John S. Barron Eric J. Appellof Elizabeth J. Austin M l r · John S. Barron Eric J. Appellof...

50
John S. Barron Eric J. Appellof Elizabeth J. Austin Dwighi F. Fanton William J. Weniel Staci H. Bachenheimer Ml Samuel A. Giliiland John F. Stafstrom. Jr. Lauren Gruber Seller Raymond E. Baldwin, Jr. Elizabeth C. Yen Timothy A. Bishop James W. \cnnidn Colm M. Gershon Alice Ann Carey Edward P. McCreerv. Ill Herbert H. Moorin Stephen A. Douglas David 0.jafk^on LeeAnn Solomon Christ Kevin C. Murphy PULLMAN & COMLEY Sandra Jarva Weiss G. Whitney Biggs Diane E. Greenfield >> Michael G. Procror Grove W. Sioddard Lira J. Hecht Atttymeys At Lau' Deborah S. Breck Douglas A. Strauss Coleen Hurlie-Dunn Andrew P. Weiss James B. Stewan Neil A. Lippman Superfund Records Center Thomas J. Byrne Jeffrey V. McCormick Joseph M. Lodato Ronald Case Sharp Peter W. Oldershaw Andrew j . McDonald Robert M. Wonneberger Kvrv.. <:7yf: Frank B. Cleary Christopher M. McKeon Nancy A. D. Hancock Collin P. Baron David Medina Raymond C. Bershtein Michael N. LaVelle Neil Y. Siegel r>^}y.AK:__yy\_^ -— D. Robert Morris James T. Shearin James P. White. Jr. Counsel Marshall J. Touponse Christine M. Niedermeier John R. Ward Mark 1, Fishman Frederick L. Comley Leslie A. Zackin rJanc\ DeFonce Lapera Huntley Stone Reply to: Bridgeport Tel. 330-2202 SDMS DocID 446561 December 18, 1992 Marilyn K. Goldberg U. S. Environmental Protection Agency P. O. Box 221470 Chantilly, VA 22022 Re: U. S. EPA 104(e) Information Request Regarding the Solvents Recovery Service of New England, Southington, CT Site Subject: The Bridgeport Metal Goods Mfg. Co. Response Dear Ms. Goldberg: Enclosed please find the response of The Bridgeport Metal Goods Mfg. Co. to the above-referenced U. S. EPA 104(e) information request. Please be advised, however, that the respondent. The Bridgeport Metal Goods Mfg. Co., objects to general instruction number three set forth in enclosure A-1. Section 104 of CERCLA does not grant or provide EPA with the authority to impose an ongoing duty to supplement responses. Moreover, any such instruction and the instruction contained in enclosure A-1 is arbitrary and capricious, indefinite and unduly burdensome. yery truly yours, evin C rphy KCM/mc Enclosure cc: Mr. Edward Cook CB9240100.1gol HSO M.AIN STREET P.O. BOX 7006 BRIDGEPORT, CT 06601-7006 (20-i) 5^0-2000 FAX (205) 576-8888 200 PEQLJOT AVENL E P.O. BOX 510 SOUTHPORT, CT 06490-0510 (203)254-5000 FAX (205)254-5070 ONE CENTURY TOWTR NEW H.AVEN, CT 06510-7000 (205)773-3006 FAX (203) 776-7075

Transcript of John S. Barron Eric J. Appellof Elizabeth J. Austin M l r · John S. Barron Eric J. Appellof...

  • John S. Barron Eric J. Appellof Elizabeth J. Austin Dwighi F. Fanton William J. Weniel Staci H. Bachenheimer M l Samuel A. Giliiland John F. Stafstrom. Jr. Lauren Gruber Seller Raymond E. Baldwin, Jr. Elizabeth C. Yen Timothy A. Bishop James W. \cnnidn Colm M. Gershon Alice Ann Carey

    Edward P. McCreerv. Ill

    Herbert H. Moorin Stephen A. Douglas David 0.jafk^on LeeAnn Solomon Christ

    Kevin C. Murphy PULLMAN & COMLEY Sandra Jarva Weiss G. Whitney Biggs Diane E. Greenfield >> Michael G. Procror Grove W. Sioddard Lira J. Hecht Atttymeys At Lau' Deborah S. Breck Douglas A. Strauss Coleen Hurlie-Dunn Andrew P. Weiss James B. Stewan Neil A. Lippman Superfund Records Center Thomas J. Byrne Jeffrey V. McCormick Joseph M. Lodato Ronald Case Sharp Peter W. Oldershaw Andrew j . McDonald Robert M. Wonneberger Kvrv.. ^}y.AK:__yy\_^ -— D. Robert Morris James T. Shearin James P. White. Jr. Counsel Marshall J. Touponse Christine M. Niedermeier John R. Ward Mark 1, Fishman Frederick L. Comley Leslie A. Zackin rJanc\ DeFonce Lapera Huntley Stone

    Reply to: Bridgeport

    Tel. 330-2202

    SDMS DocID 4 4 6 5 6 1 December 18, 1992

    Marilyn K. Goldberg

    U. S. Environmental Protection Agency

    P. O. Box 221470

    Chantilly, VA 22022

    Re: U. S. EPA 104(e) Information Request Regarding the

    Solvents Recovery Service of New England, Southington,

    CT Site

    Subject: The Bridgeport Metal Goods Mfg. Co. Response

    Dear Ms. Goldberg:

    Enclosed please find the response of The Bridgeport Metal

    Goods Mfg. Co. to the above-referenced U. S. EPA 104(e)

    information request.

    Please be advised, however, that the respondent. The

    Bridgeport Metal Goods Mfg. Co., objects to general instruction

    number three set forth in enclosure A-1. Section 104 of CERCLA

    does not grant or provide EPA with the authority to impose an

    ongoing duty to supplement responses. Moreover, any such

    instruction and the instruction contained in enclosure A-1 is

    arbitrary and capricious, indefinite and unduly burdensome.

    yery truly yours,

    evin C rphy

    KCM/mc

    Enclosure

    cc: Mr. Edward Cook

    CB9240100.1gol

    HSO M.AIN STREET P.O. BOX 7006 BRIDGEPORT, CT 06601-7006 (20-i) 5^0-2000 FAX (205) 576-8888 200 PEQLJOT AVENL E P.O. BOX 510 SOUTHPORT, CT 06490-0510 (203)254-5000 FAX (205)254-5070

    ONE CENTURY TOWTR NEW H.AVEN, CT 06510-7000 (205)773-3006 FAX (203) 776-7075

    file:///cnnidn

  • ENCLOSURE B

    Solvents Recovery Service of Nev England

    104(e) Information Request Form for Generators

    1. Name of Respondent: "nte Bridgeport Metal Goods Mfg. Co.

    2. Date Information Request Completed: December 18, 1992

    3. For each transaction listed on Form 1 (attached),

    identify by chemical name the type of waste material that the

    Respondent sent for treatment or disposal to the Site or sent

    with a transporter for treatment or disposal to the Site. If

    the chemical name is not known, please state the trade name

    and the name of the manufacturer. Also identify the

    transporter of each waste volume and identify who made the

    decision to bring the waste to the Site — the transporter,

    generator, or broker. Attach copies of all documents

    consulted, examined, or referred to in the preparation of

    answers to these questions.

    4. At the end of Form 1 and consistent with the format of Form

    1, identify and provide complete information on any

    additional transactions which do not appear on Form 1 or

    transactions which are in some manner incorrectlv recorded

    on Form 1. Attach copies of all documents which provide

    information on these transactions.

    5. If you are not the generator of any of the wastes

    attributed to you in the listing of transactions on Form 1

    (i.e., you sent waste materials to the Site for disposal or

    treatment that were generated by a person other than you),

    please complete steps a through d below:

    a) Provide the information requested for that transaction

    on Form 1;

    b) Highlight the transaction by placing an asterisk (*) to

    the left of the appropriate transaction date on Form l;

    and

    c) Provide the information requested on Form 2 (attached);

    d) Attach copies of all documents consulted, examined, or

    referred in to the preparation of answers to these

    questions.

    6. Please identify all persons consulted in the preparation bf

    the answers to these questions. Indicate their relationship

    to the Respondent (e.g., current employee - environmental

    manager, past employee - maintenance department, etc.).

    Attach extra pages if necessary.

    ^h^^

  • 6, ( c o n t i n u e d )

    Name:

    A d d r e s s

    Phone No.

    R e l a t i o n

    Name:

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Name:

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Name:

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Edward Cook

    The Bridgeport Metal Goods Mfg. Co.

    365 Cherry S t ree t , Bridgeport, CT 06605

    203-366-4701

    t o Responden t Current Employee

    Kevin C. Murphy, Esquire

    Pullman & Ccmley

    850 Main Street, Bridgeport, CT 06604

    203-330-2000

    t o R e s p o n d e n t Attorney

    Qxier Cyr

    85 OaJcwood Drive

    Monroe, CT 06468

    t o R e s p o n d e n t : Retired

    Alan Simpson

    4 Bruns Road

    Ansonia. CT 06401

    t o R e s p o n d e n t : Retired

  • 2

    6. ( c o n t i n u e d )

    Name: Warren T^hrens

    A d d r e s s 41 Sentinel Hi l l Road

    Milford, CT 06460

    Phone No.

    R e l a t i o n t o Responden t Retired

    Name: Mî ê Jones

    A d d r e s s : 1^ Robert Frost Drive

    Shelton, CT 06484

    Phone No.

    R e l a t i o n t o R e s p o n d e n t Retired

    Name: Dick Wanner

    10 Fox Hil l Road A d d r e s s :

    Woodbridge, CT 06525

    Phone No.

    R e l a t i o n t o R e s p o n d e n t : Retired

    Name: ^ony Dinice

    A d d r e s s : 25 Meadow Stree t

    Shelton, CT 06484

    Phone No.

    R e l a t i o n t o R e s p o n d e n t : Retired

  • ( c o n t i n u e d )

    Name:

    A d d r e s s

    Phone No.

    R e l a t i o n

    Name;

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Name:

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Name:

    A d d r e s s :

    Phone No.

    R e l a t i o n

    Ken Ryder

    11 S t r a i t s v i l l e Road

    Prospect, CT 06712

    t o Responden t Retired

    Frederick Deer

    44 Verna Road

    Monroe, CT 06468

    t o Responden t Retired

    Greg Farrington

    58 Overton Avenue

    Milford, CT 06460

    t o R e s p o n d e n t : Retired

    Juan Resto

    The Bridgeport Metal Goods Mfg. Co.

    365 Cherry S t ree t , Bridgeport, CT 06605

    203-366-4701

    t o R e s p o n d e n t : Current Bnployee

  • ( c o n t i n u e d )

    Name: Steve Gergely

    A d d r e s s The Bridgeport Metal Goods Mfg. Co.

    365 Cherry S t ree t , Bridgeport, CT 06605

    Phone No. 203-366-4701

    R e l a t i o n t o Responden t Current Employee

    Jack DeWitt Name:

    A d d r e s s : The Bridgeport Metal Goods Mfg. Co.

    365 Cherry S t ree t , Bridgeport, CT 06605

    Phone No. 203-366-4701

    R e l a t i o n t o Responden t Current Employee

    Bob Hull Name:

    Address: The Bridgeport Metal Goods Mfg. Co.

    365 Cherry Street, Bridgeport, CT 06605

    203-366-4701 Phone No,

    R e l a t i o n t o R e s p o n d e n t : Current Enployee

    Name;

    Address:

    Phone No.

    Relation to Respondent:

  • Please identify the person(s) completing this questionnaire

    and identify the relationship to the Respondent. Attach

    \ l 0 l f extra pages if necessary.

    Name: Edward Cook

    A d d r e s s : The Bridgeport Metal Goods Mfg. Co.

    365 Cherry S t ree t , Bridgeport, CT 06605

    Phone No. 203-366-4701

    Relation to Respondent: Current Employee

    Name: Kevin C. Murphy, Esquire

    A d d r e s s : Pullman & Conley

    850 Main S t ree t , Bridgeport, CT 06604

    203-330-2000 Phone No.

    Relation to Respondent: Attorney

    Name;

    Address;

    Phone No.

    Relation to Respondent;

    file:///l0lf

  • ( ( FORM 1 Pa% . 1

    Solvents Recovery Service of New England

    Bridgeport Metal Goods

    Transaction Gallon Waste Type (3) Nzune/Address Name/Description of Who

    Date (1) Volumq (2) of Transporter Selected the Sita (4)

    0 8 / 0 6 / 5 6 165 .00 tr ichloroethylene* not known* The Bridgeport Metal Goods Mfg. Co.*

    II ri 0 6 / 1 7 / 5 7 660 .00

    tl II 3 5 / 2 6 / 5 8 495 .00

    0 5 / 2 6 / 5 8 330 .00 II n

    t l I t

    0 1 / 2 3 / 5 9 550 .00

    It t t

    0 1 / 2 3 / 5 9 330 .00

    II 11

    0 2 / 1 5 / 6 0 9 3 5 . 0 0 ft tr

    1 0 / 1 9 / 6 0 8 8 0 . 0 0

    0 9 / 2 1 / 6 1 330 .00 II n

    1 1 / 1 2 / 6 2 385 .00 ft It

    *See attached sheet

    Notes:

    (1) The transaction date refers to the date the waste was delivered to SRSNE. This

    date may differ from the date the waste left the generator's facility, (particularly

    if the transaction was brokered by another party), and therefore may not match exactly

    with your records. EPA expects you to make your best efforts to correlate your

    records with EPA's documents. This is to prevent double-counting of shipments in

    EPA's volumetric ranking.

    (2) All gallon volumes are waste-in transactions to SRSNE.

    (3) Please state waste type by chemical name. If the chemical name is not known, please

    state the trade name and the manufacturer's name.

    (4) e.g., XYZ Chemical Company - generator; ABC Waste Trucking - transporter;

    EFG Waste Disposal Service - broker.

  • ( ( FORM 1 i S o l v e n t s Recovery Se rv i ce of New England

    B r idgepor t Metal Goods

    Transaction

    Date (1)

    09/30/63

    10/20/64

    07/30/65

    02/17/66

    10/18/66

    06/20/67

    06/19/68

    05/16/69

    04/30/70

    03/03/72

    12/10/73

    11/06/80

    Gallon was te Type (3) Name/Address Name/Descript ion of Who Volume 121 of T r a n s p o r t e r Se l ec t ed t h e s i t a (4)

    385.00

    330.00

    275.00

    385.00

    330.00

    385.00

    385.00

    330.00

    385.00

    385.00

    220.00

    1,100.00

    trichloroethylene^ not known* The Bridgeport Metal Goods Mfg. Co.

    II '

    II *

    11

    11

    11 *

    II

    11

    II

    1,1,1 Trichloroethane*

    1,1,1 Trichloroethane*

    1,1,1 Trichloroethane*

    *See attached sheet

    http:1,100.00

  • ( FORM ( ADDITIONAL TRANSACTIONS

    S o l v e n t s Recovery s e r v i c e of New Eng land B r i d g e p o r t M e t a l Goods

    Transaction Date (1)

    G a l l o nVolume

    Wasta (2)

    Typa (3) Name/Address of T r a n s p o r t e r

    Nzune /Desc r ip t i on of Who S e l e c t e d t h e S i t e (4)

    Question 5 not applicable.

  • ( < (

    FORM 2

    Solvents Recovery Seirviee of New England

    Transactions Involving Waste Not Generated by Respondent

    Transaction Gallon Neune and Address

    Date Volume of Generator

    Question 5 not applicable.

  • Regarding "waste type" and site selection, no specific

    document and no specific person was able to provide a specific

    response to this recjuest. Rather, the responses to this request

    are drawn from documents and institutional memory regarding the

    type of equipment in-use and chemicals used at the Bridgeport

    facility.

    In an effort to provide responses to this, records were

    reviewed from the accounting and purchasing departments as well

    as the on-site laboratory.

    Accounts payable vouchers, paid invoice vouchers, freight

    bills and shipping/receiving documents are retained for six (6)

    years plus the current year. Thus, the accounting department

    provided no relevant information.

    Purchase order copies and purchase requisition copies are

    retained for two (2) years plus the current year. Thus, the purchasing department had no relevant information.

    Laboratory records provided no specific detailed information, but did provide general information regarding materials in use during approximate periods of time. See

    Exhibit A documents.

    Given the lack of information developed by the document

    review, a number of parties were contacted or interviewed. See

    Response to Question 6 and Exhibit B.

    In addition, the documents identified as Exhibit C were

    also consulted, examined or referred to in preparing answers to

    this request.

  • AXTON-CROSS CO.

    H E A V Y l |Bn i | l C H E M I C A L S

    S H E L T O N • C O N N E C T I C U T

    September 1 $ , I96I

    Bridgeport Metal Ooods Mfg. Oo.

    365 Cherry St.

    Bridgeport, Oonn.

    Attn I Mr. Olmer Cyr

    Dear Olmer t

    In aooordance with our conversation of yesterday I wish to confirm the p r ices we were ta lk ing about.

    The p r i ce of I . O . I . Triohloroethylene (HD Qrade Neutral Stabil ized) In tankwagons (2000 gallons) F.O.B. your plant ia |10 .50 owt.

    This material meets a l l U.S. specif icat ions and the Military specif icat ion MIL T-7003. I t i s s t ab i l i zed wllh the same system used by a l l other Trichloroethylene being produced today.

    In view of the coming events the savings you would r e a l i s e would be too great to turn down. At the present p r ice you would ahow a savings of I150.OO each load or |750.00 per year and under the new October I s t p r i c e , you would save 1300.00 per load or |1500.00 per year .

    I am sending the complete specif icat ions and pa ten ts covering the s t ab l l i x i ng system Jus t in case any questions a r i s e .

    I know t h i s mater ia l wi l l do your Job because people in your.< f i e ld have been using I . C . I . Trlchlor for a number of years and have been not only t rouble f ree , but saving a considerable amount of money doing so .

    If I can be of any fujrther help on t h i s item, p lease l e t me know.

    Very t r u l y yours,

    AXr(3N-CR0SS GOMPAMT

    r . L. AnTJier PLDthb Inc.

  • U L k ^ a i * t ^ .. jt^i ' iO'^yi*^-^-'*^

    DETREX CHEMICAL INDUSTRIES, INC. p . O. BOX s o t

    \ DETROIT, MICHIGAN 48232 ANCA COOI II)

    TILtPHONI •M.*M« Februa ry , 1965

    '^••'Js**

    Gentlemen:

    Exper ience has taught us how to save you a lot of money in your me ta l cleaning operat ion.

    Over the y e a r s , our s to re of knowledge about degreas ing has been used to save our cus tomer s thousands and thousands of d o l l a r s .

    New types of degreas ing equipment, - - improved maintenance p r o c e d u r e s , and be t te r solvent, singly or col lect ively, will reduce cos t s 257o or m o r e .

    I'd like to suggest that you make use of this exper ience and know-how a t your ea r l i e s t convenience. T h e r e is no charge for a thorough examination of your c u r r e n t methods and Det rex field engineers a r e the most qxialified in the indust ry to give you logical , intelligent, cost saving answers on meta l cleaning.

    Your compet i tor won' t wait and w e ' r e ready and anxious to help you.

    Very t ru ly yours ,

    DETREXT3HEMICA USTRIES. INC.

    Jert W. Clark Sales Manager Industr ia l Sales

    RWC/jf

    enc .

  • m^y^yy . ^ j e y ^ t y ' ; ^ . > / y : , .

    ^iii^r.-MTi'George T. Lundgren

    ^i^^BOX:T • • • ^ y '"' .̂̂'•:

    •'.

  • / 7 / « ^ "

    / : m THE BRIDGEPORT AlETAL GOODS A1F6. CO. M ENGINEERING DEPARIMENT

    INTER-OFFICE MEMORANDUM

    TO: R . L . Wanner

    FROM: K.D. Hlgglns

    DATE: September 21, 1978

    SUBJECT: NEW DEGREASING EQUIPMENT FOR DEPARTMENT A AND REPLACEMENT

    OF HAilD DEGREASERS AND SPIRAL WASHING MACHINE IN DEPARTMENT 6

    The purpose of this report is to review a quote dated 8/12/76

    and 8/13/76 for two new degreasers far Department 2 and A.

    Department if2

    The degreaser recommended is a barrel type with a capacity of

    approximately 110 cubic feet of work per hour. Based on our

    present work load of flashlights and cups, the equipment will

    have approximately 50% utilization^ but is required because

    of flashlight size. However, a smaller machine would be only

    $1,200 cheaper and would be questionable as to how well It

    could handle 2 and 3 cell flashlight bodies. It should also

    be noted that almost all labor savings will be made with the

    purchase of this equipment and possible 50% of the solvent

    • savings. This unit will be equipped with a still to keep the

    solvent clean.

    In reviewing problems, those which had definite possibilities

    were: . . .

    1. Denting of flashlight bodies.

    With proper loading and unloading of equipment, parts

    should not dent.

    2. Cupped parts that are properly cleaned may.create a

    problem in the plunger. (During present cleaning oper

    ations, parts are given a final soap rinse.)' Fred .Deer

    and the writer feel this problem could be solved and will

    run a test in the next few days.

    ^ ^ f

  • /

    Page 2

    9/21/78

    3. Parts not cleaned In our present equipment may be

    difficult to loadon buff chucks. We now pot ash

    dip a large number of parts which are buffed and

    there are no apparent problems placing on buff

    chucks, according to Tony Denlse.

    The plus features are:

    1. A considerable reduction In cost of solvent over

    our present pit degreaser.

    2. Because of a more efficient operation, there will

    be a savings of one operator.

    3. Parts which are lacquered after plungers should

    not require an additional finishing operation in

    Department 37 (steel shells).

    Department i?A

    The degreaser recommended Is a tray type with a capacity of

    60 to 180 trays per hour. Our present unit runs about 120

    trays an hour. However, It Is not doing as good a job of

    cleaning as required. The new machine will handle the dally

    load of 800 to 900 trays In 8 hours. The new equipment will

    eliminate overtime to keep up with the buffing load. Because

    we plan on using Trichlorethylene Instead of Trichloroethane,

    we will increase cleaning capability tremendously. The new

    unit has more sprays, better filtering accessories, and an

    oversized still to Insure absolute cleanliness of solvent.

    The two degreasers will be tied into a carbon adsorber which

    will reclaim the vapors from the cleaning operation. It will

    return 80% of all solvent and remove 95% of all solvent from

    the vapors. The equipment will conform to OSHA standards

    .warranted by Baron-Blakeslee. If the carbon adsorber does not

    perform to percentages stated within one year, Baron-Blakeslee

    will allow return of equipment for a restocking charge of 20%.

    There are a few jobs now done in the spiral washer in Department

    33 which will have to be done elsewhere (bulb holder and 5A90).

    These parts require lubrication after cleaning and will have to

    be greased, probably In Department 37.

    The following Is a breakdown of cost for.equipment. As of this

    writing, we do not have installation cost.

  • Page 3

    9/21/78

    1 - 162ATH-LLV Baron-Blakeslee

    barrel degreaser complete

    with still $A8,511

    1 - TH-VSS5V tray degeraser

    complete with still $63,69A

    1 - carbon adsorber CAV6 $29,300

    Haterial handling equip

    ment for barrel degreaser $ 2,500

    TOTAL $1AA,005

    Savings based on '76, '77, and '78 solvent usage of

    Trichloroethane at a cost of $2.81 per gallon, present price,

    with an assumed savings of 70% (warrantee is 80%) is $35,'A30

    per year.

    In addition, we save a LG-10 man In Department 33 and over

    time in Department A to keep up with tray work. Savings Is

    $10,908.

    Recap on Savings;

    Solvent savings $35,A30

    Labor savings $10,908

    Steel parts - now need 2

    operations befor lacquer,

    which would be eliminated. $ 37A

    TOTAL SAVINGS $A6,712

    Therefore, write-off would be $1AA,'005 *-, ̂o

    $A6;712 = ^3.08 years.

    Still to be reported is installation and shipping charges.

    As soon as information is available, a final cost run down

    will be reported.

    Installation will be predicted on locating equipment in the present area occupied by P^ and if9 plunger. A rough layout is attached indicating adequate room. Also attached is a picture of the type of loading/unloading equipment required for barrel degreaser.

    ^ smk

    cc: W. Ahrens

    F. Deer

    R. Hull

    S. Palo

    J. Shelsky

    A. Simpson

  • ^/^^^ y.-jriy y~r^y/fn^y/y^-^ O^^J /

    June 29» 1972

    Bridgeport Metal Goods Box 3153

    Bridgeport , Cotin. 06605

    Attni Hr. AI Simpson,

    Deer Alt The following 1« our report of the ettrrey relatire to the application of Trichlorethylene In a Yapor degreasing process 9̂ xA oor efforts to assist you in oonforaAngc with the recently proaogulated Conoeotlout Departnenf~of KOTlronmental iToteotion regulations for ami)lent air q^uallty; We have given a o^siderable an cunt of though to tba situation at your plant and find, that where «e would baTC preferred to give you a simple straight forward reconmendatloa to switch from Trichlorethylene to "Blaco-Thane" (l,l«It Trloblorethane degreasing grade)| the fundaaental opexatlona of your degreasing processed and your storage facilities mitigate against this simple solution. In making the following reconoendatlona we want you to keep In mind several facta. (1) That the converaion from Trichlorethylene Is an absolute

    necessity. ~

    (2) Using the exempt aolYsnt (lfl»lf Trloblorethane) In rusted

    degreasing SQUlpment, with partially oorrodad ^Ivanlsed pipes,

    and removing moisture In a ayatem where there Is no

    functioning water separator Is almost certain to create the

    deoompoaltlon of tha Itlflf Trloblorothane oaualng considerable

    amount of rust and further corrosion of your equipment.

    (3) k n j storage •yitaa which has fli active potential of causing the oomlngllng of ltl»l» Trloblorethana and Trichlorethylene must be avoided} because the atablllser Intereactlon of these products will under most conditions yield an highly aoldlc degreasing system.

    W'

  • Mr, Al Simpson -2- 6/29/72

    Our recommendations for your oompllanoe with the aforementioned

    regulations are;

    I. Convert your Betrez oroes rod Model § VC325-155 S/R 21920 from Trichlorethylene to l«l*lt Trloblorethane at your next maintenance shutdown. All filters, filter pots, and pumps, end oartrldges, must be cleaned and drained of Trichlorethylene. All water separators must be drained of Trlchlor» aa must the still and the atlll boilers and water aepavbb^rs and transfer pumps, feed lines and tleat ocmtrol devices* We will readjust the steam pressure control to approximately 8 to 12 F3I and reset the safety vapor control to funptkn at the boiling temperature of l»ltlt Trloblorethane (l^^F){i''^The still, steam sweep valve, will have to be blocked off or removed from the system te prevent the possibility of steam sweeping still residues.

    Inspection of the Detrex cross rod degreasing systems yield

    two areas of potential difficulty. First the galvanized

    ooollng colls both In the still ani vepor degreaser. These

    did not look In first olsss C(mdltlon and will have to be

    watebed fairly closely for Increased corrosion. In the event

    of Aocellerated corrosion I auggeet we order new stainless

    steel colls both for the still and vapor degreaser as qtlokly

    as possible.

    Ve feel that it would not be prudent to attempt to drain and clean

    the exletlng 3*000 gallon vertical storage tank for 1«1.1»

    Trloblorethane service due to the fact that there Is a 4"

    dlfferentftAl between tbe bottom of tbo tank and the suotlonn

    line to the pomp. This mean* that there it aliteys a liquid

    level In the tank regardleaa of your best efforta to drain It.

    We also obcerve that there is no ole«B oat manway In tbe top

    - of tbe tank making bitoketing and dralolttg out lapraotlcal.

    Therefore, we eoggest that • 30OO gallon vertleal tank be

    Inatallad adjacent to your •zistlnr 3000 gallon tank and have thb

    new one equipped with a proper sllioa gel ittbreatbing vent drier,

    level gaugaa, and olean out oaixwayst This tank will be pluabod

    through a new pump into tbe existing lines leading to tbe De^ex

    cross rod vapor degreaser should give you the assurance of not

    oomlngllng your Trichloratjpylane and lfl»l« Trloblorethane.

    II. The open top Detrex vapor degreaser removing drawing

    compound from your steel oupa for tbe flash light program

    looks to be in ralAtive good oondltlon« with an Intact galvanized

    yt. side walls and coils. Bowever, «• adequate water separator

    ^ system ̂ anclttdad* Ve would iuggeat that thia degreaser be

    7 ^ started out with "BlaooAThaney, Iflfl* Trloblorethane, and

    ^ ^ Inspected very carefully for frve water. If our analysis Indicate

    •"^^ any quantities of t f % water in tha iystea ve will immedlstely

    recommend the fabrication of a water oooled stalnlaas steel separator before any deooaposltloa of the solvent takes.place. This vapor degreaaer would also be plumbed *« y ^ ^ existing lines into yoor nm^ur.n ' rmtrm *•«»

  • Kr. Al Simpson -3- 6/29/72

    III. The vapor degreaser currently Installed In yoor plating shop removing grease from copper and brass parts and used as a water sremovlng system Is in absolutely terrible condition end will, I understand, be replaced by a almllar vapor degreaeer located In your yard. The appearance of this degreaser In the plating area Indicates that the free water has been a common problem In your svstem and the oorroelon of tbe degreaser »nd aooessory system Is very much In tbe extreme. This degreasing

    r7 machine should be replaced not with the used, rusted, galvanized, a e g T ^ m t n looated In the yardg which Inoldently, has a small and inoperable water separator* but should with a new stainless steel, steam heated Segfeaaer equipped wltb proper water separating faollltlss. However, undet the assumption that you will use the machine In your yard • § a replacement for this d9gT9»M9r we definitely do not raooanend that Ifltlf Trlchlorethana be mied. Va aeriouily fear the advent of an hydrolysis reaction which would decompose the *Blaco-Thane** and cause excessive staining of yoir parte and corrosive and breakdown the deg#easlng apparatus*

    f

    Under these aforementioned oondltlons we feel ti most practical alternative is to convert this degreaser to Ferchlorethylene. Peroblorethylane is a non hydroldif chlorinated advent and Is stabils In the presence of water and can be a sure«»safe alternative to Trichlorethylene. This will not eauss tbe aelvent decomposition and therefore corrosion* It will be neoaaaary to increase the steam praasora eapabllitlee to a mxiaun of 60 P8I, Inetall the necessary presaure tegulatlbg valves to conform to normally ood engineering practices and eharge this machine with erchlorethylene, tfe anggeat tbat the old Trichlorethylene

    storage tank be used In this C B f taking precautions to • a a u r e

    that at much of tha Trichlorethylene aa that 1« in this system

    currently be removed and a new ahorgt of Farohlorethylene

    added t n top af It. The old pumping and handling system

    could be adapted to this appllcationi plumbing directly to this

    degreaser.

    There Is not doubt that the overall oonveraion of your plant

    processes would be slmpller if we could go 100^ to '^Isoo-Thane*,

    however, I seriously doubt that tba plating rooa degreeser

    should be converted to l»ltlf TTieblorethane* I feel that the

    rlak that you would be running is not acceptable*

    \ ^

  • Mr. Al Simpson -k^ 6/29/72

    The facility that you would thane have would be dual solvent

    system o r dual solvent storage tanks. We feel that combined tankwagons deliveries can be handled at a satisfactory market

    pries.

    Tbe other facet of our bulk conversion sertloe Is to monitor

    the acid acceptance and aolfture ccmtent of your degreesti^

    process on a continuing basis for a period of three months

    assuring that the advent stability and acid acceptanoe

    balance are Intact for tble ftart«up period. We are

    prepared to aaslst you In this conversion at your convenience

    and look forward to hearing from you in the very near future.

    Very truly yours,

    THS HtmBAfiD^HALL CH£HICAL CO.

    George V. D a v i s / / Vice President ^ '

    GWD/kw

    CCl Tony Nardella

    Harry Glordlnao

    /

  • 37 7 ̂ '̂ (T/̂ s /̂̂

    ((

    N

  • S.R.S.N.E./C.E.R.C.L.A. - 1955 thru 1980

    Proposed Interview Listing

    Past Employees:

    Omer Cyr

    Alan Simpson

    Warren Ahrens

    Mike Jones

    Dick Wanner

    Tony Dinice

    Ken Ryden

    Fred Deer

    Greg Farrington

    Current Employees

    Juan Resto

    Steve Gergely

    Jack DeWitt

    Bob Hull

    (Questionnaires mailed 11/24/92)

    Employment Response

    Period Received

    1947/1989 Purch Mgr Retired 12/18/92

    1960/1990 Chemist Retired 12/1/92

    1956/1988 Eng Mgr Retired 12/1/92

    1970/1987 Buyer Employed No Response

    Elsewhere

    1973/1982 Plant Mgr Retired No Response

    1978/1986 Supervisor Employed No Response

    Elsewhere

    1983/1987 Engineer Employed No Response

    Elsewhere

    1974/1987 Employed No Response

    Elsewhere

    1972/1989 Eng Tech Employed No Response

    Elsewhere

    Interview Conducted

    1970-Present Supervisor 12/3/92

    1943-Present Methods Eng 12/4/92

    1975-Present Mgr Q.C. 12/8/92

    1953-Present Planner 12/8/92

    /y&^t^

  • M E M O

    To: Ed Cook

    From: John M. Zaczynski, Jr.

    Date: November 10, 1992

    Subject: Conversation with Al Simpson Regarding Shipments of

    Trichloroethvlene/1,1.1 Trichloroethane during the

    period 8/6/56 - 11/6/80.

    Discussion: Called Al Simpson ~ 2:20 PM 11/9/92 regarding the

    above topic. The following is a summary of what Al had to say:

    1) During the period of time 8/6/56 - 11/6/80 BMG used

    Trichloroethylene initially and then switched to

    1,1,1 Trichloroethane. (Al was at BMG 1960-1990.)

    2) The degreasing operation was located at the north wall

    on the first floor of the buffing department.

    3) The degreasing operation was small and had a still

    associated with the degreaser.

    4) The degreasing solution was sent out for

    recycle/reclaim. The solution received by BMG was

    recycled/restabilized solvent. Solvent came from

    recycler.

    5) Solvent sent for recycling consisted of degreasing

    solvent and a large amount of buffing debris from the

    degreaser stil1.

    6) Minimum number of drums per shipment was 3-5 drums.

    7) No uniform Hazardous waste manifests were used during

    this period of time.

    Conclusion; Shipments of Trichloroethylene/1,1,1 Trichloroethane

    will have to be tracked via shipping papers. Purchase Orders,

    receiving information on recycled solvent, etc.

    JZ/lc

  • Page 1 of 2 /xCc/ '̂̂ /

    E>AST Al>nD CURRE3MT E2«IE>LOYEE Q U E S T I O N N A I R E

    Subject: Shipment of Haste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period L955 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time period.

    Employee Name L O A v 'f-Vug.CiO

    Employment Period \̂ .

  • Page 2 of 2

    Question(s) ! Response(s^

    5) Do you remember the names of 1 S) KJ 0

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste 6) tJO

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes,' 7)

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes," 8)

    do you recall the name(s) of

    transporters or "brokers? !

    9) If the answer to Q6 is 'yes,' ! 9)

    how and why was the company

    (site) chosen for use by BMG? I

    Was it recommended by another I

    waste generator, the trans- I

    porter or broker, or others? I

    10) In respect to all the above | 10) questions do you recall the I name of anyone who might be | of added assistance in our I endeavor to provide the 1 b: E> d-i^cJi^-.. U.S.E.P.A. with information I

    re this site? 1

    General Remarks:

  • Page 1 of 2 Wycy E>AST A N D C U R R E N T E1-UPL.OYEE Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1355 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time period.

    Employee Name ^ y 7 7 ^ / ^ 7 T ' C ^ Y / ^

    Employment Period A / / / / ^ ^ — ^ r / ^ 7

    Position(s) /^cZ/ec^/Z^SyA/y?-

    Ouestionfs) Response(s).

    ^) Tfi/cH.

    1) What oarts cleanino solvent(s)

    were being purchased?

    c ) ry/y^yye^^

    2) What enamel and lacquer 2) ^ / V A / ^ ^

    related solvent(s) were being

    purchased?

    3) To assist your memory in Ql 3) y^^^' ^ ^ ^ ̂ 'were they

    a) Trichloroethylene

    b) 1,1,1 Trichloroethane

    (Methyl Chloroform)

    or c) Something else?

    4) Do you recall what the 4) f7o

    purchased quantities and time

    periods were with respect to

    Ql/3 and Q2?

  • Page 2 of 2

    0uestion(5)

    5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes,

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes,'

    do you recall the name(s) of

    transporters or "brokers?

    9) If the answer to Q6 is 'yes,'

    how and why was the company

    (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above

    questions do you recall the

    name of anyone who might be

    of added assistance in our

    endeavor to provide the

    U.S.E.P.A. with information

    re this site?

    General Remarks:

    ResponseCs)

    5) / 7 o ^ ^ ^ ^ ^ ' ^ ' ^ ^ ^

    i>^7-ye.£:y^

    ^y^/^y^/Jy- - C:>y^yy^^

    6) y£-s

    7) /7o

    8) y/o

    9) TI/^/'/Loi/^P SoiJi^y^^

    10 ) y y ^ / ^ ̂ Sf^rfyy>So ^^

    /^c^^eys. X ^ ^ ^y/^^ysr ^/yo iO/9s -o^s/

  • Pa3e__l..pf_2

    E>JVST 2VND CURFtEaSIT E t 4 F L O Y E E Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1955 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time iperiad,

    Employee Name

  • Page.. 2..of .2

    1 ^ ^ ^

    Questionfs)

    5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes,

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes,'

    do you recall the name(s) of

    transporters or "brokers?

    9) If the answer to Q6 is 'yes,'

    how and why was the company

    (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above

    questions do you recall the

    name of anyone who might be

    of added assistance in our

    endeavor to provide the

    U.S.E.P.A. with information

    re this site?

    General Remarks:

    Interview conducted by

    Edward Cook,

    Re3pon3e(3)

    5)

    / / ^

    6) /70

    7)

    A//A

    8)

    /V. ' / / )

    9)

    1 0 ) / ^

    Title: Facilities Engineer

    Date X7^^"^^y

    770

  • Page 1 of 2

    E»AST A N D C U R R E N T E M P L O Y E E Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1955 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning th^ subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time period.

    &4

    Employee Name >^^an^2g" C :7^3€^e^ ) r^

    Employment Period

    Position(s) ^^/c7ccy7?uj2J^ ^ C ̂ , ^ - ^s^ / ^ ^ j gy^

    Question(s) Respons e(s}

    1) what parts cleaning solvent(s)

    were being purchased? 1 ^̂ M P •

    2). What enamel and lacquer 2)

    related solvent(s) were being / ^ purchased?

    3) To assist your memory in Ql 3)

    were they

    a) Trichloroethylene //7A b) 1,1,1 Trichloroethane

    (Methyl Chloroform)

    or c) Something else?

    \

    4) Do you recall what the 4)

    purchased quantities and time A/€ periods were with respect to

    Ql/3 and Q2?

  • Page.. 2 .ot 2

    Question(s)

    5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes,'

    do you recall the name(s) of

    transporters or "brokers?

    9) If the answer to Q6 is 'yes,'

    how and why was the company

    (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above

    questions do you recall the

    name of anyone who might be

    of added assistance in our

    endeavor to provide the

    U.S.E.P.A. with information

    re this site?

    General Remarks;

    Interview conducted by

    Edward Cook,

    Response(s)

    5)

    / 0

    6)

    M^

    7)

    / ^

    8) /i^7/9'

    9)

    0

    A

    Title; Facilities Engineer

    Date;

  • Page 1 of 2

    P A S T A N D C U R R E N T E M P L O Y E E Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1955 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject tinie period.

    Employee Name / ^ y r ^ l S ^ //Z/OC^ ' y £ y ^ —

    Employment Per

    Position(s) f c yue / ^

    Ouestion(s) Responsefs)

    1) what parts cleaning solvent(s)

    were being purchased?

    2) What enamel and lacquer 2)

    related solvent(s) were being 7/o purchased?

    3) To assist your memory in Ql 3)

    were they

    a) Trichloroethylene

    b) 1,1,1 Trichloroethane

    (Methyl Chloroform)

    or c) Something else?

    4) Do you recall what the 4)

    purchased quantities and time

    periods were with respect to 7li) V Ql/3 and Q2?

  • Page 2 of 2

    0uestion(3)

    5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes,

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes,'

    do you recall the name(s) of

    transporters or "brokers?

    9) If the answer to Q6 is 'yes,'

    how and why was the company

    (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above

    questions do you recall the

    name of anyone who might be

    of added assistance in our

    endeavor to provide the

    U.S.E.P.A. with information

    re this site?

    General Remarks:

    Interview conducted

    Response(s)

    3^-/^ 5)

    ^f^^^^y^^-^^-f^-cC^ - c T o ̂ y x i r ^ y e . CCK^^

    6) ^ILe^ ^ ^ c ̂ /yy^

  • Page 1 of 2

    P A S T A N D C U R R E N T E M P L O Y E E Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1955 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time period.

    Employee Name -^C^Th^ ^ ^ " ^ ^ ^ ^ .̂ ̂£^^ Employment Period 7^7(7 T ^ j /7kf/9e^^

    Position(s) ^^. .c^y^^L-^^.^y^&yyT^ ' / i T^gj^^y- / ^ / j ^ ^ ̂ /Ay^^ey.

    Ouestion(s) Respon3e(s)

    1) What parts cleaning solvent(s) 1) ^^v- t̂r^ i^'^^y^.t. yy/fy-i'.i^ty'ryyyr^ were being purchased?

    2) What enamel and lacquer 2)

    related solvent(s) were being y:3!b y

  • Page 2 of 2

    Question(s) R e s p o n 3 e ( s )

    5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    /from?

    6) Do you recall any waste

    shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes,

    do you recall when or what

    amounts were involved?

    8) If the answer to Q6 is "yes,'

    do you recall the name(s) of

    transporters or "brokers?

    9) If the answer to Q6 is 'yes,'

    how and why was the company

    (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above

    questions do you recall the

    name of anyone who might be

    of added assistance in our

    endeavor to provide the

    U.S.E.P.A. with information

    re this site?

    General Remarks:

    6) No

    7) ^

    8) ^

    9)

    / ^

    10)

    ?^

    ^ U T t y ̂ i * ̂ y^^rnu^ yzC'r'P^73Co.r^»c

  • Page 1 of 2

    P A S T A N D C U R R E N T E2-IPLOYEE Q U E S T I O N N A I R E

    Subject: Shipment of Waste Material(s) from BMG (Bridgeport

    Metal Goods) to S.R.S.N.E. (Solvents Recovery Service

    of New England) site at Southington, Ct. within the

    period 1̂ 55 thru 1980 (inclusive).

    Introduction:

    Under C.E.R.C.L.A. (Comprehensive Environmental Response

    Compensation and Liability Act), the Southington Site is

    scheduled for remedial action within R.C.R.A. (Resource

    Conservation and Recovery Act).

    Regulations related to these Acts require that BMG provide

    the U.S.E.P.A. with information concerning the subject

    activities. The sources of this information shall include (but

    not be limited to) both past and current employees.

    May we respectfully request your response to the following

    questions, all of which relate to the subject time period.

    Employee Name ^ ^ ^ ^ Z ^ . S y ^ y z < ^ ^

    Employment Period ^//i>c> —v a/o/fo

    Position(s) ^ '^ r

    Ouestion(s) Response(g) ^ _

    1) What parts cleaning solvent(s) 1) >

    were being purchased?

    2) What enamel and lacquer 2) / 7>ciJ7' ^t-zyffve t ^ S .seyyT related solvent(s) were being purchased?

    3) To assist your memory in Ql 3)

    were they

    a) Trichloroethylene

    b) 1,1,1 Trichloroethane

    (Methyl Chloroform)

    or c) Something else?

    4) Do you recall what the 4)

    purchased quantities and time / / O

    periods were with respect to

    Ql/3 and Q2?

  • Page 2 of 2

    Question(3) Re3Ponse(s)

    5) ^/=:c^. y f / / ' / ' ^ ^ ^ ^ 5) Do you remember the names of

    companies that BMG purchased

    the Ql/3 and Q2 materials

    from?

    6) Do you recall any waste 6) y e ^ shipments being made to the

    subject company (site)?

    7) If the answer to Q6 is 'yes 1) M O do you recall when or what

    amounts were involved?

    ^ /^&-z^efvS- 7T/^-^ r ^ f i ^ ^ 8) If the answer to Q6 is "yes,'

    do you recall the name(s) of 2)oooyJ /= ' o ' ^ " ^ ' ^ ^ ̂ ^ transporters or "brokers?

    9) If the answer to Q6 is 'yes,' 9) ^ 77//AJA: 6 o y i Pt^^Ui^/^^^^O how and why was the company '2>er7=>7T S O ^ ^ ^ ^ T V t ^ ^' (site) chosen for use by BMG?

    Was it recommended by another

    waste generator, the trans

    porter or broker, or others?

    10) In respect to all the above 10) questions do you recall the name of anyone who might be oy*. j^TiS yfS^Sryf^y^S ^i^^y^OG of added assistance in our endeavor to provide the U.S.E.P.A. with information

    re this site?

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  • D e g r e a s e r Dept.??!^

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  • THE BRIDGEPORT METAL GOODS MFG. CO. Telephone 203 3 66-4701

    Fax 203 335-9378

    Telex 681-3312

    twDGEPORT, CONNECTICUT 06605365 CHERRY STREET

    November 1 7 , 1992

    Mr. F e r d C h m i e l n i c k i DETREX C o r p o r a t i o n P . 0 . Box 5111

    S o u t h f i e l d , MI 48086- 5111 iP

    i y :y7 /Dear Ferd,

    conversation X'off p.Further to our telephone 3ation\*o 11/16/911/16/922 p.m..

    concerning a DETREX Model VC-325-1S-S Degreaser, once owned by

    Bridgeport Metal Goods (BMG). The reason(s) I have requested a

    copy of the Technical Info Sheet for this machine concerns a

    data package we have been requested to prepare for the

    U.S.E.PsA. Region I Boston, MA.

    The data we are assembling relates to the years 1955 thru

    1980 (inc.) in respect to parts cleaning, using

    Trichloroethylene and 1,1,1 Trichloroethane.

    The Federal Agency is conducting an ongoing investigation of

    a site in Connecticut at which, during the indicated time

    period, a fully R.C.R.A./State Permitted Company was

    reprocessing these Halogenated Solvents,

    It is believed that B.M.G., along with over 1200 other

    companies, indirectly shipped material to this site at a

    deminimus level for purposes of reprocessing and/or recovery.

  • T H t BRlDGtPORT MtTAL GOODS MFG. CO. SHEET NO

    continued

    Page 2

    I am sure from the above Ferd, you can picture the overall

    data we are putting together for the Agency

    (i.e.) What Solvent we purchased. How much we purchased. When we purchased it, and of course provide them with an idea of how we used it the DETREX machine with its specific sump capacity etc. etc.

    Should226.

    you require further information please call me @ Ext.

    Your

    Edward Cook

    Facilities Engineer

    EC/lc

  • 199 WHITINQ STREET vwc NEW BRITAIN, CONN. 06051 ( /^.Sfa-'^y/^!^^ CRANE & RIGGING CORP.

    /

    NEW BRITAIN 203-225-9434 • FAX 203-225-7569 • WATS 1-800-533-9557

    -1 1 r

    S';2^7'/'^'^ Ce^-.. -.

    1—*Tr:^L».j.s«.--.i4-i'-f • '• ' P

    • PLANT RELOCATION • IN PLANT RIQQINQ Ert.1883 • HEAVY HAUUNQ i • INDUSTRIAL 8TORAOE ^ • STEEL n^BRICATION • SKIDDING AND CRATING • MILLWRK3HT SERVICE • MODUUR CONSTRUCTION n. ®• LOCAL A LONG DISTANCE SERVICES

    TRUCKING • CRANES UP TO 80 TONS

    «

  • ' • • ] ' . • ' : ' • \ - : \ j : n i'Ku;.! U h l K h X

    D E T R E X CORPORATION •4y

    P.O. Box 5111. Southfield, MI 48086-5111

    XECUrtve OFFICE TELEPHONE: (3)3)350-SeOO FAX: (3t3) 3Se-5B03

    DATE /^'/7-9^

    TIME

    PLEASE DELIVER THE FOLLOWING MATERIALS AS SOON AS POSSIBLE

    TO

    y)r I'dgepg^ f)lQ{aP FIRM Caos) 336-^31^ FAX ff

    NUMBER OF PAGES 4 (including cover page)

    FROM

    FIRM: T^d-Lrek

    Please notify Beverly immediately if not received properly at

    (313) 358-5800 Ext. 286

  • .1 r:.v..i ULifiLA

    D E T R E X CORPORATION

    P.O. Box 5111. Southfield, MI 48086-5111

    LXECUTIVE OFFICE TELEPHONE: 0 1 3 ) 3 5 B - 5 8 0 0 FAX: (313) 396 SBOS

    December 17 , 1992

    Mr. Kdward Cook

    FacilitiGS Engineer

    The Bridgeport Metal Goods Mfg. Co.

    365 Cherry Street

    Bridgeport, CT 06605

    Dear Ed:

    This is in accordance with our recent communications. Since

    this is a so-called "archaeic" category request, we encountered

    difficulty in locating any records whatsoever.

    We finally did locate a spec sheet which we feel will relate

    •̂•(••̂Lo the particular equipment. In reviewing the spec sheet, it

    provides information about the sump capacity (50 gallons chamber

    1, 35 gallons chamber 2, total capacity 85 gallons). This will

    specifically respond to your particular question in regard to that

    i Leiii.

    We hope this information will be of some assistance to you.

    Very truly yours,

    Ferd J. Chmielnicki

    Corporate Secretary

    and General Counsel

    FJC:bb

    enclosure

  • . 1 i .. . ;• . U t i r . L A

    VC325 - IS

    i l l

    MODEL VC325-IS My>r

    "tt r tl l - i

    Conveyorized Degreaser

    Vapor - Spray - Vapor

    Crossrod - Return-type

    Steam Heated

    August 1946

    DETREX CORPORATION

    DETROIT MICHIGAN

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