RAYMARK INDUSTRIES, INC.
On this page:
- What Is Being Done to Clean Up the Site?
- What Is the Current Site Status?
- EPA’s Involvement at the Site
- Sampling and Monitoring
- Operable Units (opens new page)
- Cleanup Progress (opens new page)
The 34-acre Raymark Industries, Inc. site is located at 75 East Main Street in Stratford, Connecticut. Raymark Industries, Inc. (Raymark) was a manufacturer of automotive brakes, clutch parts, and other friction components, primarily for the automotive industry. Raymark and its predecessors were located on a 34-acre parcel at 75 East Main Street in Stratford, CT. Raymark operated at this location from 1919 until 1989 when operations ceased. Raymark's manufacturing waste was historically disposed of as fill on the facility, but over time this waste material was also disposed of within Stratford at a minimum of 46 residential properties, and at numerous other commercial, recreational and municipal properties. In addition, several wetland areas in close proximity to the Housatonic River were also filled in with Raymark's manufacturing waste. The contaminants in Raymark's waste primarily consisted of polychlorinated biphenyls (PCBs), asbestos, lead, and copper; however, extensive VOC soil contamination also exists at the former Raymark facility. Extensive testing of soil, groundwater, soil gas, indoor air, and sediments throughout the Stratford community has been conducted by the EPA and Connecticut Department of Energy and Environmental Protection (CTDEEP). The total population within 4 miles of the site is approximately 145,000. No known public drinking water wells are located within 4 miles of the site; however, a few private water supply wells may exist upgradient of the former East Main Street facility.
Seed oysters are cultivated in the Housatonic River near some of Raymark's historical disposal locations and crabs and clams may also be harvested for recreational purposes in the area. Selby Pond, located adjacent to Ferry Creek and the Housatonic River, has warning signs posted that informs the public that eels from this pond may have high levels of PCBs.
The 34-acre former manufacturing facility at 75 East Main Street has been demolished, capped, and redeveloped into what is now known as the Stratford Crossing Shopping Center - which includes Home Depot, Shoprite, and Walmart.
The site is being addressed by area or Operable Unit. See What is Being Done for current status of each.
Operable Unit 1 - Facility
Operable Unit 2 - Groundwater/Indoor Air
Operable Unit 3 - Ferry Creek (Area I - Includes Upper Ferry Creek and Associated Wetlands
Operable Unit 4 - Raybestos Memorial Field (Ballpark)
Opearble Unit 5 - Shore Road
Opearble Unit 6 - Additional Properties
Operable Unit 7 – Ferry Creek (Area II - Includes Lower Ferry Creek, Selby Pond, and the Housatonic River Wetlands)
Operable Unit 8 – Ferry Creek (Area III - Includes Wetlands at Beacon Point and Elm Street)
Operable Unit 9 - Short Beach Park & Stratford Landfill
Vapor Mitigation Systems
What Is Being Done to Clean Up the Site?
During the summer of 1992, EPA built a temporary cap on a portion of the commercial property known as the Raybestos Memorial Ballfield. EPA began excavating contaminated waste/soil from 46 residential properties during the fall of 1993. This contaminated material was transported back to the Raymark Industries, Inc. facility where it was capped in place (see Operable Unit 1 discussion below). The residential excavations were completed in the fall of 1995 and property restoration continued into 1996. In addition, throughout 1993 and 1994, Raymark undertook a number of interim actions at its 75 East Main Street facility, including removing thousands of one cubic yard bags of asbestos and containers holding hazardous substances, temporarily capping four waste lagoons, and securing the facility. CTDEEP also undertook a number of interim actions on municipal properties between 1993 and 1994, including installing temporary caps and fencing at the Wooster Middle School and a portion of what is known as Short Beach Park. During 1994, CTDEEP also required several commercial property owners to restrict access to known contaminated waste areas through the installation of fences or pavement. In June 1995, CTDEEP excavated contaminated materials at the Wooster Middle School and brought all of this material back to the Raymark facility before August 1995 where it was also capped in place. Between 2003 and 2004, EPA and CTDEEP installed vapor ventilation systems in approximately 106 homes to address the potential intrusion of contaminated vapors into buildings. In 2014 and 2015, as part of Federal Aviation Administration safety upgrades at the Sikorsky airport property, EPA contributed a small portion of the funds and provided technical oversight to address an area that included known Raymark Waste. This property is part of the OU6 Additional Properties.
Operable Unit 1 - Facility
As a result of environmental investigations conducted by Raymark and EPA, a remedy for the manufacturing facility (OU1) was documented in a July 1995 Record of Decision (ROD). Shortly thereafter, in September 1995, the cleanup of the Raymark property began with the demolition of 15 acres of buildings and the placement of an impermeable cap over those 15 acres as well as over the remaining +/-20 acres of contamination on the property.
Cap construction was completed by EPA (working with CTDEEP and USACE) by November 1997. The construction of the Stratford Crossing Shopping Center began in the spring of 2001 and opened for retail business in early 2002. The 1995 ROD also included a source control action for groundwater that included a passive dense non-aqueous phase liquid (DNAPL) extraction system. The 2016 ROD for OUs 2, 3, 4, and 6 included a modification of the OU1 remedy to discontinue the DNAPL extraction system because of its limited effectiveness.
Operable Unit 2 - Groundwater
The groundwater study of the area, known as OU2, encompasses approximately 500 acres. Area groundwater has been classified by the state as non-drinkable, and there are no known active wells within the impacted groundwater aquifer.
Since 2000, EPA sampled the groundwater, soil gas, and indoor air in a residential area between Ferry Boulevard and the Housatonic River for chemicals disposed of at the former Raymark Industries, Inc. facility on East Main Street. These chemicals, called volatile organic compounds or VOCs, are present in the groundwater and can change from a liquid into a gas, migrate upwards, and then enter homes through the foundation. EPA identified several homes where this had occurred and, working with CTDEEP, installed sub-slab ventilation systems in nine homes in this area by January 2003.
In an effort to ensure protection of public health and also eliminate the continued need for environmental monitoring in this neighborhood, which was both expensive and intrusive, EPA signed a Time-Critical Removal Action Memorandum in 2003 for the installation of sub-slab systems in all of the homes throughout the affected area. A Health Consultation prepared by CTDPH (working with ATSDR) supported this action based principally on trichloroethene (TCE) exceedances in the area. The ventilation systems, which are similar to radon systems, draw air from beneath the foundation and vent it through a pipe near the roof of each house.
By the fall of 2004, installation of these systems was complete with approximately 100 homes receiving systems (installed by CTDEEP through a cooperative agreement with EPA). Long-term maintenance of the systems is being conducted by CTDEEP at no cost to the homeowners or tenants. At the time, a number of property owners in the area refused the systems.
In September 2016, EPA issued a Record of Decision (ROD) that includes the final cleanup remedy for OU2. The remedy addresses potential vapor intrusion through installation of vapor ventilation systems at approximately 20 properties, mostly residential, and assessing and addressing potential vapor intrusion risks at additional properties.
The existing passive DNAPL extraction system at the former Raymark facility (OU1) will be discontinued because of its limited effectiveness. EPA will not take further action at the OU1 source area, other than to continue the use and enforcement of an existing environmental land use restriction (ELUR) placed on the OU1 land records prohibiting activities that could compromise the integrity of the cap and also prohibiting borings and the installation of new groundwater wells without the permission of CTDEEP and EPA. Residential use of the property is also prohibited. In the downgradient area, EPA will also implement institutional controls to prevent the use of the contaminated groundwater plume that exceeds drinking water standards and the extraction of groundwater that could cause migration of the contaminated plume. Although public water is currently supplied to those living and working in the downgradient area and the local aquifer has been classified as GB (non-potable without treatment) by the State of Connecticut, institutional controls are needed to address and prevent potential future risk from contaminated groundwater in the OU2 plume, such as from installing drinking and groundwater extraction wells. Periodic groundwater monitoring will be performed to evaluate potential vapor intrusion, assess any potential changes in the extent of the areas of potential vapor intrusion and in the source and downgradient areas, and take action as needed.
EPA will also review the Site at least once every five years to assure that the remedial action continues to protect human health and the environment.
Operable Unit 3 – Upper Ferry Creek
Upper Ferry Creek, known as OU3, includes Ferry Creek and the surrounding wetland areas from approximately Interstate 95 (across from Homestead Avenue) southward to Broad Street. It encompasses approximately 33 acres which includes approximately five acres of wetlands.
A remedial investigation report for OU3 was completed in August 1999. The report concludes that fill and natural soils throughout OU3 are contaminated with asbestos, lead, copper, semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and dioxins. In some areas the level of contamination is high. Potential risks to human health, sediment-dwelling organisms, and those that are higher up the food chain (that feed on sediment-dwelling organisms) are a concern throughout the area.
In September 2016, EPA issued a Record of Decision (ROD) that includes the final cleanup remedy for OU3. Raymark Waste containing material and sediment containing contaminants of concern from the former Raymark facility will be excavated and either consolidated and capped as part of the OU4 remedy at the Raybestos Memorial Ballfield, or shipped to a licensed out-of-town disposal facility. More specifically, the remedy includes: excavation and removal of the top two feet of sediment from the channel of Upper Ferry Creek from Interstate 95 to the Broad Street bridge; excavation and removal to a depth of four feet of soil that meets the definition of Raymark Waste from the banks of Upper Ferry Creek; excavation and removal to a depth of four feet of wetland soil that meets the definition of Raymark Waste from abutting wetland areas; replacing excavated sediment and Raymark Waste with clean material; and restoration and revegetation of excavated areas with native species and restoration of wetlands.
EPA will implement institutional controls to limit future excavation, groundwater use, and other activities that could pose a risk, where necessary, conduct long-term monitoring and operation and maintenance, and periodically monitor groundwater, surface water, and sediment to assess the effectiveness of the remedy. EPA will also review the Site at least once every five years to assure that the remedial action continues to protect human health and the environment.
Operable Unit 4 - Raybestos Memorial Ballfield
The Raybestos Memorial Ballfield (the Ballfield), known as OU4, is located north of the former Raymark facility just over the Metro-North railroad tracks leading to New York City. It encompasses approximately 14 acres. Residential properties border the OU4 study area to the north/northwest. Town, commercial, and industrial properties are located to the northeast. A former inactive industrial facility (the Contract Plating site) abuts the area to the south/southwest.
OU4 was historically used as a gravel pit operation, then as a disposal area for industrial wastes. Contaminants found include asbestos, lead, arsenic, and polychlorinated biphenyls (PCBs).
In 1992, EPA installed a security fence around the area, installed a temporary soil cover, and sampled and removed drummed wastes at the Ballfield. This effort restricted access to the area as well as to the contamination found within the soil.
In 1999, EPA performed a comprehensive remedial investigation that included test pits, soil borings, monitoring well installation, an electromagnetic survey, and ground penetrating radar to determine the presence, location, and character of buried wastes. A remedial investigation report was completed in August 1999. The report concludes that fill and natural soils throughout the OU4 study area are contaminated with asbestos, lead, barium, zinc, arsenic, polychlorinated biphenyls (PCBs) and semi-volatile organic compounds (SVOCs). In most cases, the contamination is higher in the subsurface soils than in the surface soils. EPA currently estimates that approximately 111,000 cubic yards of Raymark Waste are present at the Ballfield. Potential risks are to human health. No ecological risks were identified.
In late 2014, the Town of Stratford received a $2.85 million grant to demolish and remediate the Contract Plating site. Contract Plating is a Brownfields site, which is outside of the scope of the Superfund site.
Vita Nuova, an independent redevelopment consultant, was funded by EPA to work with the Town and assist in the planning and redevelopment of various options for OU4; EPA and CTDEEP coordinated with the Town and Vita Nuova to ensure that OU4 cleanup objectives align with potential redevelopment opportunities. Vita Nuova also worked with the Town on redevelopment opportunities for the adjacent Contract Plating (Brownfields) site, as well as the adjacent Town Department of Public Works (DPW) site, and in November 2015, presented possible redevelopment plans for the area to the public.
In September 2016, EPA issued a Record of Decision (ROD) that includes the final cleanup remedy for OU4, a remedy that is consistent with EPA’s statutory requirements to select a cleanup plan that protects human health and the environment. Raymark Waste from OUs 3 and 6 will be consolidated at OU4 and capped along with the existing Raymark Waste already at the Ballfield. Any Raymark Waste that exceeds the available consolidation capacity at OU4 (as controlled by not exceeding a maximum cap elevation) and the more toxic waste from OUs 3 and 6 will be transported to an out-of-town licensed disposal facility. More specifically, this portion of the cleanup remedy is expected to involve the following activities:
- Removal of existing vegetation, buildings, debris, and other infrastructure;
- Construction of an access road from Longbrook Avenue through the former Contract Plating property to the Ballfield;
- Consolidation of excavated sediment and Raymark Waste from OU3 and OU6 with the existing 111,000 cubic yards of Raymark Waste on OU4;
- Construction of a permanent, low-permeability cap over the consolidation area to isolate contamination. The cap will be able to support redevelopment for commercial/industrial, municipal, and/or recreational uses. The top of the cap will not exceed a maximum elevation of 46 feet above mean sea level, and the majority of the cap will have finished elevations between 30 and 40 feet above mean sea level;
- Construction of storm water management features;
- Construction of a permanent or temporary (based upon input received from residents and property owners who live in this area and future design considerations) visual and sound barrier along the boundary with Patterson Avenue, Clinton Avenue, and Cottage Place;
- Construction of a permanent vegetated berm along the border of Patterson Avenue (however, if it is determined, following public input, that a permanent visual and sound barrier should be installed along the border with the Patterson Avenue residential properties, then construction of a berm would become unnecessary);
- Restoration of the property with vegetation and pavement as appropriate;
- Institutional controls to protect the cap, limit groundwater use, and other activities that could pose a risk; and
- Long-term monitoring and operation and maintenance.
EPA will also review the Site at least once every five years to assure that the remedial action continues to protect human health and the environment.
EPA’s cleanup plan will allow for the redevelopment of the currently unused and blighted Raybestos Memorial Ballfield and will address many commercial properties whose reuse has been hampered by the presence of Raymark Waste. This cleanup plan will respond to environmental hazards and allow properties to be used to their full potential, bringing economic benefits to the Town of Stratford.
EPA is committed to a cleanup that places primary importance on health and safety for abutting and nearby residents, for residents along any trucking route, and for the workers performing the cleanup work. EPA will develop the details regarding construction management and health and safety in plans created for each work area during the remedial design process. Through an enhanced outreach effort, EPA will continue to solicit input from the Stratford community as we develop these plans.
Operable Unit 5 - Shore Road
The Shore Road Area, known as OU5, is an approximately four-acre section of Shore Road near the Housatonic Boat Club and the former Shakespeare Theater that borders the Housatonic River.
Contamination was found in this area in 1993 and, as a temporary measure, CTDEEP covered the area with a plastic fabric barrier and six inches of wood chips. In early 1999, EPA found that the plastic fabric barrier was beginning to wear and that much of the wood chips had eroded. At the request of the Town of Stratford, EPA took steps to re-evaluate the risks posed by the contaminants in the area.
These steps included the completion of an Engineering Evaluation/Cost Analysis (EE/CA) report in June 1999 that documented risks to human health and the environment from asbestos and lead. As a result of these findings, EPA released an Action Memorandum in September 1999 and performed a removal action that included the installation of a revetment along the unprotected southeastern tidal areas, restoration of existing riverside revetments to limit exposure to underlying contaminated soils, capping of excavated soils, paving of driven surfaces and capped soils, and installation/restoration of utilities to allow maintenance without the threat of exposure to contaminated soils. These removal actions were completed in September 2000.
Future actions include monitoring of the area to ensure the integrity of the cap installed over contaminated soils and land use restrictions. EPA will also be evaluating whether additional actions are needed at OU5.
Operable Unit 6 - Additional Properties
The Additional Properties operable unit, known as OU6, consists of properties located throughout the Stratford. These properties, with commercial, recreational, or residential use, were constructed on top of locations where Raymark manufacturing waste was used to fill low lying areas in town. Each of these properties have been evaluated individually to ensure that unacceptable risks to human health or the environment are not present. A remedial investigation was completed in July 2005.
Since the completion of the RI, EPA has worked with the Town of Stratford and citizens groups in an effort to find acceptable cleanup approaches to address the contaminated properties. Agreement was previously reached for four of the properties and EPA issued a Record of Decision (ROD) in 2011 for the permanent cleanup of these four properties.
In September 2016, EPA issued a Record of Decision (ROD) that includes the final cleanup remedy for 22 remaining OU6 Additional Properties. This portion of the remedy includes excavation and removal to a depth of four feet of soil that meets the definition of Raymark Waste from these properties. Excavated material will be either consolidated and capped as part of the OU4 remedy at the Raybestos Memorial Ballfield, or shipped to a licensed out-of-town disposal facility. The remedy also includes replacement of excavated Raymark Waste with clean material, restoration of excavated areas to the pre-excavation condition, institutional controls to limit future excavation, groundwater use, and other activities that could pose a risk, where necessary, and long-term monitoring and operation and maintenance. If a property or parcel, beyond the 22 OU6 Additional Properties, is discovered in the future to contain Raymark Waste, such property or parcel may be responded to as described in the 2016 ROD. EPA will also review the Site at least once every five years to assure that the remedial action continues to protect human health and the environment.
Operable Unit 7 – Lower Ferry Creek (Includes Lower Ferry Creek, Selby Pond, and the Housatonic River Wetlands)
Lower Ferry Creek, known as OU7, includes lower Ferry Creek (from Broad Street to the mouth of Ferry Creek), Selby Pond, and the Housatonic River wetlands (located south and east of Shore Road). It encompasses approximately 44 acres of which approximately 35+ acres are wetlands and/or open water.
A remedial investigation report for OU7 was completed in November 2000. The report concludes that fill and natural soils throughout OU7 are contaminated with asbestos, metals, pesticides, semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and dioxins. In some areas the level of contamination is high. Potential risks to human health, sediment-dwelling organisms, and those that are higher up the food chain (that feed on sediment-dwelling organisms) are a concern throughout the area.
EPA is currently conducting a feasibility study of cleanup alternatives for OU7.
Operable Unit 8 – Beacon Point Area 2
Beacon Point Area 2, known as OU8, includes wetlands to the north and south of the Beacon Point boat launch area and wetlands off of Elm Street. It encompasses approximately 14 acres which are wetlands and/or open water.
A remedial investigation report for OU8 was completed in November 2000. The report concludes that fill and natural soils throughout OU8 are contaminated with asbestos, metals, pesticides, semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), and dioxins. In some areas the level of contamination is high. Potential risks to human health, sediment-dwelling organisms, and those that are higher up the food chain (that feed on sediment-dwelling organisms) are a concern throughout the area.
EPA is currently conducting a feasibility study of cleanup alternatives for OU8.
Operable Unit 9 - Short Beach Park & Stratford Landfill
Short Beach Park and the Stratford Landfill combined encompass the area known as OU9. The two areas together were historically used as a single landfill. The Short Beach Park Area is currently a heavily used recreation area for baseball, softball, soccer, and golf. The Stratford Landfill is no longer active.
Between 1993 and 1994, CTDEEP installed a temporary cap on a portion of Short Beach Park where Raymark Waste was found to be present. Additional investigations were conducted by EPA in December 2003 through February 2004 with a remedial investigation report completed in July 2005.
The RI found that there was no immediate risk to workers or recreational users of the park due to the presence of Raymark Waste. However, the RI also determined that if the use of the area changed in the future to a residential setting, unacceptable risks would exist because of the presence of Raymark Waste. Because of this, the RI identified the need to develop a permanent remedy for OU9 so that public health is protected in the future.
EPA is currently conducting a feasibility study of cleanup alternatives for OU9.
What Is the Current Site Status?
EPA, working cooperatively CTDEEP and the Town of Stratford, has taken extensive immediate actions over the years to protect public health by excavating wastes from residential areas, installing interim caps over contaminated wastes, fencing and capping municipal properties, and restricting access to commercial properties.
CTDEEP has also excavated contaminated materials from Wooster Middle School and brought all of the material back to the Raymark facility, where it was capped in place as part of OU1 cleanup.
A Record of Decision (ROD) was issued in 1995 which addressed the former Raymark facility, referred to as Operable Unit 1 (OU1). Actions included demolition of buildings, consolidation of wastes from 46 residential properties at OU1, and covering this areas with a low permeability cap.
A second Record of Decision (ROD) was issued in 2011 to address four of the numerous properties in Operable Unit 6 (OU6) that contained Raymark Waste.
In September 2016, EPA issued a third ROD to select final cleanup remedies for OU2 (Groundwater), as well as OU3 (Upper Ferry Creek), OU4 (Raybestos Memorial Ballfield), and the 22 remaining OU6 properties (Additional Properties). Details are provided in each OU description below.
EPA’s Involvement at the Site
EPA has been working with various state and federal agencies including the Connecticut Department of Energy & Environmental Protection (CTDEEP) and Connecticut Department of Public Health (CTDPH), the Agency for Toxic Substances and Disease Registry (ATSDR), the National Oceanic and Atmospheric Administration (NOAA), the U.S. Army Corps of Engineers (USACE), and others to address the issues found at the Raymark Superfund site.
EPA has also worked closely with the Town of Stratford in an effort to find publicly acceptable approaches to address the contaminated areas throughout the Town. To this end, EPA has worked with a number of citizens groups, including the Raymark Advisory Committee (RAC), the Raymark Superfund Team (RST), Stratford Action for the Environment (SAFE), and Save Stratford. Numerous meetings have occurred throughout the years in an effort to reach agreement on cleanup approaches of areas contaminated with Raymark Waste.
The Raymark Industries, Inc. Superfund Site (Site) is currently divided into nine separate pieces (Operable Units, or OUs) in an effort to effectively manage the various investigatory studies that have taken place throughout the Site. The status of each OU at the site is described further below.
Sampling and Monitoring
Lead, asbestos, and PCBs have been the predominate contaminants found in soils at the former industrial manufacturing facility and at numerous locations in Stratford where Raymark's manufacturing waste was disposed of in the past. Groundwater in the area of the former Raymark facility is also contaminated with heavy metals, semi-VOCs, and VOCs. Ingesting or coming into contact with these contaminants could pose a threat to public health. An advisory was issued by the Agency for Toxic Substances and Disease Registry (ATSDR) based on the concern that people could be exposed to site-related contaminants through inhalation of, direct contact with, or ingestion of, waste present in the soil, and consumption of potentially contaminated seafood. Consumption of contaminated groundwater near the site is not considered a current human health threat as groundwater is not currently used for drinking water purposes.
During cleanup, a site can be divided into a number of distinct areas depending on its complexity. These areas, called operable units (OUs), may address geographic areas, specific problems, or areas where a specific action is required. Examples of typical operable units include construction of a groundwater pump and treatment system or construction of a cap over a landfill.