Amendment 0004 - OU3 Remedial Investigation Report (Vol 1 of 3).pdf

TETRA TECH NUS, INC.

55 Jonspin Road • Wilmington, MA 01887-1020

(978) 658-7899 • FAX (978) 658-7870 • www.tetratech.com

RAC1-EPA-1581

Contract No. 68-W6-0045

October 4, 1999

Mr. Ronald Jennings (HBT) U. S. Environmental Protection Agency One Congress Street, Suite 1100. HBT Boston, Massachusetts 02114-2023

Subject: Transmittal of Final Remedial Investigation Report Raymark - Area I - Ferry Creek, OU3, Remedial Investigation/Feasibility Study RAC I W.A. No. 002-RICO-01H3

Dear Mr. Jennings:

Enclosed are nine copies (seven bound, one unbound, and one other for distribution) of the Final Area I Remedial Investigation for the Ferry Creek, OU3 study area. As instructed by you, I have also transmitted three copies to the Connecticut Department of Environmental Protection

(CTDEP).

If you have any questions, please contact me.

Very truly yours.

Heather M. Ford Project Manager

PMO -

HMF:pmp

Enclosures - 3 volumes per person c: H. Horahan (EPA) w/o enc.

R. Curan (CTDEP) w/enc. (3) A. Ostrofsky (TtNUS) w/o enc. xT File N7491-1.0 w/o enc./N7491-3.4w/enc. ^

RI99245F

FINAL

AREA I

REMEDIAL INVESTIGATION

VOLUME I OF

TEXT

RAYMARK-FERRY CREEK-OPERABLE UNIT 3

STRATFORD, CONNECTICUT

RESPONSE ACTION CONTRACT (RAC), REGION

For U.S. Environmental Protection Agency

By

Tetra Tech NUS, Inc.

EPA Contract No. 68-W6-0045

EPA Work Assignment No. 002-RICO-01H3

TtNUS Project No. N7491

October 1999

I V '

Heather M. Ford j George D. Gardner, P.E.

Project Manager Program Manager

TABLE OF CONTENTS

FINAL AREA I REMEDIAL INVESTIGATION

RAYMARK INDUSTRIES- OU3

VOLUME I

SECTION PAGE

1.0 INTRODUCTION 1-1

1.1 Purpose of Report 1-2

1.2 Report Organization 1-2

1.3 Study Area Background 1-4

1.3.1 History of Raymark Facility and Environs 1-4

1.3.2 Facility Operating History 1-7

1.3.3 Environmental Permits 1-11

1.3.4 Study Area Description and Setting 1-13

1.3.5 Other On-Going Activities 1-15

1.3.6 Previous Investigations 1-16

2.0 STUDY AREA INVESTIGATIONS 2-1

2.1 Surface Water and Sediment Investigations (1992-1994) 2-2

2.1.1 Sediment at Raymark Facility and

along Ferry Creek (1992 - 1995) 2-2

2.1.2 Surface Water at Raymark Facility (1993) 2-3

2.2 Soil Sampling (1993) 2-3

2.3 Expanded Site Inspection and Vertical Sampling Program (1993) 2-3

2.4 Phase I Remedial Investigation (1993 - 1995) 2-5

2.4.1 Soil Borings, Test Pits, and Soil Sampling (1994) 2-5

2.4.2 Surface Water and Sediment Sampling (1994-1995) 2-6

2.4.3 Salinity Survey (1994) 2-6

2.4.4 Ground Penetrating Radar Survey (March 1994) 2-7

2.4.5 Topographic Survey/Global Positioning Survey (1994) 2-7

2.5 Comprehensive Site Investigation Sampling Program (1994-1995) ..2-8

2.6 Removal Actions Post-Excavation Program (1994 - 1996) 2-9

2.7 Ecological Risk Assessment (1996 - 1998) 2-10

2.8 Phase II Site Investigation (1997) 2-10

2.8.1 Soil Borings and Soil Sampling 2-10

2.8.2 Sediment Sampling 2-11

2.9 Groundwater Discharge Study 2-12

3.0 PHYSICAL CHARACTERISTICS OF THE STUDY AREA 3-1

3.1 Surface Features and Land Use 3-1

3.2 Geology 3-2

3.2.1 Regional Geology 3-2

3.2.2 Site Geology 3-4

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TABLE OF CONTENTS (Cont'd)

RAYMARK INDUSTRIES - OU3

SECTION PAGE

3.3 Hydrogeology 3-10

3.3.1 Regional Hydrogeology 3-10

3.3.2 Study Area Hydrogeology 3-11

3.4 Surface Water Hydrogeology 3-13

3.5 Meteorology 3-14

4.0 NATURE AND EXTENT OF CONTAMINATION 4-1

4.1 Potential Sources of Contamination 4-1

4.1.1 Raymark Soil-Waste Materials Disposal 4-2

4.1.2 Raymark Wastewater Discharge 4-3

4.1.3 Groundwater Discharge 4-3

4.2 Overview of Chemical Compounds Detected 4-3

4.2.1 Volatile Organic Compounds (VOCs) 4-4

4.2.2 Semivolatile Organic Compounds (SVOCs) 4-4

4.2.3 Pesticides 4-5

4.2.4 Polychlorinated Biphenyls (PCBs) 4-5

4.2.5 Dioxins and Furans 4-5

4.2.6 Metals 4-6

4.2.7 Asbestos 4-6

4.2.8 Chemical Compounds Used or Handled at the

Raymark Facility 4-7

4.2.9 Terminology for Evaluating Analytical Data 4-7

4.2.10 Evaluation of Usability of Field Screening Data 4-8

4.3 Background Concentrations 4-9

4.3.1 Sediment 4-10

4.3.2 Surface Water 4-10

4.3.3 Soil 4-11

4.4 AreaA-1: AreaA-1: Upper Ferry Creek (Morgan Francis

Property) - Summary of Contamination 4-11

4.4.1 Sediment 4-12

4.4.2 Surface Water 4-14

4.4.3 Soil 4-15

4.5 Area A-2: Upper Ferry Creek (Commercial Property)

Summary of Contamination 4-18

4.5.1 Soil 4-19

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STRATFORD. CONNECTICUT

SECTION PAGE

4.6 Area A-3: Upper Ferry Creek (Wetlands)

Summary of Contamination 4-22

4.6.1 Sediment 4-22

4.6.2 Surface Water 4-26

4.6.3 Soil 4-27

5.0 CONTAMINANT FATE AND TRANSPORT 5-1

5.1 Contaminant Sources and Releases 5-1

5.2 Contaminant Fate and Transport in the Area I Study Area 5-4

5.2.1 Soil 5-6

5.2.2 Sediment and Surface Water 5-7

6.0 BASELINE HUMAN HEALTH RISK EVALUATION 6-1

6.1 Introduction - Overview of Risk Assessment Process 6-1

6.2 Data Evaluation Methodology 6-3

6.2.1 Selection of Chemicals of Potential Concern 6-4

6.3 Toxicity Assessment 6-15

6.3.1 Carcinogenic Effects 6-17

6.3.2 Noncarcinogenic Effects 6-21

6.3.3 Toxicity Summaries for Major Chemicals of Concern 6-23

6.4 Exposure Assessment 6-26

6.4.1 Exposure Setting 6-27

6.4.2 Conceptual Site Model 6-28

6.4.3 Potential Routes of Exposure 6-31

6.4.4 Potential Receptors 6-33

6.4.5 Exposure Pathways 6-34

6.4.6 Quantification of Exposure 6-35

6.4.7 Exposure to Lead 6-42

6.5 Risk Characterization 6-43

6.5.1 Risk Characterization Methodology 6-44

6.6 Uncertainties Analysis 6-45

6.6.1 Uncertainty in Selection of Chemicals of Concern 6-47

6.6.2 Uncertainty in the Exposure Assessment 6-48

6.6.3 Uncertainty in the Toxicological Evaluation 6-49

6.7 Baseline Human Health Risk Assessment - Area A-1

Morgan Francis Property 6-53

6.7.1 Overview of Area A-1, the Morgan Francis Property 6-54

6.7.2 Data Evaluation 6-54

6.7.3 Area A-1, Exposure Assessment 6-58

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SECTION PAGE

6.7.4 Risk Characterization 6-64

6.7.5 Uncertainties 6-70

6.7.6 Summary of Human Health Risk Assessment 6-71

6.8 Baseline Human Health Risk Assessment - Area A-2

Commercial Properties West of Ferry Creek 6-73

6.8.1 Overview of Area A-2, Commercial Properties West of

Ferry Creek 6-73

6.8.2 Data Evaluation 6-74

6.8.3 Area A2, Exposure Assessment 6-77

6.8.4 Risk Characterization 6-81

6.8.5 Uncertainties 6-86

6.8.6 Summary of Human Health Risk Assessment 6-87

6.9 Baseline Human Health Risk Assessment - Area A-3

Ferry Creek and Properties East of Ferry Creek 6-87

6.9.1 Overview of Area A-3, Ferry Creek and Properties

East of Ferry Creek 6-88

6.9.2 Data Evaluation 6-88

6.9.3 Area A-3, Exposure Assessment 6-92

6.9.4 Risk Characterization 6-97

6.9.5 Uncertainties 6-101

6.9.6 Summary of Human Health Risk Assessment 6-102

6.10 Summary of Human Health Risk Assessment for Areas A-1, A-2, and A-3 6-103

6.10.1 Noncarcinogenic Risks 6-103

6.10.2 Carcinogenic Risks 6-104

6.10.3 Exposure to Lead 6-104

6.10.4 Exposure to Asbestos 6-106

7.0 ECOLOGICAL EVALUATION 7-1

7.1 Site Description and Potential Receptors 7-2

7.1.1 Study Area Description 7-2

7.1.2 Water and Sediment Quality 7-3

7.1.3 Habitats and Potentially Exposed Receptor Groups 7-5

7.2 Routes of Exposure 7-6

7.3 Identification of Contaminants of Concern 7-6

7.4 Selection of Ecological Endpoints 7-7

7.5 Selection of Indicator Species 7-7

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RAYMARK INDUSTRIES- OU3

SECTION PAGE

7.6 Ecological Effects 7-7

7.6.1 Chemistry 7-8

7.6.2 Contaminant Residue in Organisms 7-10

7.6.3 Effects on Wildlife 7-11

7.6.4 Toxicity Testing 7-12

7.6.5 Benthic Community Analysis 7-14

7.7 Summary and Conclusions 7-15

8.0 SUMMARY AND CONCLUSIONS 8-1

8.1 Nature and Extent of Contamination Summary 8-2

8.1.1 Nature of the Contamination within Area I 8-2

8.1.2 Extent of Contamination within Area I 8-3

8.1.3 Volatile Organic Compounds (VOCs) 8-3

8.1.4 Semivolatile Organic Compounds (SVOCs) 8-4

8.1.5 Pesticides 8-5

8.1.6 Polychlorinated Biphenyls (PCBs) 8-6

8.1.7 Dioxins/Furans 8-6

8.1.8 Metals 8-7

8.1.9 Asbestos 8-8

8.2 Contaminant Fate and Transport Summary 8-9

8.3 Risk Assessment Summary 8-9

8.3.1 Human Health Risk Assessment 8-9

8.3.2 Ecological Risk Assessment 8-12

8.4 Conclusions 8-13

REFERENCES

VOLUME II

TABLES

NUMBER

1-1 History of Activities Associated with Raymark Facility and Environs

4-1 Chemical Contaminants Frequently Detected in OU3 Study Area

4-2 Chemical Compounds Used or Handled at the Raymark Facility

4-3 Summary of Background Concentrations in Sediment

4-4 Summary of Background Concentrations in Surface Water

RI99245F Raymark, CT

TABLES (Cont'd)

4-5 Summary of Background Concentrations in Soil 4-6 AreaA-1: Samples Collected and Analyses Performed 4-7 Area A-1, Sediment Contaminants Exceeding Background 4-8 Area A-1, Surface Water Contaminants Exceeding Background 4-9 Area A-1, Soil Contaminants Exceeding Background 4-10 Area A-2: Samples Collected and Analyses Performed 4-11 Area A-2, Soil Contaminants Exceeding Background 4-12 Area A-3: Samples Collected and Analyses Performed 4-13 Area A-3, Sediment Contaminants Exceeding Background 4-14 Area A-3, Surface Water Contaminants Exceeding Background 4-15 Area A-3, Soil Contaminants Exceeding Background 6-1 Criteria Used to Evaluate Chemicals Detected in Soil/Sediment 6-2 Criteria Used to Evaluate Chemicals Detected in Surface Water Biota 6-3 Cancer Slope Factors for Chemicals of Concern 6-4 Estimated Orders of Potential Potency for Carcinogenic PAHs'11

6-5 Dioxin and Furan Toxicity Equivalent Factors" 6-6A Slope Factors for Aroclors111

6-6B Toxicity Equivalence Factors for PCB Congeners 6-7 Reference Doses and Endpoints/Target Organs for Chemicals of Concern 6-8 Summary of Potential Receptors 6-9 Summary of Exposure Routes Evaluated Quantitatively 6-1OA Summary of Exposure Input Parameters - Sediment/Soil'11

6-1 OB Chemical Specific Dermal Absorption Factors for Soils/Sediments 6-11 Summary of Exposure Input Parameters- Surface Water11"21

6-12 Selection of Chemicals of Potential Concern, Area A-1, Morgan Francis Properties, Surface Soil/Sediment

6-13 Selection of Chemicals of Potential Concern, Area A-1, Morgan Francis Properties, All Soil/Sediment (0-15')

6-14A Comparison of Maximum Concentrations to Ground water Protection Benchmarks, Area A-1, Morgan Francis Properties, Surface Soil/Sediment

6-14B Comparison of Maximum Concentrations to Groundwater Protection Benchmarks, Area A-1, Morgan Francis Properties, All Soil/Sediment (0-1 5')

6-14C Comparison of Leachate Concentrations to SPLP Criteria

RI99245F VI Raymark, CT

6-15 Selection of Chemicals of Potential Concern, Area A-1, Morgan Francis Properties, Surface Water

6-16 Selection of Receptors and Exposure Pathways Area A-1, Morgan Francis Properties

6-17 Exposure Point Concentrations, Area A-1, Morgan Francis Properties 6-18A Summary of Cancer Risks and Hazard Indices Reasonable Maximum

Exposure Scenario Area A-1, Morgan Francis Properties 6-18B Summary of Cancer Risks and Hazard Indices Central Tendency

Exposures Scenario Area A-1, Morgan Francis Properties 6-19 Summary of Remedial Investigations and Recommendations, Area A-1, Morgan Francis Properties 6-20 Selection of Chemicals of Potential Concern Area A-2, Spada Property, Surface Soil/Sediment 6-21 Selection of Chemicals of Potential Concern, Area A-2, Spada Property, All Soil/Sediment (0-15') 6-22A Comparison of Maximum Concentrations to Groundwater Protection

Benchmarks, Area A-2, Spada Property, Surface Soil/Sediment 6-22B Comparison of Maximum Concentrations to Groundwater Protection

Benchmarks, Area A-2, All Soil/Sediment (0-15') 6-23 Selection of Receptors and Exposure Pathways, Area A-2, Spada

Property 6-24 Exposure Point Concentrations, Area A-2, Spada Property 6-25A Summary of Cancer Risks and Hazard Indices Reasonable Maximum

Exposure Scenario, Area A-2, Spada Property 6-25B Summary of Cancer Risks and Hazard Indices Central Tendency Exposure

Scenario, Area A-2, Spada Property 6-26 Summary of Remedial Investigations and Recommendations, Area A-2, Spada Property 6-27 Selection of Chemicals of Potential Concern, Area A-3, Residential

Properties on Housatonic Avenue, Surface Soil/Sediment 6-28 Selection of Chemicals of Potential Concern, Area A-3, Residential

Properties on Housatonic Avenue, All Soil Sediment (0-1 5') 6-29A Comparison of Maximum Concentrations to Groundwater Protection

Benchmarks, Area A-3, Residential Properties on Housatonic Avenue, Surface Soil/Sediment

RI99245F VII Raymark, CT

6-29B Comparison of Maximum Concentrations to Groundwater Protection Benchmarks, Area A-3, Residential Properties on Housatonic Avenue, All Soil/Sediment (0-15')

6-29C Comparison of Leachate Concentrations to TCLP/SPLP - Criteria Area A3, Residential Properties on Housatonic Avenue

6-30 Selection of Chemicals of Potential Concern, Area A-3, Residential Properties on Housatonic Avenue, Surface Water

6-31 Selection of Receptors and Exposure Pathways, Area A-3, Residential Properties on Housatonic Avenue

6-32 Exposure Point Concentrations, Area A-3, Residential Properties on Housatonic Avenue

6-33A Summary of Cancer Risks and Hazard Indices Reasonable Maximum Exposure Scenario

6-33B Summary of Cancer Risks and Hazard Indices Central Tendency Exposure Scenario Area A-3, Residential Properties on Housatonic Avenue

6-34 Summary of Remedial Investigations and Recommendations, Area A-3, Residential Properties on Housatonic Avenue

7-1 Total Organic Carbon Statistics Surface Sediment Samples 7-2 Sediment AVS SEM Statistics 7-3 Contaminants of Concern 7-4 Comparison of AWQC for CoCs with Measured Water Concentrations

(ug/L) 7-5 Concentrations of Contaminants Detected in Sediment Samples (Dry

Weight Basis) 7-6 Concentrations of Trace Metals, PCBs, DDTs and PAHs in Fish Tissues

(Wet Weight) 7-7 Concentrations of Trace Metals, PCBs, DDTs, and PAHs in Crab Tissues

(wet weight) 8-1 Summary of the Potential Risks That Could Result from Exposure to

Raymark Soil-Waste.

RI99245F VIII Raymark, CT

RAYMARK INDUSTRIES OU3

STRATFORD. CONNECTICUT

VOLUME II

FIGURES

NUMBER

1-1 Site Locus Map 1 -2 Study Area 3-1 AreaA-1: Estimated Thickness of Fill 3-2 Area A-2 and A-3: Estimated Thickness of Fill 3-3 Geologic Profiles 4-1 Area A- :

4-2 Area A- :

4-3 Area A- :

4-4 Area A- :

4-5 Area A- :

4-6 Area A-1:

4-7 Area A-1:

4-8 Area A-1:

4-9 Area A-1:

4-10 Area A-2:

4-11 Area A-2:

4-12 Area A-2:

4-13 Area A-2:

4-14 Area A-2:

4-15 Area A-2:

4-16 Area A-2:

4-17 Area A-2:

4-18 Area A-2:

4-19 Area A-3:

4-20 Area A-3:

4-21 Area A-3:

4-22 Area A-3:

4-23 Area A-3:

4-24 Area A-3:

4-25 Area A-3:

4-26 Area A-3:

4-27 Area A-3:

Sample Location Plan Total Aroclors in Surface Sediment and Surface Soil Total Aroclors in Subsurface Sediment and Subsurface Soil Lead in Surface Sediment and Surface Soil Lead in Subsurface Sediment and Subsurface Soil Copper in Surface Sediment and Surface Soil Copper in Subsurface Sediment and Subsurface Soil Asbestos in Surface Sediment and Surface Soil Asbestos in Subsurface Sediment and Subsurface Soil Sample Location Plan Total Aroclors in Surface Soil Total Aroclors in Subsurface Soil Lead in Surface Soil Lead in Subsurface Soil Copper in Surface Soil Copper in Subsurface Soil Asbestos in Surface Soil Asbestos in Subsurface Soil Sample Location Plan Total Aroclors in Surface Sediment and Surface Soil Total Aroclors in Subsurface Sediment and Subsurface Soil Lead in Surface Sediment, Surface Water, and Surface Soil Lead in Subsurface Sediment and Subsurface Soil Copper in Surface Sediment, Surface Water, and Surface Soil Copper in Subsurface Sediment and Subsurface Soil Asbestos in Surface Sediment and Surface Soil Asbestos in Subsurface Sediment and Subsurface Soil

6-1 Human Health Risk Receptors and Hot Spots 7-1 Primary Contaminant Pathways from the Raymark Industries Facility

RI99245F IX Raymark, CT

VOLUME HI

APPENDICES

Appendix A - Boring Logs Appendix B - Analytical Data - 1 Diskette Appendix C - Hydrologic and Hydraulic Analysis (ACOE) Appendix D - Ecological Risk Assessment (NOAA); Evaluation of Raymark Superfund

Data for PRG Development (SAIC); Evaluation of Ecological Risk to Avian and Mammalian Receptors in the Vicinity of Upper and Middle Ferry Creek, Stratford, CT (SAIC)

Appendix E - Ground Penetrating Radar Survey Appendix F - Human Health Risk Assessment Supporting Documentation Appendix G - Supplemental Evaluation of Nature and Extent of Contamination Appendix H - Supplemental Evaluation of Fate and Transport Processes

RI99245F X Raymark, CT cc

ACRONYMS AND ABBREVIATIONS

USED IN THE REMEDIAL INVESTIGATION REPORT

ABS

ARARs

ARCS

AST

ATSDR

AWQC

bgs

B&RE

°C

COM

CERCLA

cf cfm cfs

CFR

CLP

cm cm/sec

COC

COCP

CPF

CSF

CSI

CTDEP

CT DHS

CTDOH

CT DOT

CT DPHAS

CTE

CWA

CY

DAS

DDT

dia

DNAPL

ELI

EM

EPA

ESI

°F

FEMA

Absorption Factor Applicable or Relevant and Appropriate Requirements Alternative Remedial Contracting Strategy aboveground storage tank Agency for Toxic Substances and Disease Registry Ambient Water Quality Criteria below ground surface Brown & Root Environmental degree Celsius Camp Dresser and McKee The Comprehensive Environmental Response, Compensation, and Liability Act of 1980. Amended by SARA in 1986. Also called the Superfund Law.

cubic centimeter cubic foot cubic foot per minute cubic foot per second Code of Federal Regulations (EPA) Contract Laboratory Program centimeter centimeter per second Contaminant of Concern Contaminant of Potential Concern Carcinogenic Potency Factor Carcinogenic Slope Factor Comprehensive Site Investigation Connecticut Department of Environmental Protection Connecticut Department of Health Services Connecticut Department of Health Connecticut Department of Transportation Connecticut Department of Public Health and Addiction Services Central Tendency Exposure Clean Water Act cubic yard Direct Analytical Services Dichloro diphenyl trichloroethane diameter dense non-aqueous phase liquid Environmental Laboratories, Inc.

Electromagnetic U.S. Environmental Protection Agency Expanded Site Inspection degree Fahrenheit Federal Emergency Management Agency

RI99245F -1- Raymark OU3, CT

Foster Wheeler

FS

ft ftVday ft3/day

GA/GAA

gal

GB

gpd gpm

GPR

GPS

HEAST

HI

HNUS

hr

HQ

i

ID

IEUBK

ILCR

in.

IDW

IRIS

K K« kg Koc Kow I Ib

LDR

LOAEL

m or

MCL

MCLG

MEP

MFL

mg mg/kg

Foster Wheeler Environmental Corporation Feasibility Study foot square foot per day cubic foot per day gram State of Connecticut classification for drinking water sources gallon State of Connecticut classification for non-drinking water sources gallon per day gallon per minute Ground Penetrating Radar Global Positioning System EPA's Health Effects Assessment Summary Tables Hazard Index Halliburton NUS Corporation hour Hazard Quotient hydraulic index inner diameter EPA's Integrated Exposure Uptake and Biokinetic Model for lead exposure Incremental Lifetime Cancer Risk inch Investigation-Derived Waste EPA's Integrated Risk Information System Database Hydraulic conductivity Adsorption coefficient kilogram Adsorption partitioning coefficient Octanol-water partitioning coefficient liter pound land disposal restriction Lowest Observed Adverse Effect Level meter micro (prefix) micrograms per deciliter microgram per kilogram microgram per liter Federal Safe Drinking Water Act maximum contaminant level. The primary MCL is health-based; the secondary is aesthetic-based.

Federal Safe Drinking Water Act maximum contaminant level goal.

Multiple Extraction Procedure million fibers per liter milligram milligram per kilogram

RI99245F -2- Raymark OU3, CT mg/l or mg/L mi ml mph

MSL

NAPL

NCR

NESHAP

NGVD

NOAA

NOAEL

NPDES

NTCRA

OSHA

OSWER

OU2

OU3

PAH

PCB

PCDD

PCDF

PCE

PH

ppb ppm

PRG

PRP

psi

QA/QC

RAC

RAO

Raymark Facility RRCs

RCP

RCRA

Removal Action

RfC RfD

RFI

Rl

RI/FS

RME

ROD

RSRs

SARA

milligram per liter mile milliliter miles per hour mean sea level non-aqueous phase liquid National Oil and Hazardous Substances Contingency Plan National Emission Standards for Hazardous Air Pollutants National Geodetic Vertical Datum National Oceanic Atmospheric Administration No Observed Adverse Effect Level National Pollutant Discharge Elimination System Non-Time Critical Removal Action Occupational Safety and Health Administration (EPA's) Office of Solid Waste and Emergency Response Operable Unit No. 2 Operable Unit No. 3 polynuclear aromatic hydrocarbon polychlorinated biphenyl Polychlorinated dibenzo dioxins Polychlorinated dibenzo furans Tetrachloroethene hydrogen-ion concentration part per billion part per million Preliminary Remediation Goal Potentially Responsible Party pound per square inch Quality Control/Quality Assurance Response Action Contract Remedial Action Objective Raymark Industries, Inc. Facility EPA Region III Risk-based Calculation reinforced concrete pipe Resource Conservation and Recovery Act Action taken by EPA to address immediate danger to public health and the environment Reference Concentration Reference Dose RCRA Facility Investigation Remedial Investigation Remedial Investigation/Feasibility Study Reasonable Maximum Exposure (EPA's) Record of Decision. Documents the selection of a cost-effective Superfund remedy.

State of Connecticut Remediation Standard Regulations Superfund Amendments and Reauthorization Act of 1986.

RI99245F -3- Raymark OU3, CT

Amended CERCLA. Also known as the Superfund law.

SB/SC State of Connecticut Classification for Coastal and Marine Surface

SCT

SDWA

SPLP

SPT

sq ft sq in.

sqyd

SSL

SVOC

TAL

TAT

TBC

TC

TCB

TCDD

TCE

TCL

TCLP

TEF

TEQ

TERC

TOC

TOX

TPH

TPY

TSCA

TSD

UCL

USAGE

uses

USDOI

USGS

UST

VOC

VSP

Weston

WQC

1,1-DCA

1,1,1-TCA

1,2-DCE

1,1-DCE

2,4-D

Water Salinity-Conductivity-Temperature Safe Drinking Water Act Synthetic Precipitation Leaching Procedure Standard Penetration Testing square foot square inch square yard EPA's generic soil screening levels Semivolatile Organic Compound (CLP) Target Analyte List for Inorganics Technical Assistance Team To Be Considered Toxicity Characteristic Trichlorobiphenyl 2,3,7,8 - tetrachlorodibenzo-p-dioxin Trichloroethene (CLP) Target Compound List for Organics Toxicity Characteristic Leaching Procedure Toxicity Equivalence Factor Toxicity Equivalency Total Environmental Restoration Contract Total Organic Carbon Total Organic Halides Total Petroleum Hydrocarbons ton per year Toxic Substances Control Act (RCRA) Treatment, Storage, and Disposal Upper Confidence Limit U.S. Army Corps of Engineers Unified Soils Classification System U.S. Department of the Interior U.S. Geological Survey underground storage tank Volatile Organic Compound Vertical Sampling Program Roy F. Weston, Inc.

State of Connecticut water quality standards 1,1-Dichloroethane 1,1,1 -Trichloroethane 1,2-Dichloroethene 1,1-Dichloroethene 2,4-dichlorophenoxyacetic acid

RI99245F -4- Raymark OU3, CT

1.0 INTRODUCTION

This Area I Remedial Investigation (Rl) Report defines the nature and extent of contamination in Ferry Creek, other ecological areas, and adjacent properties resulting from past disposal practices at the Raymark Industries, Inc. Facility (Raymark Facility), located in Stratford, Fairfield County, Connecticut (Figure 1-1). This Rl Report was prepared by

Tetra Tech NUS, Inc. (TtNUS, formerly Brown & Root Environmental (B&RE)), for the U.S.

Environmental Protection Agency (EPA) under RAC Work Assignment No. 002-RICO-01H3, Contract No. 68-W6-0045, to partially fulfill the requirements for Operable Unit No. 3

(OU3), Raymark - Ferry Creek. Originally, a Draft Rl was issued in June 1998, for all the

OU3 areas affected by Raymark-type waste. In that document the OU3 study area was divided into 8 areas (A-1, A-2, A-3, B, C, D, E, and F - see Figure 1-2). However, when

EPA decided additional information was needed for some of these areas, a decision was made to sub-divide the areas into 3 separate cleanups. The Area I study area (study area), which includes subareas A-1, A-2, and A-3, is on the fastest track and is the subject of this Final Rl report. The Area II study area contains subareas B, C, and F, and it is anticipated that the Draft Rl report will be issued in the winter of the year 2000. The Area

III study area contains subareas D and E, and it is anticipated that the Draft Rl report will be issued in the winter of the year 2000.

As requested by EPA, this Rl Report incorporates information collected for OU3 during

1997 to 1999, with data previously compiled in the Final Technical Memorandum, Compilation of Existing Data, Raymark - Ferry Creek (B&RE, January 1997). This Rl Report was developed based on the original Work Plan (December 1996), Work Plan Amendment

No. 2 (March 1997), and Work Plan Amendment No. 4 (February 1998). The results of the field work executed under Work Plan Amendment No. 3 are also a part of this Rl.

Additional efforts to evaluate groundwater contamination beneath and downgradient of the former Raymark Facility are currently being conducted by TtNUS under a separate work assignment.

RI99245F 1-1 Raymark OU3, CT

This Area I Rl Report was prepared in accordance with the Interim Final Guidance for

Conducting Remedial Investigations and Feasibility Studies under CERCLA (EPA, 1988). It is consistent with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980; as amended by the Superfund

Amendments and Reauthorization Act (SARA) of 1986; and the National Gil and

Hazardous Substances Pollution Contingency Plan (NCP). This Area I Rl Report is consistent with the State of Connecticut's applicable and relevant environmental laws and regulations.

1.1 Purpose of Report

This Area I Rl Report documents the nature and extent of contamination, and associated public health and environmental risks within Ferry Creek, other ecological areas, and adjacent properties associated with the Raymark Facility. (Figure 1-2 identifies the OU3 study area and the Area I study area.) The overall objectives of the Rl are to:

• Compile and evaluate all available data needed to characterize the study area conditions and to determine the nature and extent of contamination in the surface water, sediment, and soil in Ferry Creek and other ecological areas,

• Assess the total risks to human health and the environment within the study area,

• Serve as the data resource for developing, screening, and evaluating a range of potential alternative remedial actions that address the contamination within the study area. The Rl also supports the remedial alternatives screening and the

Feasibility Study (FS).

1.2 Report Organization

This Rl Report is comprised of three volumes. Volume I presents the text and discussion of investigation activities, results, interpretations, and references. Volume II contains

RI99245F 1-2 Raymark OU3, CT tables and figures (including oversize figures). Volume III presents the appendices.

Appendix A contains the boring logs; Appendix B is comprised of a disk, which contains analytical data used to produce this Rl Report; Appendix C is the Hydraulic Assessment prepared by the U.S. Army Corps of Engineers (USACOE); Appendix D is the Ecological

Risk Assessment prepared by the National Oceanic and Atmospheric Administration

(NOAA); Appendix E is the Ground Penetrating Radar Survey; Appendix F is the backup tables and calculations for the Human Health Risk Assessment; Appendix G contains the supplemental evaluations of the Nature and Extent of Contamination; and Appendix H contains the supplemental evaluation of Contaminant Fate and Transport.

This Rl Report is organized as follows:

• Section 1.0, Introduction, discusses the purpose and scope of the Rl, summarizes the background and history, and describes the study area,

• Section 2.0, Study Area Investigations, presents a summary of the previous field investigation activities conducted in the study area,

• Section 3.0, Physical Characteristics of the Study Area, presents descriptions of surface features and land uses, geology, hydrogeology, surface water hydrology, and meteorology,

• Section 4.0, Nature and Extent of Contamination, discusses the potential sources, contaminant presence, and contaminant distribution in the soil, surface water, and sediment in the study area,

• Section 5.0, Contaminant Fate and Transport, presents an interpretation of potential contaminant migration pathways and transport mechanisms,

• Section 6.0, Baseline Human Health Risk Assessment, includes identification of human receptors and exposure pathways, selection of contaminants of concern

RI99245F 1-3 Raymark OU3, CT

(COCs), a discussion of the human health effects associated with the COCs, and the results of the human health risk evaluation,

• Section 7.0, Ecological Evaluation, presents a summary of the environmental setting and identifies areas of potential ecological concern. The ecological risk assessment is presented in Appendix D,

• Section 8.0, Summary and Conclusions, details the summary of Sections 4.0, 5.0, 6.0, and 7.0 and the conclusions reached on contaminated areas.

1.3 Study Area Background

This section summarizes the history of the study area and vicinity, the past operations at the Raymark Facility, describes the study area, identifies other on-going activities associated with the Raymark Facility, and summarizes the types of investigations previously conducted at the Raymark Facility and its environs.

1.3.1 History of Raymark Facility and Environs

The Raymark Facility, formerly named Raybestos - Manhattan Company, was located at

75 East Main Street in Stratford, Fairfield County, Connecticut at latitude 41°12'02.5"N and longitude 73°07'14.0"W (see Figure 1-1). The Raymark Facility operated from 1919 until 1989, when the plant was shut down and permanently closed. The Raymark Facility produced and manufactured products mainly for the automotive industry. The manufacturing of these products generated waste. The facility was demolished and a cap was placed over the contaminated areas on the property in 1996 and 1997. Based on

Stratford tax map information, the facility occupied 33.4 acres and manufactured friction materials containing asbestos and non-asbestos components, metals, phenol-formaldehyde resins, and various adhesives. Primary products were gasket material, sheet packing, and friction materials including clutch facings, transmission plates, and brake linings. As a

RI99245F 1 -4 Raymark OU3, CT result of these activities, soils at the facility became contaminated primarily with asbestos, lead, and polychlorinated biphenyl compounds (PCBs).

Between 1919 and 1984, low-lying portions of the Raymark Facility were filled with manufacturing waste materials from various plant operations. The filling of those areas occurred over the life of the facility operations, and progressed essentially from north to south, across the Raymark Facility. New buildings and parking areas were constructed over these filled areas as the manufacturing facility expanded.

The Raymark Facility was underlain by an extensive drainage system network. This network collected water and wastes from the manufacturing operations and diverted it into the facility drainage system. The system also collected stormwater runoff. These liquids were transported through the drainage system network, mixed with lagoon wastewaters, and discharged to Ferry Creek.

During peak operations at the Raymark Facility, approximately two million gallons of water were used for plant processes each day. Municipal water was used for both contact and non-contact cooling water. To supplement this source, Raymark installed an additional on-site supply well. The well, located in the northeastern corner of the facility, was used for non-contact cooling water. Facility water was recirculated, with some percentage reinjected into the on-site well, the remaining water and municipal water were discharged through the facility drainage system. Wastewater from facility operations was collected and discharged to a series of four settling lagoons located in the southwestern corner of the facility, and along the southern property boundary near Longbrook Avenue and the

Barnum Avenue Cutoff. The wastewater consisted of wastewater from the acid treatment plant, wet dust collection, and paper making processes; non-contact cooling water, and solvent recovery plant operations. The lagoons also received stormwater drainage and surface water runoff.

Solids were allowed to settle in Lagoon Nos. 1, 2, and 3 prior to discharge of clarified wastewater and unsettled solids to Lagoon No. 4, that in turn discharged directly into

RI99245F 1 -5 Raymark OU3, CT

Ferry Creek. Discharge of wastewater to Lagoon Nos. 1, 2, and 3 ceased in 1984. These lagoons were closed in December 1992 and January 1993. During the fall of 1994, stormwater drainage that exited the Raymark Facility through Lagoon No. 4 was diverted around this lagoon and connected directly to the storm sewer, which ultimately discharges to Ferry Creek. Lagoon No. 4 was closed in early 1995.

During the operation of the lagoons, the settled material in the lagoons was periodically removed by dredging. During the facility's 70 years of operation, it was common practice to dispose of both this dredged lagoon waste and other manufacturing waste as "fill" material (referred to as "Raymark-type waste" in this Rl) both at the Raymark Facility and at various locations in Stratford. Several of these locations that received Raymark-type waste are included within the area designated as "the study area" (Figure 1-2).

A number of these off-the-facility "locations," with levels of asbestos, lead, and PCBs that may pose a threat to public health, were remediated under EPA CERCLA time-critical removal actions during 1993 to 1996. The remediated locations are residential properties that were designated a health threat and excavated under EPA direction to abate the public health threat that may have existed. The excavated material from these residential locations was stored and ultimately placed under the cap at the Raymark Facility. Waste from one municipal property, Wooster Middle School, was also excavated, stored, and ultimately placed under the cap at the Raymark Facility.

In 1980, Raymark filed a Notification of Hazardous Waste Activity in accordance with

RCRA. RCRA activities are detailed in Sections 1.3.3.1 of this report.

In 1992, EPA issued Raymark a CERCLA 106 Removal Order and work plan designed to abate the danger or threat to public health and welfare, and the environment posed by four open lagoons containing asbestos, metals, solvents, and PCBs; a hazardous waste pile;

buildings and land containing hazardous substances; and large tanks of questionable integrity containing asbestos and hazardous substances; and to eliminate the potential for hazardous substances to migrate off-site.

RI99245F 1 -6 Raymark OU3, CT

1.3.2 Facility Operating History

The following narrative presents a summary of plant operations and waste handling practices for Ray mark's manufacturing operations; see OU1 Rl (HNUS, 1995) for further details.

1.3.2.1 Phenolic Resin Manufacturing

Solid and liquid phenolic resin was manufactured at the Raymark Facility. The resin was produced in five or six pressure vessels; companion tanks held the raw product. After production, the liquid resins were transferred to the plant floor to manufacture plant goods or to set in order for use in solid form. Prior to use, the solid resins were pulverized on site to meet product specifications, and then transferred to the plant floor for use.

1.3.2.2 Brake Lining Production

Brake lining production began by adding dry asbestos materials, liquid phenolic resins, and solvents (to thin the resins) to the mixers located on the plant floor. The mixers operated for approximately one hour until the liquid resin had penetrated and coated all the dry materials. This mixture, resembling a soft heavy mud, was formed into brake lining parts that were then baked in ovens for six hours. The end product was a hard material that was machined to the specifications of a finished brake lining. As necessary, materials that were trimmed and ground during the machining operations and not used in the finished product were disposed of on- or off-site as fill/soil-waste material; after 1984, these processed wastes were shipped off site in containers.

During the machining operations, waste particulates were collected in a wet-type dust collection system. Particulates collected from the system were mixed with process water and pumped to the on-site lagoons as a 90/10 water/dust slurry mixture. The slurry mixture settled out in the lagoons and eventually filled them. When a lagoon was filled, the slurry mixture would be diverted to another lagoon, to allow time (several months) to

RI99245F 1 -7 Raymark OU3, CT dewater. The dewatered material in the lagoon was excavated and disposed of either on-site or off-site. After 1984, the waste participates were collected in dry dust collectors and disposed of off site in one-cubic yard bags.

1.3.2.3 Standard Transmission Clutch Plates

The process of producing clutch plates began by creating a mixture of asbestos, other components, and water and forming a paper-like sheet of material. This sheet was rolled onto a machine roller, saturated with phenolic resin, and then oven dried and cured. The clutch plates were machined to specifications from these sheets and the finished clutch plate was bonded to a steel core. As in the brake lining production, the manufacturing process produced machining particulates that were collected in the dust collection system, mixed into a wet slurry, and pumped to the lagoons to settle. This system was replaced in

1984, by the dry dust collectors.

In the early 1980s, the process was modified to allow water to be reused and captured into the manufacturing process resulting in no discharge of water. In addition, the dry asbestos used in the original manufacturing of the paper-like material was replaced with a cotton-type material, so the product became asbestos-free.

The Raymark Facility molded (raw) steel into a steel core onto which the clutch plate was mounted. After molding the steel core was degreased, etched to specification, coated with a phenolic resin, and allowed to dry. The clutch plate was then mounted to the steel core.

A specialty heavy-duty clutch was also manufactured on the Raymark Facility. The process of mixing the asbestos, resins, and water to produce heavy-duty clutches was similar to that used to produce the standard transmission clutch plates.

RI99245F 1 -8 Raymark OU3, CT

1.3.2.4 Gasket Material Manufacturing

Gasket material was produced in large rubber sheets. The rubber was composed of naphtha, toluene, asbestos, phenolic resins, and various fillers. The process began by mixing asbestos, latex, rubber cement, and rubber together until the mix was homogeneous. The mix was then loaded onto a roller machine where it was flattened into a sheet. The sheet was removed and laid out on a large table for cutting. The gaskets were then cut to specification.

The trim from cutting was pulverized and re-used in the process. Vapors were collected and passed through the activated carbon solvent recovery plant. Prior to the mid-1980s, no vapor collection or handling occurred.

1.3.2.5 Disc Brake Pad Manufacturing Operations

Asbestos, glass, and semi-metallic disc brakes were manufactured at the Raymark Facility.

Asbestos disc brakes were composed of asbestos, phenolic resin, and fillers; glass disc brakes were composed of fiberglass, phenolic resin, and fillers; and semi-metallic disc brakes were composed of steel wool, phenolic resin, and fillers. The operations to process these disc brake pads involved mixing components in plant mixers until a homogenous mixture was coated completely with phenolic saturate, pouring the mixture into electronically heated molds to form a hard part, and machining this part into the needed specified product size.

Waste generated from the machining process was collected in the dust collector system, and transported as described above, as a water/waste slurry mixture to the on-site lagoons. After 1984, dry dust collectors collected the particulate matter and the material was disposed of off site in one-cubic yard bags. The trim and off-specification material, if not pulverized for reuse, was disposed of as fill.

RI99245F 1 -9 Raymark OU3, CT

1.3.2.6 Miscellaneous Activities

The following activities also occurred on the Raymark Facility:

• Coal-fired Steam Generation - The Raymark Facility generated steam from August

1919, until the early 1940s. Steam was generated from coal-fired steam boilers.

The coal was delivered by rail directly onto the facility by a railroad spur that has since been removed. The coal was stored in the area surrounding the boiler house and heavy equipment transported it around the plant. No figures are available on the quantities of coal used,

• Steam Boilers The steam boilers were converted to oil in the early 1940s.

Number six fuel oil was stored in two 50,000 gallons tanks. No figures are available on quantities of oil used,

• Material Storage Numerous tanks located throughout the plant stored raw product, manufactured goods not yet turned into a product, and waste products remaining from the various manufacturing processes,

• Dry Trim Reclamation - The materials that were trimmed from the baked products

(dry trim) were stored outside under a roof on the asphalt pavement. The trim re-use process consisted of using hammer mills to pulverize the waste trim. As dry trim re-use occurred more frequently during later years of facility operations, particulates from this process were collected in a separate dry dust collector system and bagged for disposal,

• Finished Products to customers.

- These materials were stored on-site pending off-site shipment

RI99245F 1-10 Raymark OU3, CT

1.3.3 Environmental Permits

The Raymark Facility was subject to the requirements of both state and Federal Permits.

1.3.3.1 RCRA Activities

Raymark filed a Notification of Hazardous Waste Activity form on August 15, 1980, under the name of Raybestos Friction Materials Company. The activities delineated on this form indicated that the company generated, treated, stored, and disposed of hazardous wastes such as chlorinated solvents, acetone, formaldehyde, toluene, sludge from lime treatment generated from steel finishing operations, asbestos, acids, phenols, methyl ethyl ketone, and ignitable, corrosive, toxic wastes.

On November 12,1980, the notification was expanded to include the activities and quantities listed below for each waste activity. However, the quantities listed below were the total permitted quantities and not the actual quantities or units reportedly used at

Raymark.

• The Raymark Facility was permitted to process more than 2.5 billion gallons of lead-contaminated waste liquid each year in the on-site lagoons. It is estimated that 6 million gallons of the 2.5 billion gallons were treated each year.

• The Raymark Facility container storage area was permitted to handle approximately

23 million gallons of toxic, ignitable, corrosive, and acidic wastes each year.

• The Raymark Facility tank storage area was permitted to handle approximately

10 million gallons of waste yearly.

• The Raymark Facility incinerator was permitted to process approximately 240,000 gallons per year of toxic and ignitable wastes.

RI99245F 1-11 Raymark OU3, CT

In 1986, Raymark filed a permit application for the various Raymark Facility activities under the name of Raymark Industries, Inc. At that time, the original RCRA Part A notification was re-filed and the on-site activities and waste generated were significantly reduced. The activities described in the revised submittal included 7,040 gallons of liquid container waste, 150 cubic yards of solid container waste stored on the property, and an approximately 7-acre landfill on the property. The "landfill" was comprised of the lagoons previously located along the southern boundary of the Raymark Facility. Each of these activities appeared to include the handling of ignitable, toxic, corrosive, and toluene-contaminated wastes.

The facility closed in September 1989. In 1990, pursuant to a RCRA 3007 information request, Raymark indicated it still had significant quantities of waste and unused products remaining on-site. Some of these waste products were 400,000 gallons of asbestos slurry in tanks and 1,700 cubic yards of unfinished asbestos product. These wastes were removed from the Raymark Facility between 1990 to 1994.

During the operations of the Raymark Facility, wastewaters were routed into four lagoons.

Three of the lagoons stopped receiving waste in 1984, and were temporarily closed in

December 1992 and January 1993, under an EPA order. The fourth lagoon was temporarily closed in 1994. In 1993, on-site storm water was rerouted around Lagoon

No. 4 so the storm water no longer discharged into Lagoon No. 4. The facility cleanup/remediation was conducted under the CERCLA program, and the on-site sources

(lagoons, tanks, incinerator) have been removed and/or remediated as part of the long-term solution.

1.3.3.2 Wastewater Activities

The Raymark Facility had a 2.5 million gallon per day water and waste water discharge flow from the plant operations into the lagoons for discharge into Ferry Creek. This discharge was permitted under the State of Connecticut National Pollution Discharge

Elimination System (NPDES) program from the early 1970s until the early 1990s, with

RI99245F 1-12 Raymark OU3, CT volumes decreasing as plant activities were reduced. The activities permitted included:

acid treatment plant wastewater, dust collection system wastewater, noncontact cooling water, and solvent recovery plant wastewater. A separate permit was issued for an extraction well, which was installed on-site to remove groundwater contaminated with toluene from the aquifer which was discharged to the sanitary sewer. The toluene contamination was the result of a spill that occurred on site in 1984.

1.3.4 Study Area Description and Setting

The area identified as the study area for this Area I Rl includes Ferry Creek, other ecological areas, and adjacent properties impacted by the Raymark Facility soil-waste.

Originally, the OU3 area was defined as the commercial properties (Morgan Francis, Spada, and the Housatonic Boat Club) where Raymark-type waste was known to have been deposited. The OU3 area was expanded to include Ferry Creek and surrounding wetlands based on analytical results of surface water and sediment sampling conducted in the creek. The proximity of additional commercial and municipal properties that may also have received fill from Raymark waste increased the scope of the OU3 area to its present configuration (Figure 1-2). Because additional information was needed on these parcels, EPA decided to separate the OU3 areas into three study areas. This Rl contains information on Area I, which includes subareas A-1, A-2, and A-3. These locations are downgradient of the facility and may have been affected by wastewater discharge, stormwater drainage, surface water runoff, manufacturing waste direct deposition, and groundwater contaminant migration. The name designations used for locations and properties in this report are those that have become convention for the study area, as established by EPA.

Ferry Creek is located approximately 500 feet west of and parallel to the Housatonic River.

It flows south from the Interstate 95 overpass through the Morgan Francis Property, under

East Broadway Street and Ferry Boulevard, through the Spada Property, to the non-functioning flood control barrier (spring-loaded sluice gate system that is stuck partially open by debris) at Broad Street, and discharges into the Housatonic River. The OU3 area

RI99245F 1-13 Raymark OU3, CT also includes "other ecological areas impacted by Raymark Facility waste", which are defined by the delineated wetland boundaries along Ferry Creek; the delineated wetland boundaries along the Housatonic River, the Housatonic Boat Club and Beacon Point Road

(north and south of the boat launch); the wetland located adjacent to and south of 1260

Elm Street, Lot K; and the Selby Pond Site, located south of the intersection of Sratford

Avenue and Lockwood Avenue. Wetlands have been delineated throughout the study area. The Area I study area is comprised of the following properties;

• Subarea A-1 (Upper Ferry Creek - Morgan Francis Property) is located approximately

600 feet south of the Raymark Facility property. The boundaries consist of Interstate

95 to the north and northwest, residential properties along Blakeman Place to the west.

Ferry Boulevard and East Broadway Street to the east and northeast, and residential properties along Harris Court to the south. It encompasses a portion of Ferry Creek, which flows south from Interstate 95 to Ferry Boulevard; some commercial properties that EPA refers to as Salce Construction, Preferred Products, Shock's Autobody, and the Morgan Francis property; and the State of Connecticut properties near Interstate 95 and the triangle-shaped parcel of land between Ferry Boulevard and East Broadway

Street. It is noted that "clean" fill was placed on a portion of the Morgan Francis property in Subarea A-1. Subarea A-1 covers approximately 11.1 acres, including approximately 0.44 acres of wetlands (including the creek channel). The upland vegetation at the Morgan Francis property consists of early successional open field vegetation, with areas of shrubs and trees along the property boundary fenceline and along the Ferry Creek channel. Wetland vegetation along Ferry Creek in this area is sparse since much of the creek channel is rip-rapped and has steep-sided banks. The

State of Connecticut properties near Interstate 95 and the triangle-shaped parcel of land between Ferry Boulevard and East Broadway Street consist of mowed grass areas. A small swale (approximately 500 square feet), dominated by common reed is present in the triangle-shaped parcel. The commercial properties (Salce Construction, Preferred

Products, and Shock's Autobody) are unvegetated developed properties, with the exception of landscape plantings. The area surrounding the buildings on these commercial properties are typically covered with pavement or gravel.

RI99245F 1-14 Raymark OU3, CT

• Subarea A-2 (Upper Ferry Creek - Commercial Property) is located approximately 50 feet east of Subarea A-1. The boundaries consist of Ferry Boulevard to the west. Ferry

Creek and an undeveloped lot to the south and east, residential properties along Willow

Avenue to the north, and Broad Street to the south. It encompasses numerous commercial properties that EPA refers to as the Blue Goose…