The proposed I-95 Exit 33 Interchange project that would add a new northbound and southbound ramp in and out of Stratford has received more attention after a group of Milford and Stratford residents expressed opposition to the project. Milford residents say their primary concern stems from a potential loss of business in Devon, just over the Washington Bridge. But some Stratford residents say the proposed project highlights a much larger problem — the contaminated groundwater actively flowing underneath the site of the potential Exit 33 northbound ramp and residential properties near Ferry Boulevard.
The Environmental Protection Agency (EPA) has classified Raymark-contaminated groundwater and indoor air extending out from the original Raymark facility (Operable Unit 1/OU1), now the Stratford Crossing shopping center, as Operable Unit 2 (OU2). According to the EPA’s 2005 remedial investigation, the OU2 area “encompasses approximately 500 acres. … Half of these are commercial in nature, containing highways and business activities; the remaining area includes residences and water bodies.”
Regarding the proposed Exit 33 northbound ramp site, Ron Curran, who has overseen the nine Raymark operable units in Stratford for the Connecticut Department of Energy and Environmental Protection (DEEP) since the mid-1990s, confirmed that a “major portion of OU2 does move over the area.”
While Curran has been given a cursory overview of the proposal, he has not yet received an official detailed project proposal that would indicate whether the construction would interfere with the groundwater flowing through OU2. Curran said that as a matter of procedure, a groundwater investigation will need to be performed before any project proceeds.
Curran said OU2 is currently under a five-year review, with results expected in 2015. Curran said he does not expect much variation from past results, pointing out that unless new technology is brought in to address the leaching, contamination will more or less stay the same and could take “hundreds of years” to filter out completely.
When asked if there are any plans to address the current groundwater flow or contamination, Curran said there are not.
Beneath homes
The Action Memorandum Regarding Indoor Air, which the EPA’s project manager, Ron Jennings, co-authored, states: “Liquid wastes containing volatile organic compounds (VOCs) were routinely placed into numerous on-site lagoons which discharged to groundwater and nearby surface waters (like ponds and streams). In addition, there were many solvent spills (including trichloroethylene) at the [Raymark] facility.”
The report, available for public viewing on the EPA’s Superfund website, also states that the “groundwater predominately flows from the facility toward the Housatonic River, directly underneath this residential neighborhood. The depth to groundwater underneath the homes is only about 10-12 feet below ground surface.”
Environmental action
OU2 has been a central part of the debate between Stratford residents and the EPA and DEEP over the last two decades. Two environmental advocacy groups formed, beginning with Stratford Action for the Environment (SAFE), in October 1999, as a direct result of the way the organization says the EPA handled the capping and consolidation of Raymark Waste (RW). Members say the groundwater (OU2) was never addressed and continued to pollute the surrounding area because RW was not handled properly at OU1.
SAFE members say they are leading the effort against Exit 33 in large part because of OU2, as they fear construction on-site could disrupt groundwater flows.
In 2007, a second organization, SaveStratford.org, began vocalizing residents’ concerns over renewed plans put forth by the EPA and DEEP to dig up and cap waste near residential properties. One of the founding members of SaveStratford.org, Tom Smith, has been active in discussions with the EPA and DEEP as part of the Raymark Advisory Committee (RAC) and subsequently as part of the Raymark Superfund Team (RST) mediation conferences, which included the EPA’s representative Jim Murphy, EPA’s Jennings, and DEEP’s Curran. Both committees disbanded without an agreement and without any actionable plan for the eight remaining operable units in town.
Plumes and dangers
Smith said this month in a written statement that “SaveStratford.org has not yet weighed in on the proposed exit 33 project as we are awaiting the EPA’s ‘Comprehensive Clean-up Plan’ which, after 15 years, we hope will begin to address the Toxic Plume that is emanating from the Raymark OU-1 site. With respect to the OU-2 (Toxic Plume) issue, our position is that the EPA needs to provide Stratford with a viable permanent solution that addresses the root cause of the problem (the actual plume itself) — not the half measures taken to date (i.e. ventilation systems and bureaucratic bungling. … The fact that it is now almost 2015 and they still have not completed a study which might give some insight into the magnitude and severity of the OU-2 Toxic Plume is frankly stunning and appalling.”
Smith further explained that SaveStratford.org’s position is that the “final remedy” the EPA and CT DEEP put in place at the OU1 site is hardly “final” because it did nothing to address the toxic leaching that required sub-slab ventilation systems in more than 100 homes in Stratford. Without these systems, according to both Smith and the EPA’s public 1,200-page 2011 Toxicological Review of Trichloroethylene, the contaminants from the groundwater, especially TCE, pose a potentially serious human health risk.
Jennings’ 2003 memorandum also stated that “[e]xposure to TCE in humans may cause, among other things, nervous system effects, liver and lung damage, and impaired heart function.”
Study of OU2 due
When asked about the promised study of OU2 referenced by Tom Smith, the EPA’s Jim Murphy said that a feasibility study for OU2 has been completed, but the report will not be available to the public until next year.
Jennings, who has been project manager for Raymark remediation in Stratford for the last 17 years, oversaw the feasibility study this year but was unavailable for comment. EPA spokesperson Jim Murphy said he did not believe a conversation was necessary at this time.
Commenting on the Exit 33 project and its relationship to OU2, Murphy said that complaints were a “red herring” and that there is “zero risk” of disrupting groundwater. “And even if they did encounter it, the DOT would handle it and contact us,” he added.
The DOT, OU2 and Exit 33
Though the Exit 33 project, which would see construction begin within the OU2 site, is only in the preliminary design phase, both Stratford Mayor John Harkins and the Connecticut Department of Transportation (DOT) are actively promoting it. The DOT says the department’s contractors will begin construction on the new interchange after the Moses Wheeler Bridge has been completed (estimated for 2017). In fact, the DOT’s director of communications, Judd Everhart, says the project “will begin in earnest,” with the private consulting group, STV, handling the environmental assessment in the area.
The DOT Department of Environmental Compliance’s Denise Young also said that “in general, the DOT is aware of the contamination in the area and has discussed the project with CT DEEP and US EPA. The DOT will perform soil and groundwater investigations to supplement the data already gathered by EPA in the areas of project construction and prepare plans and specs to minimize our impact.”
Stratford mayor
Marc Dillon, chief of staff for Stratford Mayor John Harkins, said, “The mayor is quite confident that any environmental factors will be considered and handled prudently by CT DOT, as the department does very well on each of its projects across the state. Those who are opposed to the project, which has widespread support throughout the region, are grasping at straws in an obvious attempt to mislead the public.”