protection Agency (USEPA) 1993 Presumpfire Remedies Policy and Procedures Office of Solid Waste and Emergency Response Washington DC Directive 93550shy4TFS September 1993 bull

US Environmental Protection Agency (USEPA) 1993 PresumptiveRemedies Site Characterization and Technology Selection for CERCLA Sites wtf Volatile Organic Compounds In Soils Office of Solid Waste and Emergency Response Washington DC Directive 93550-48FS September 1993 - bull bull bull bull - bull

US Environmental Protection Agency (USEPA) 1994 Guidance Manual for the Integrated Exposure Uptake Biokinetic Model for Lead in Children Office of Solid Waste and Emergency Respdnse Washington DC EPA540R-93081 February 1994

US Environmental Protection Agency (USEPA) 1994 Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities Office of Solid Waste and Emergency Response Washington DC OSWER Directive 93554-12 July 1994

US Environmental Protection Agency (USEPA) 1994 Risk Updates No 2 USEPA Region I August 1994 l

USEnvironmental Protection Agency (USEPA) 1995 Risk Updates No 3 USEPA Region I August 1995

US Environmental Protection Agency (USEPA) 199amp- Final Guidance Presumptive Response Strategy and Ex Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites Office of Solid Waste and Emergency Response Washington DC EPA 540R-96023 October 1996 bull

US Environmental Protection Agency (USEPA) 1996 Risk Updates No 4 USEPA Region I November 1996

U S Environmental Protection Agency (USEPA) 1996 Region I EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analysis 1996

US Environmental Protection Agency (USEPA) 1997 Presumptive Remedy Supplemental Bulletin Multi-Phase Extraction (MPE) Technology for VOCs in Soil and Groundwater Office of Solid bull Waste and Emergency Response Washington DC EPA 540-F-97^004 April 1997

US Environmental Protection Agency (USEPA) 1997 Health Effects Assessment Summary Tables FY-1997 Annual (HEAST) Office of Health and Environmental Assessment Environmental Assessment and Criteria Office and Office of Solid Waste and Emergency Response Washington DC July 1997

US Environmental Protection Agency (USEPA) 1997 Exposure Factors Handbook Office of Research and Development Washington DC August 1997

US Environmental Protection Agency (USEPA) 1998 Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in Groundwater Office of Research and Development Washington DC EPA600R-98128 September 1998

US Environmental Protection Agency (USEPA) 1998 Management of Remediation Waste Under RCRA Office of Soil Waste and Emergency Response EPA53Q-F-98-026 October 1998

US Environmental Protection Agency (USEPA) 1999 Use of Monitored Natural Attenuation at Superfund RCRA Corrective Action and Underground Storage Tank Sites Office of Solid Waste and Emergency Response Washington DC Directive 92004-17P April 1999

US Environmental Protection Agency (USEPA) 1999 A Guide to Preparing Superfund Proposed Plans Records of Decision and Other Remedy Selection -Documents Office of Solid Waste and Emergency Response Washington DC Directive 92001-23P July 1999

U S Environmental Protection Agency USEPA) 2000 EPI (Estimation Programs interface) bull Suite Developed by EPAs Office of Pollution Prevention Toxioe and Syracuse Research Corporation ltSRC)2ltOQ

US Environmental Protection Agency USEPA) 2001 Revised Alternative Cap Design Guidance Proposed for Untined Hazardous Waste LandfiHe in the EPA Region February 5 2001

US Environmental Protection Agency USEPA) 2001 Supplemental Guidance for Developing Soli Screening Levels tor Superfund Sites Peer Review Draft Office of Emergency and Remedial Response Washington OCOSWER Directive 93554-24 March 2001

US Environmental Pfoteotton Agency USEPA) 2001 Risk Assessment Guidance for Superfund Volume Human HeaRn Evaluation Manual Part D Standardized Planning Reporting and Review isfSupertund Risk Assessments Final Office of Emergency and Remedial Response Washington OCOSWER Direbttve 92857-47 December 2001

US Environmental Protection Agency (USEPA) 2002 Users Guide for the integrated Exposure Uptake Biottnetic Model for Lead in Children Office of Emergency and Remedial Response Washington OC EPA 92857-42 May 2002

US Environmental Protection Agency USEPA) 2002 Draft Guidance for Evaluating the Vapor intrusion to indoor Air Pathway from Groundwater and Soils RCR A2002033 November 2002

US environmental Protection Agency USEPA) 2002 National Recommended Water Quality Criteria Federal Register December 27 2002

X bull

US Environmental Protection Agency USEPA) 2002 Calculating Upper Confidence Limits lor Exposure Point Concentrations at Hazardous Waste Sites Office of Emergency and Remedial Response Washington DC OSWER 92856-10 December 2002

US Environmental Protection Agency USEPA) 2003 Recommendations of the Technical Review Workgroup for Lead for an Approach to Assessing Risk Associated with Adult Exposures to Lead in Soil technical Review Workgroup for Lead January 2003

US Environmental Protection Agency USEPA) 2003 Draft Final Guidelines for Carcinogen Risk Assessment External Review Draft Risk Assessment Forum February 2003

US Environmental Protection Agency USEPA) 2003 Drinking Water Standards Office of Water Jcme2003 -shy

U8 Environmental Protection Agency (USEPA) 2003 The DMAPL Remediation Challenge is There a Case for Source Depletion Expert Panel on ON APL Remediation Ground Water and Ecosystems Restoration Division EPA Contract No euro8^0-02-092 December 2003

US Environmental Protection Agency USEPA) 2004 Users Guide for ProUCL Version 30 Technical Support Center httpvwwepagovnerlesd1tscfeoftwarehtm April 2004

US Environmental Protection Agency (USEPA) 2004R6K Assessment Godance for Superfund Volume I Human Health Evaluation Manual Part pound Supplemental Guidance for Dermal Risk Assessment) Final Office of Superfund Remediation and Technology Innovation Washington DC EPAS40R99Q05 July 2004

US Environmental Protection Agency (USEPA) 2004 Preliminary Remediation Goafs Table Region 9 Technical Support Team Office of Superfund Programs Region IX October 2004

U S Environmental Protection Agency (USERA) 2005 Waste Ste Cteaoupamp Reuse in New England httpYosemlteepagovr1npLpadn8flAccessed February 25200S

US Environmental Protection Agency (USEPA) 2005 Integrated flsfc Information System (IMS) Environmental Criterion and AssessmentOffice March 200amp

Earl W Phillips Jr Esq Rich Fil Esq of 2

W Kilborn 5enior Enforcement Counsel

Enclosures

cc Addie Fiske DOJ Anni Loughlin EPA Addie Fiskc USDO1 Jack Loonev CT Ad








)CERCLA 01-2007-0113 )





II DEFINITIONS





























































C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull


















)CERCLA 01-2007-0113 )





II DEFINITIONS





























































C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull











II DEFINITIONS





























































C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull





























































C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull






























C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports



Statement of Work for DMC UAO Version FINAL Durham Meadows Superfund Site Date July 26 2007 Durham Connecticut shy of 30





















































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull





















C Selected Remedy
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull
























10

VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull











VI ORDER




VIII PARTIES BOUND




11










12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull




















12







13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull

















13











14








15









16









17







18








19











20












21








22










23

herein









24












25












26




XXXI SEVERABILITY







27






II DEFINITIONS













III SELECTED REMEDY

































C Soil Sampling
























B Deliverables


1 Progress Reports
























































B Deliverables



1 Progress Reports



































































































































































m nlliU degdegdeg






APPENDIX 2 to UAO



Index










67255 233866 67260 237194 67272 237200 67273 237201 67274 237202 67275 237203 67276 bull 237204 67277 237205 67278 shy 237214 67285 237215 67327 bull 237216



For External Use





Doc Type LETTER




Doc Type LETTER




Doc Type MEMO

Page 1 of2


File Break 1006

UocDate06252007

FOeBieaJk WQ7shy


FBeBreakt 1007




For External Use

237381




Addressee

Doc Type INDEX lt

Doc Date 09012005

PUe Break 2001

ft of Pages 40


INDEX OF GUIDANCE










bull bull - bull




























X bull











SDMS DocID 274209 Via E-Mai anl d Certified Mail Return ...

Documents

Transcript of SDMS DocID 274209 Via E-Mai anl d Certified Mail Return ...