Upload
others
View
2
Download
0
Embed Size (px)
Citation preview
/
THE HARKER FIRM
Timothy Marker and Associates Attorneys Suite 740
Tel. (202) 966-7900 5301 Wisconsin Avenue, N.W.
Fax (202) 966-5044 WASHINGTON, D.C. 20015
February 4, 1993
SDMS DocID 450031
Marilyn K. Goldberg (HES-CAM6)
U.S. Environmental Protection Agency
P.O. Box 221470
Chantilly, VA 22022
c/o TechLaw, Inc.
14500 Avion Parkway
Suite 300
Chantilly, VA 2 2 021
Attn: Lee Bishop
Re: Request for Information for Solvents Recovery Service of New
England Superfund Site in Southington, Connecticut
Dear Ms. Goldberg:
The Marker Firm represents Benjamin Moore & Co. ("Benjamin
Moore") in regard to the Solvents Recovery Service of New England
("SRSNE") Superfund Site in Southington, Connecticut. This letter
and enclosure are in response to your Section 104(e) request dated
December 7, 1992.
We wish at the outset to state that it is Benjamin Moore's
intention to fully cooperate with you in your investigation into
this matter. Please do not interpret the delay in our response as
reflecting anything other than a confusion in communication over
the holiday period and a personal illness this last week.
This response addresses any and all activity that Benjamin
Moore has any record of, or recollection of, with SRSNE during the
period 1955 to 1980. We are including copies of all documents that
we have that deal with this activity in this period. Our records
search found nothing other than the documents that are provided
wherewith.
We recognize a continuing obligation to provide you with any
additional information which we may discover, but as the period of
concern to you is 12 years ago, and therefore beyond the limit of
Benjamin Moore's document retention policy, it is unlikely that any
Marilyn K. Goldberg
February 4, 1993
Page Two
additional information will turn up. However, we will keep
investigating and we will inform you if we find anything else.
Please note that nothing in our response should be taken as an
admission that Benjamin Moore has any liability for either EPA
costs or alleged environmental damage arising from activities at
SRSNE.
Benjamin Moore has cooperated to date with your investigations
and will continue to cooperate. However, in order to staunch the
flow of transaction costs we ask to be included in de minimis
settlement negotiations as soon as they are open.
In the meantime, please continue to keep us informed of your
progress, and thank you again for your patience regarding this
response.
Sincerely yours.
"̂'' Timothy L. Harker
Counsel to Benjamin Moore & Co,
TLH:lm/9 3N
V.
ENCLOSURE B
Solvents Recovery Service of New England
104(e) Information Request Form for Generators
1. Name of Respondent: Benjamin Moore & Co.
2. Date Information Request Completed: February 2, 1993
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, identifv 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 1;
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 of
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.
000001
6 . ( c o n t i n u e d )
Name: John S i lva
c/( 3 Benj; amin Moore & Co . , P.O. Box 220 A d d r e s s
Un: Lon Avenue Extens ion , Johnstown, NY 12095
(518) 736--1723 Phone No.
R e l a t i o n t o R e s p o n d e n t Former P lan t Manager - Milford P lan t
Name: Alfred Worsham
A d d r e s s : ^ / ° Benjamin Moore & Co. , 49 Sumner S t r e e t
Mil ford , MA 01757
P h o n e N o . (508) 473-8900
R e l a t i o n t o R e s p o n d e n t P lant Super intendent - Milford Plant
Name: Arthur Chianese
A d d r e s s : "^/o Benjamin Moore & Co. , 49 Sumner S t r e e t
Milford, MA 01757
P h o n e N o . (508) 473-8900
R e l a t i o n t o R e s p o n d e n t : Foreman of the Maintenance Department Milford Plant
Name: Mark Largey
A d d r e s s : '^^^ Benjamin Moore & Co. , 49 Sumner S t r e e t
Milford, MA 01757
P h o n e NO. (508) 473-8900
R e l a t i o n t o R e s p o n d e n t : A s s i s t a n t P lan t Supervisor Milford Plant
CONTINUED ON PAGE 2A
00000.^
2A
(continued)
Name: Van Stoaner
Address: c/o Benjamin Moore & Co.. 49 Sumner Street
Milford. MA 01757
Phone No. r508) 473-8900
Relation to Respondent Plant Operations Manager
l*0u004
P l e a s e i d e n t i f y t h e p e r s o n ( s ) c o m p l e t i n g t h i s q u e s t i o n n a i r e and i d e n t i f y t h e r e l a t i o n s h i p t o t h e R e s p o n d e n t . A t t a c h e x t r a p a g e s i f n e c e s s a r y .
Name: John T. Rafferty
A d d r e s s : " /̂o Benjamin Moore & Co., 51 Chestnut Ridge Road
Montvale, NJ 07645
Phone No. (201) 573-9600
R e l a t i o n t o R e s p o n d e n t : Secretary and General Counsel
Name: Timothy L. Harker
A d d r e s s : The Harker Firm, 5301 Wisconsin Avenue, N.W.
Su i t e 740, Washington, D.C. 20015
Phone No. (202) 966-7900
R e l a t i o n t o R e s p o n d e n t : Attorney
Name:
A d d r e s s :
Phone No.
R e l a t i o n t o R e s p o n d e n t ;
O O O O O L ^
FORM 1 Page: l
Solvents Recovery Service of Mew England
Benjamin Moore 6 Company
Transaction Gallon Waste Type (3) Mame/Address Mame/Description of Who
Date (1) Volume (2) of Transporter Selected the Site (4)
10/11/72 4,400.00 See Exhibit A
10/31/72 4,400.00 See Exhibit A
11/30/72 8,580.00 See Exhibit A
12/28/72 4,400.00 See Exhibit A
01/18/73 3,960.00 See Exhibit A
01/22/73 3,520.00 See Exhibit A
02/05/73 2,200.00 See Exhibit A
02/12/73 2,420.00 See Exhibit A
03/05/73 2,200.00 See Exhibit A
03/27/73 3,520.00 See Exhibit A
Motes:
(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
crif the transaction was brokered by another party), and therefore may not match exactly
C-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.
f ) ) FORM 1 Pag^. 2
Solvents Recovery Service of Mew England
Benjamin Moore & Company
Transaction Gallon Waste Type (3) Date (1) Volume in. 04/02/73 3,410.00 See Exhibit A
04/09/73 3,410.00 See Exhibit A
05/17/73 2,805.00 See Exhibit A
05/24/73 2,750.00 See Exhibit A
06/04/73 3,520.00 See Exhibit A
06/28/73 2,310.00 See Exhibit A
07/19/73 3,905.00 See Exhibit A
07/23/73 3,355.00 See Exhibit A
2,035.00 See Exhibit A07/30/73
08/21/73 3,245.00 See Exhibit A
See A08/30/73 2,860.00 Exhibit
2,035.00 See Exhibit A09/24/73
See Exhibit A10/01/73 1,870.00
See Exh: Lbit A4,730.00 10/15/73
10/29/73 1,320.00 See Exh: Lbit A
See Exhibit A2,915.00 11/05/73 CD
See Exhibit A2,200.00 11/19/73 '^
1,320.00 See Exhibit A12/03/73 2
See Exhibit A1,320.00 12/06/73
Mame/Address Mauae/Description of Who
of Transporter Selected the Bite (4)
http:1,320.00http:1,320.00http:2,200.00http:2,915.00http:1,320.00http:4,730.00http:1,870.00http:2,035.00http:2,860.00http:3,245.00http:2,035.00http:3,355.00http:3,905.00http:2,310.00http:3,520.00http:2,750.00http:2,805.00http:3,410.00http:3,410.00
( ) f )
FORM 1 Page: 3
Solvents Recovery Service of New England
Benjiunin Moore t Company
Transaction Gallon Waste Type (3) Mame/Address Mame/Description of Who
Date (1) Volume (2) of Transporter Selected the Site (4)
12/10/73 1,760.00 See Exhibit A
See Exhibit A12/28/73 2,860.00
See Exhibit A01/14/74 1,760.00
See Exhibit A01/21/74 1,100.00
See Exhibit A07/05/77 2,090.00
See Exhibit A07/11/77 1,760.00
See Exhibit A07/18/77 1,045.00
See Exhibit A06/05/78 5,660.00
See Exhibit A01/24/79 5,462.00
See Exhibit A02/28/79 4,797.00
See Exhibit A10/22/80 5,236.00
CD
CD
d'
CD
CD
-v3
http:5,236.00http:4,797.00http:5,462.00http:5,660.00http:1,045.00http:1,760.00http:2,090.00http:1,100.00http:1,760.00http:2,860.00http:1,760.00
f >
FORM 1 - ADDITIONAL TRANSACTIONS Page:
Solvents Recovery Service of New England Benjamin Moore ( Company
TransactionDate (1)
Gallon Waste Type (3) Volume (2)
Name/Address of Transporter
Name/Description of Who Selected the Site (4)
CD
on
'*^»»*'
Benjamin Moore Response to EPA Section 104(e) Request - "FORM 1"
Alleged Alleged Name/Address Name/Description Transaction Gallon of of Who Selected
Date Volume Waste Tvoe Transporter the Site
10/11/72 4,400.00 See Note 1 See Note 1 See Note 1 10/31/72 4 400.00 See Note 1 See Note 1 See Note 1 11/30/72 8 580.00 See Note 1 See Note 1 See Note 1 12/28/72 4, 400.00 See Note 1 See Note 1 See Note 1 01/18/73 3 960.00 See Note 1 See Note 1 See Note 1 01/22/73 3 ,520.00 See Note 1 See Note 1 See Note 1 02/05/73 2 200.00 See Note 1 See Note 1 See Note 1 02/12/73 2 ,420.00 See Note 1 See Note 1 See Note 1 03/05/73 2 200.00 See Note 1 See Note 1 See Note 1 03/27/73 3 520.00 See Note 1 See Note 1 See Note 1
04/02/73 3 410.00 See Note 1 See Note 1 See Note 1 04/09/73 3 410.00 See Note 1 See Note 1 See Note 1 05/12/73 2 805.00 See Note 1 See Note 1 See Note 1 05/24/73 2 750.00 See Note 1 See Note 1 See Note 1 06/04/73 3 ,520.00 See Note 1 See Note 1 See Note 1 06/28/73 2 310.00 See Note 1 See Note 1 See Note 1 07/19/73 3 905.00 See Note 1 See Note 1 See Note 1 07/23/73 3, 355.00 See Note 1 See Note 1 See Note 1 07/30/73 2, 035.00 See Note 1 See Note 1 See Note 1 08/21/73 3 245.00 See Note 1 See Note 1 See Note 1 08/30/73 2 860.00 See Note 1 See Note 1 See Note 1 09/24/73 2 ,035.00 See Note 1 See Note 1 See Note 1 10/01/73 1 870.00 See Note 1 See Note 1 See Note 1 10/15/73 4 730.00 See Note 1 See Note 1 See Note 1 10/29/73 1,320.00 See Note 1 See Note 1 See Note 1 11/05/73 2 915.00 See Note 1 See Note 1 See Note 1 11/19/75 2 ,200.00 See Note 1 See Note 1 See Note 1 12/03/73 1 ,320.00 See Note 1 See Note 1 See Note 1 12/06/73 1,320.00 See Note 1 See Note 1 See Note 1
12/10/73 1 ,760.00 See Note 1 See Note 1 See Note 1 12/28/73 2 ,860.00 See Note 1 See Note 1 See Note 1 01/14/74 1 760.00 See Note 1 See Note 1 See Note 1 01/21/74 1 ,100.00 See Note 1 See Note 1 See Note 1 07/05/77 2 090.00 See Note 1 See Note 1 See Note 1 07/11/77 1< 760.00 See Note 1 See Note 1 See Note 1 07/10/77 1 045.00 See Note 1 See Note 1 See Note 1 06/05/78 5< 660.00 See Note 1 See Note 1 See Note 1 01/24/79 5 462.00 See Note 1 See Note 1 See Note 1 02/28/79 4, 797.00 See Note 1 See Note 1 See Note 1 10/22/80 5 236.00 See Note 1 See Note 1 See Note 1
Sum Here 124, 445.00
000010 ^'»ll».»'
Plus (See Note 2):
12111 1 1 ^ 5,000.00 Waste SRS see Note A See Note B Solvent
Sludge
01/08/80 5,085.00 Waste SRS see Note A See Note B
Solvent
Sludge
02/01/80 4,620.00 Waste SRS see Note A See Note B
Solvent
Sludge
Note A: Transportation was apparently provided to and from Solvent
Recovery Service's facilities in Southington, CT by Solvent
Recovery Service of Lazy Lane, Southington, CT.
Note B: We do not know who made the first decision to send
Benjamin Moore recyclable solvent wastes to Solvent Recovery
Service, but it appears that the decision was followed in this
instance by Robert Modrak. [Nota bene: Mr. Modrak is not
deceased, but he is physically incapacitated and no attempt was
made to interview him.]
Ste;̂ **̂
^ * m t ^
0 00011
http:4,620.00http:5,085.00http:5,000.00
Notes Accompanying "Form 1"
NOTE 1
After diligent research and investigation, Benjamin Moore is unable
to identify this specific transaction, and cannot, therefore,
provide any specifics about waste type. Transporter, or the
"name/description" of who selected the site.
NOTE 2
The 104(e) request asks for "copies of all documents consulted,
examined, or referred to in the preparation of answers to these
questions." We consulted documents from two sources. All
documents consulted, examined, or referred to from our files are
herewith produced (see Exhibits B and C). We also consulted the
documents that EPA produced to us on or about November 6, 1993.
Copies of the documents that came from EPA are not attached.
Please contact us if you would like copies.
Among the documents that Benjamin Moore found in its files are
fourteen separate sheets of paper that refer to three distinct
transactions within the relevant time period. These are separated
into packets in our enclosed Document Production.
Packet "one of three" includes three documents associated with a
transaction dated sometime in December 1979 (see Exhibit B).
Packet "two of three" includes five documents associated with a
transaction begun on January 8, 1980 (see Exhibit B).
Packet "three of three" includes six documents associated with a
transaction begun on February 1, 1980 (see Exhibit B).
''"BM*'
0 0O012
r
Cover Sheet for documents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 1 of 3 - Description of transaction missing from EPA listing
Transaction Gallon Waste Description Name/Address of Name/Description of Who
Date Volume Transporter Selected the Site
12/??/79 5,000.00 Waste Solvent Sludge SRS see Note A See Note B
Transaction dated 12/??/79
SRS Disposal Quote 11-21-79
SRS
Shipping Order 1-11-80 1900 gals reel Sol SRS carrier TO Benj Moore
SRS Invoice 9296/22 1-25-80 5000 gals in 1900 reclaim TO Benj Moore
cf Benj Moore 18197
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt was
made to interview him.]
CD
CO
http:5,000.00
C)
Cover Sheet for documents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 2 of 3 - Description of transaction missing from EPA listing
Transaction Gallon Waste Description Name/Address of Name/Description of Who
Date Volume Transporter
01/08/80 5,085.00 Waste Solvent Sludge SRS see Note A
Transaction dated 1/08/80
Benj Moore
Shipping Order 18302
Benj Moore
Bill of Lading 18302
Weight Ticket #7996
SRS
Shipping Order
1- 8-80
1-11-80
2-20-80
2-20-80
SRS Invoice 9391/22J 2-28-80
cf Benj Moore 18302
6000 gals Waste Solvent Sludge
6000 gals Solvent NOS
16680 pounds net SRS carrier
16680 pounds net SRS carrier
5085 measured gals
Selected the Site
See Note B
TO SRS
TO SRS
TO Benj Moore
TO Benj Moore
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt was
made to interview him.]
O
CD CD t o
I—•
http:5,085.00
Cover Sheet for documents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 3 of 3 - Description of transaction missing from EPA listing
Transaction Gallon Waste Description Name/Address of Name/Description of Who
Date Volume Transporter Selected the Site
02/01/80 4,620.00 Waste Solvent Sludge SRS see Note A See Note B
Transaction dated 2/01/80
Benj Moore
Shipping Order 18403
Benj Moore
Bill of Lading 18403
SRS
Shipping Order
Weight Ticket #8667
SRS
Demurrage Charge
2- 1-80
2- 1-80
2- 1-80
2- 1-80
2- 1-80
SRS- Invoice 9481/22J 2-28-80
cf Benj Moore 18403
4800 gals Waste Solvent Sludge TO SRS
4800 gals Waste Solvent Sludge TO SRS
12580 pounds net SRS carrier TO Benj Moore
12580 pounds net SRS carrier TO Benj Moore
4800 gals SRS picked up at Benj Moore
4620 measured gals
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt waJ
made to interview him.]
t. •
http:4,620.00
fct?> • • ^ • ^
^ - ^ : • s S i ^ i i ? * * '
'KiV'.
i - » - • •» ' liX.'i j * v f i ;
! • * < '
•-^*f, .'?;?
/ "
Cover Sheet for docvunents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 1 of 3 - Description of transaction missing from EPA listing
Transaction Gallon Waste Description Name/Address of Name/Description of Who
Date Volume Transporter Selected the Site
12/??/79 5,000.00 Waste Solvent Sludge SRS see Note A See Note B
Transaction dated 12/??/79 Doc Type Ref No Date Volume coraiTient
SRS Disposal Quote 11-21-79
SRS
1-11-80 1900 gals reel Sol SRS carrier TO Benj Moore Shipping Order
SRS Invoice 9296/22 1-25-80 5000 gals in 1900 reclaim TO Benj Moore
cf Benj Moore 18197
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt was
made to interview him.]
O
CD
CD
http:5,000.00
( 2 0 3 ) 6 Z B - O D B 4
EDWARD F. B D R U C K :
> L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D , I N C . SOLVENTS RECOVERY SERVICE DF NEW/ E N G L A N D . INC .
LAZY L A N E : S O U T H I N G T O N . C O N N . 0 6 4 a S LAZY LANE • S O U T H I N Q T O N . C O N N E C T I C U T D6-4B9
^ ^ ^ /-2f^-^
P H O N E : ( 2 0 3 > 6 2 a - a O S 4
DISPOSAL QUOTATION
Benjamin Moore & Co. DATE QUOTED: 11/21/79 49 Summer Street LAB NUMBER: 9446 Milford, MA 01757 MINIMUM QTY: 5000 gallons
Att: Mr. Robert Modrak
PRODUCT: Mineral Spirit Sludge
DISPOSAL CHARGE $ .24/gallon )^ o O "= j X - ^ O O
QUALIFICATION: Based upon pre-shipment sample results of 20% H20 and 88,000
BTU's/gallon, SRSNJ will sample the crude prior to unloading,
reserving the right to reject the load if found to be signi
ficantly different from pre-shipment sample.
MINIMUM DISPOSAL CHARGE; $150.00
TRANSPORTATION: Provided by Customer
PICKUP
SHIPPING:
CRUDE TO: SRSNJ
1200 Sylvan Street
Linden, NJ 07036
VIA: Common Carrier - PREPAID
TERMS: Net 15 days
THIS QUOTATION IS BASED UPON YIELD OBTAINED FROM A PRE-SHIPMENT SAMPLE. IT MAY
BE MODIFIED AFTER THE FACT IF THE CRUDE SOLVENT AS DELIVERED DIFFERS MATERIALLY
FROM THE PRE-SHIPMENT SAMPLE.
ALL QUOTATIONS SUBJECT TO REVISION IF NOT ACTED UPON WITHING 60 DAYS. THANK
YOU FOR THE OPPORTUNITY TO QUOTE OUR SERVICE.
,fm^ EFB/wp , 791127
000018
r ) • B » j « i M l W n i f l l f t i l t • ) l m t t » t , • ^ • p t * ^ ky C«>rl«n In OWclal , i w l k w i i , W x l a r a
i l « > « M r l M , M « f . U , l « i l , M « M f i 4 > 4 A « t . I . 1*10. a n ^ J v M I ) . I t 4 l . )
Shipper's N o . _ Tn l5 S n I r r l N v OKDcR c c lMiWcaHam «•< tafifft in • H w l t n Ika 4ata «( Ik * l i i i x W i M i l i l l •« U4ii-/OL?t>
CD
CC
WM-ict t u f r
/
S O L V E N T S R E C O V E R Y S E R V I C E
• O F N E W E N G L A N D , I N C . CUSTOM DISTILLATIONS LAZY LANE • SOUTHINGTON. CONN. 06489 PHONE 203-628-8084
FOR INDUSTRY
••ri.'il ,V ; , - . - V * ' ' *^ tfc» l>- . i - * ' - '•..•^i I - * : h--*. ' . .1 * » i - i :?. «J w' i * * i tAs .
'Vrjrn '^jA'hj: • ' SOLD TO SHIP TO
1086 4. i l » , • - . » . 1 • - ' T . < - < , . .
. t . • . . ' - •,.! . » • «
Benjamin Mbore s Co. 49 Summer Street Milford, MA 01757
3 A T E S H I P P E D P R E P A I D C O L L E C T I N V O I C E D A T E OUR O R D E R N O . YOUR O R D E R N O .
1 / 1 1 / 8 0 SRSNE X 1 / 2 5 / 8 0 9 2 9 6 / 2 2 18197 Q U A N T I T Y D E S C R I P T I O N U N I T P R I C E A M O U N T
- r ~ 1 9 0 0 GALS Boae Mineral S p i r i t s .54 1026.00 • • . . . . • - • • • ! >^V3100 GALS. BY PRODUCT .35 1085.00* Uvsooo GALS. OR LBS. CRUDE PROCESSED
^%.yieLD '.:, ''.::^'--":':^'ltit.^-.38 • f . * . A - . - . . i ; :.>ik ; j * . ' r * v - i * . . ^ - • - . — r . • DRUMS RECONDITIONED
• , • • • - " ' ' , « J *
DRUMS FURNISHED
DRUMS SCRAPPED
TRANSPORTATION!
I^T 1/11 360.00
Add'l due on R/T of 12/11 120.00
2591,00
*yield less than 50%
Net 15 Days
TERMSi 1% 10 DAYS - NET 30 DAYS
d;?' '2-
( )
Cover Sheet for documents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 2 of 3 - Description of transaction missing from EPA listing
Transaction Date
Gallon Volume
Waste Description Name/Address of Transporter
Name/Description of Who Selected the Site
01/08/80 5,085.00 Waste Solvent Sludge SRS see Note A See Note B
Transaction dated 1/08/80 Doc Type Ref No Date Volume Comment
Benj Moore Shipping Order 18302 1- 8-80 6000 gals Waste Solvent Sludge TO SRS
Benj Moore Bill of Lading 18302 1-11-80 6000 gals Solvent NOS TO SRS
Weight Ticket #7996 2-20-80 16680 pounds net SRS carrier TO Benj Moore
SRS Shipping Order 2-20-80 16680 pounds net SRS carrier TO Benj Moore
SRS Invoice 9391/22J 2-28-80 5085 measured gals cf Benj Moore 18302
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt was
made to interview him.]
CD
ro
Moore^s BenjamioMoore 8?Co. ^̂ ^̂ •̂'̂ °̂ '̂̂ ^ °̂̂ ^
EASTERN DIVISION . . . Newark^^stoj^-Jacksonvl l le-Richmond-New Y o r k - M o n t v a l e ^ ^ A ^ ^ ^
SOLD TO
Solvents Recovery Service
Lazy Lane
S o u t h i n g t o n , Conn.
TERMS: 2% 10 DAYS-60 NET
L I Q U I D G A L L O N S
6 ,000 g a l s WASTE SOLVENT SLUDGE
FROM DRUMS AND BULK
MARK: FOR RECLAIMATION
PLKASR NOTTFY DISPOSITION
^ DRUMS
2 GAL. CARTONS KITS
SPRAY F1.AM. AOVERTISING • RED LABEL. MATTER
1 1/4 1/8
/ / /
/ / /
/ / /
/ / /
/ /
/
/ / /
/ / /
/ / /
/ / /
/ / /
/ / /
/ / /
/ / /
/ / /
F L A M M A B I . E NO UABEL
SPRAY F L A M . NO L A B E L
1/8/80 O R O K R N O . 18302
? S P R A Y TUBES & C A N S COUOnANTS 1/16 1/32 2 5
/ / / / /
/ / / / /
/ / / / /
/ / / / /
// / //
/ / / / /
/ / / / /
/ / / / /
/ / / / /
/ / / / /
/ / / / /
/ / / / /
/ / / / /
/ / /uo:; {01
ROUTING
WEIGHT
PACKED BY CHECKED BY •
C IRCI.ED ITEMS ARE BACK ORDERED A N D W I I . I . F01.L.0W L A T E R . A L L CLAIMS MUST BE M A D E WITHIN TEN DAYS AFTER RECEIPT OF SOODS. " B A S E " CONTAINERS ARE SHORT F I L L E D TO ACCOMMODATE THE A D D I T I O N OF T I N T I N S COLORS.
http:F01.L.0Whttp:CIRCI.ED
t - / - « L . / i l V ^ ^ O l i v e t t i • ^ ^ I t l V I V . / I I I V J I i ^ r - \ L . I M O t I M C i j U L i a U I C
« j ^ v E »ubiect to the ctasstticettoni er^d tarttfe m effec^^n the dots of the ttsue of ih t i Shipping Ordor. (1 F r o m BENJAMIN MOORE & CO. At Milford, Mass.
I SOLD TO I
A ^ y i v ^ - " ^ ^ l ^ ^ - c ^ ' ̂
^ ^
.
^x2£^VLAditions are hereby agrMd to by t h . shipper and acMptad for hint-sail and his assigns.
Subject t o Sect ion 7 of C o n d i t i o n s of app l i cable b i l l -of lad ing, if th is sh ipment is t o be de l ivered t o the consignee w i t h o u t recourse o n the cons ignor , the consignor shal l sign the f o l l o w i n g s ta tement :
T h e carr ier shall no t make del ivery o f th is " " " o m e n t w i t h o u t paymen t of f re igh t and al l
er l aw fu l charges.
B E N J A M I N M O O R E & C O .
( S i g n a t u r e o f c o n s i g n o r . )
t The F ib re Boxes used fo r th is sh ipment conf o r m t o t he speci f icat ions set f o r t h in the box maker ' s cer t i f i ca te thereon , and al l o ther requ i remen ts of the U n i f o r m Freight Classi f icat ion.
' I f t he sh ipment moves be tween t w o po r t s b y a carr ier by water , the law requires t ha t t he b i l l o f lad ing shall state whether i t is "ca r r ie r ' s o r shipper 's w e i g h t . "
N O T E : • Where the rate is dependent o n va lue, shippers are requ i red t o state speci f i ca l l y in w r i t i n g t he agreed or declared value o f t h e p rope r t y . The agreed or dec lared value of t h e p rope r t y is hereby speci f ica l ly s tated by the sh ipper t o be n o t exceeding
per
If charges are t o be prepa id , vyrite or s tamp here, " T o be Prepa id . "
TO BE PREPAID
t This is to certify that the named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.
A g e n t , Per
Pgrmanent p o t t ot f icc acMreu o l shipper 49 SUMNER ST.. MILFORD. MASS. 01757
D.P. 2 1 M I L F O R D 3 P T R 3 - 9 - 7 9
•WEIGHT CLASS OR (sua. TO CORRJ RATE
V^. oo o
NO. PKGS.
^,ooo
•CiND OF PACKAGES O E S C N i r T i O N C f A R T I C L C S . SPECIAL M A R K S A EXCEPTIONS
CARTONS - PAINT, ENAMEL, LACQUER, STAIN, SHELLAC, VARNISH, FLAMMABLE LIQUID
DRUMS - PAINT, ENAMEL, LACQUER, STAIN, SHELLAC, VARNISH, FLAMMABLE LIQUID
KITS OR PAILS - PAINT, ENAMEL, LACQUER, STAIN, SHELLAC, VARNISH, FLAMMABLE UQUID
DRUMS - COMPOUNDS, LACQUER, PAINT OR VARNISH, REMOVING, REDUCING, FLAMMABLE LIQUID
PAINT, ENAMEL, LACQUER, STAIN SHELLAC, VARNISH
CARTONS
DRUMS
KITS OR PAILS
^fJo JjJj iy^^J, N.O.^.
( jev i^M*oCC6-^ ' J J A t y u . U ^ DRUMS - COMPOUNDS, LACQUER,fAINT OR VARNISH, REMOVING, REDUCING
LABELS, NOI CUT, PLAIN PRINTED OR LITHOGRAPH, IN PACKAGES
ADVERTISING MATTER, PAPER OR PAPERBOARD OTHER THAN CORRUGATED OR FLUTED, NO!
RACK OR STANDS, STORE DISPLAY KD FLAT
SHIPMENT CONTAINS
.CTNS. . -DRUMS OF FLAMMABLE MATERIALS
WEIGHING _LDS
V^^0£>0
- ( ) 301 SCALE
BRAINARD INDUSTRIAL PARK 7996
HARTFORD, CONN. 06114
CERTIFIED WEIGHT TICKET
o o r\ GROSS
^ f r ^ t o
NET
Date-
Name of carrier ^ ^
Vehicle identification fUf :
rf )l«4leie, «^ f f .W k f Carriers la OfNcial, S.iffk«ra. Wntara
i ral tM'. d l<
J i iM««« 0«iMaH< M r a l f M '
IS, I t i l , asawaaWa^ Am. I. I t lO . and J»i>a M. M41.I fa tarrtylsrMi
Shipper's N o . _f i n e e i - l i a a i l k J / « / \ D r % C D " " " • * • " ^ ' W r ' H " ^ ' " . ' " I"k.'•> ""^alikla •aiKil. « in T H I S S H I P r I N O O K D C K C«rk.a, aa^ r.lain.d ky Ih . A i . m
(Prescribed by the Interstate Commerce Commission.) Cut tomar 's No .
.Company Agent ' s No . I K I I V f D , takjaef l« Mie ifltallans m«i tarlNs ia .Heel an Use 4 « a af Iha Issue a( Miit SiU W U 4 l n « .
At Southington, Conn. : n 19 From SOLVENTS RECOVERY SERVICE OF NEW ENGLAW). INC. « t f t ^ f t n 4 r i t ' i h t 4 tobw. m «fip«r«M« gsad v d o r . tacvp i w r l 4 (coAMnH « ^ CendiHOM of CoMe^H 9I (>«cl«fM wMt»Own|. )M*>iaJ, rrd • ! i f t d to led belew. agkecK k«.4 t»>i>pa>itr«ci M •«MiMf mff M 'WA • ' c«r#0rc*i«M M pe>Ml«i»*i at 1*i« pr«p«rtr v r f W cenitQC') O f l * * * to carfy fo >i* uswo' p l o t * • ' de(i««'t' or i « ^ dvtiwaitoM. i* on •!• ^ ^ t rood e> •*( own wowr ftne. o 'he iMiM lo d>l>**> lo m r t t e r ( • r rw i «*< (K* (•wt? to H < H dM'>»ia'tr |ep«riv ever «d pfoperry. " W l «•• '» t e r -C* '0 be peHormed herewnrf*' ihtitt be lub|*
'
OFFICE COPY
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D , I N C CUSTOM DISTILLATIONS LAZY LANE • SOUTHINGTON, CONN. 06489 PHONE 203-628-8084
FOR INDUSTRY
SHIP TO 1086 t°'-°^° BoDtjamln Moore & Cd 49 Sumner S t r e e t Milford, MA 01757
A T E S H I P P E D V I A P R E P A I D C O L L E C T I N V O I C E D A T E OUR O R D E R N O . YOUR O R D E R N O ,
2 /1 /80 SBSNE X 2 /28/80 9391/22J 18302 Q U A N T I T Y D E S C R I P T I O N U N I T P R I C E A M O U N T
1940 GALsdiiXK M ine ra l S p i r i t s .54 $1047.60 .35 1100.75* GALS. BY PRODUCT 3145
GALS. OR LBS. CRUDE PROCESSED 5085 38 » YIELD
DRUMS RECONDITIONED
DRUMS FURNISHED
DRUMS SCRAPPED
TRANSPORTATION
360.00
2508.35
RT 2 / i •• : ' r " • - • ' ' ' • ' •
* y i e l c l l e s s than 50% • - : ' . - : • • Net 15 Days
^wiKrr^rfirb'x^jTirfPTo'DAYs (yi^'^^'i^'^^^cJA
CD'
CD
CD
ro
(
Cover Sheet for documents produced By Benjamin Moore in response to EPA Section 104(e) Request
Packet 3 of 3 - Description of transaction missing from EPA listing
Transaction Gallon Waste Description Name/Address of Name/Description of Who
Date Volume Transporter Selected the Site
02/01/80 4,620.00 Waste Solvent Sludge SRS see Note A See Note B
Transaction dated 2/01/80
Doc Type Ref No Date Volume Comment
Benj Moore
Shipping Order 18403 2- 1-80 4800 gals Waste Solvent Sludge TO SRS
Benj Moore
Bill of Lading 18403 2- 1-80 4800 gals Waste Solvent Sludge TO SRS
SRS
Shipping Order 2- 1-80 12580 pounds net SRS carrier TO Benj Moore
Weight Ticket #8667 2- 1-80 12580 pounds net SRS carrier TO Benj Moore
SRS
2- 1-80 4800 gals SRS picked up at Benj Moore Demurrage Charge
SRS Invoice 9481/22J 2-28-80 4620 measured gals
cf Benj Moore 18403
Note A Transportation was apparently provided to and from Solvent Recovery Service's facilities in
Southington, CT by Solvent Recovery Service of Lazy Lane, Southington, CT.
Note B. We do not know who made the first decision to send Benjamin Moore recycleable solvent wastes
Solvent Recovery Service, but it appears that the decision was followed in this instance by Robert
Modrak. [Nota bene: Mr. Modrak is not deceased, but he is physically incapaciated and no attempt was
Oinade to interview him. ]
CD CD CD> fO
-si
http:4,620.00
FACTORY OFFICE COPY i v i o o r c points BeniaimnMoore fifCo. EASTERN DIVISION . . . Newark^fiostonyjacksonvil le-Richmond-New Y o r k - M o n t v ^ g _ j ̂
5 0 L D TO
Solvents Recovery Service
Lazy Lane
Southington, Conn.
TERMS: 2% 10 DAYS-60 NET
L I Q U I D G A L L O N S
4 , 8 0 0 q a l s WASTE SOLVENT SBUDGE
FROM DRUMS & BULK
MARK: FOR RECLAIMATION
PLEA.SE NOTIFY DISPOSITION
- • '
'
' ^ • : • • • : : , •
' • = ' • ' .
RUMS
2 G A U . ~ . ' CARTONS K I T S •••• \ SPRAY FUAM. AOVERTBINC
REO L A B E L . MATTER -
. b l L L U I - L A U I I ^ ( J t i M U K I r U t t l V I U t t H J I I M M L I^Ol l ^ e y u i i a u i e
%' Ĵ -&L}̂ n̂A- / ^ C ^ l ^ - ^ Jt-xAj-i^^^ F |B - 1 1 9 8 S ig Orda r . R E C T T V E . sub iact t o ttre c ia t t i (>ca t ions and ta r i f f s l o ^ f t a c T o n it>a d a t * o f tt>a i tsua of i t i i i S h i p p m i
F r o m BENJAMIN MOORE & CO. At Milford, Mass
I SOLD TO I J ^ GUST-TERR-ROOTE DATE ORDER NO.
9 V ^ i^Voz. ^ T T ^ J t rA
SHIP TO I
-^ 0 k ̂ >u*^ d^^r>e property deecribetj. in apparent Qood order, except at noted Icontents end condition of contents of packeget unknown!, merked. consigned, and destined es indicated below, which laid carrier (the word earner being understood throughout this cont r K t 3t meaning any person or corporation in possession of the property under the contract, agrees to carry to Its usuat place of delivery et said destination, i l on us route, otherwise to deliver to another carrier on the route to said destination. It is mutually agreed, at to each earner of all or any ol said property over all or any portion of taid route to destinati'on, and as to each party at any time intereslrid in all or any of said propeny. that every ser. vice to be performed hereunder shall be subiect to all the terms and conditions of ttte Uniform Domestic Straight Bill of Lading set forth ( I ) in Official. Southern. Western and fllinois Freight Classifications in effect on the date hereof, if this is a rail or a rail-weler shipment, or 12} in the applicable motor carrier classification or tariff if this is a motor carrier shipment
Shipper ftaraby certil iet that he it familiar wi th atf tha tMms and conditions ol the caid bill of lading, includirtf those on the back thereof, set for th tn the ciauif ication or tariff which govarnt tite transportation of this shipment, and tfta said terms artd cortditions are hereby a^aad to by tfia shipijar and accepted for himself and his aatigns.
Subject to Section 7 of Concjitions of appi cable bill of lading, if this shipment is to be delivered to the consignee without recourse on the consignor, the consignor shall sign the following statement: .-...•..
ie carrier shall not make delivery of this .Tient without payment of freight and all
'ft'er lawful charges. BENJAIVlIN MOORE 8i CO.
(Signature of consignor.)
t The Fibre Boxes used for this shipment conform to the specifications set forth in the box maker's certificate thereon, and all other requirements of the Uniform Freight Classif icatioa
* If the shipment moves between two ports by a carrier by water, the law requires that the bill o< lading shall state whether it is "carrier's or shipper's weight."
NOTE: • Where tha rate is dependent on value, shippers are required to state specifically in writing the agreed or declared value of the property. Tha agreed or declared value of the property is hereby specifically stated by the shipper to be not exceeding
per
If charges are to be prepaid, write or stamp here, "To be Prepaid."
TO BE PREPAID
t This is to certify that the named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations . of the • ^p^ tmen t of Transportation
( M A I L O R S T R E E T A D D R E S S O F C O N S I G N E E - F O R P U R P O S E S O F N O T I F I C A T I O N O N L Y . )
•WEIGHT C L A S S O R KIND OF PACKAGES. DESCRIPTION CF ANTlCLCS SPtClAL MARKS ft EXCfPTlUNIt NO. PKGS ( S u a T O CORR.) R A T E
CARTONS - PAINT, ENAMEL, LACQUER, STAIN,
SHELLAC, VARNISH, FLAMMABLE LIQUID
DRUMS - PAINT, ENAMEL, LACQUER, STAiN,
SHELLAC, VARNISH, FLAMMABLE LIQUID
KITS OR PAILS - PAINT, ENAMEL, LACQUER, STAIN,
SHELLAC, VARNISH, FLAMMABLE LIQUID
DRUMS-COMPOUNDS, LACQUER. PAINT OR
VARNISH, REMOVING, REDUCING, FLAMMABLE LIQUID
PAINT, ENAMEL, LACOUER, STAIN SHELLAC, VARNISH
CARTONS
DRUMS
KITS OR PAILS
HlPOyJL^^ lPa>«t
V f) ftiiWaiia D a i i i M t o ' i l l ' t ' t k * X ' * • ' l « ^ * t . • ' • r < a 4 k r Caeriara In OWcla l , l a v l l w r a , Waatof Sid l l l inal . ^ t W S J i a n laerWaetae. M M . I ( , I M I , M « M i i 4 a d A I>« . I , I t M , w id Jaiea I S , 1*41
Shipper'* No THIS SHIPPING ORDER "'*' '• '7:?a:r.it ' :r jL;'t ' i : i ::-" ' ' '- ' ' ' ;
(Prescribed by the Interstate Commerce Commission.) Cuttomar't No. " ' • / ' ' • . : ••
.Company Agonl't No IfCEIVIO, tu^ac t ta Il ia clatsificalians and tariffs in effect i t tfia data mt Iha Isswa af Hiis l i l l af U d i n f ,
At Southington, Conn. 19 F-o- SOLVENTS RECOVERY SERVICE OF NEW ENGLAND. INC. iK« propc ' i f 4«Kribad b « k i * i •* appsrvnl 9004 afdof. • •aM of Ih * preparlr wndaf t h * (onM»ci) O f ' • • • 'O ce> i | lo i i | wiwa< i ) l« ( * gt 4«li««ry o i lairf 4MI>i«i>o«i. •' IMI i i i »*••« rood a> •(» « « • wai«f I tn*. Q i h a i w H lo deliver le W M I K B I (of t tai > ••>• fOwi* la w i d dailtAoiiOn H •• w MrkK« 'o b« po r ' a rmcd h*raun« I thol l ba »ubiacf lo o f tha cend- ' iem nor piQh4i>t«d ta| l«« whtfttter pM«d w Mi i i i tA. harsiM (OMigiitod, mdwdm^ ift« condii ient on bock k«tao ' . which o ' * hoiaby O B ' * * ̂ le by fh« ihippoi end occopioo la* I M M M M and hi* a u i g n i
I N I M I %t t t r—t a « f i e » af c*«i»»fnaa—f«r pwr^atae W wfificwfiaw *« l | r . |
Consigned t o ,
Deslinohon .State oL _County of_
Route
_Xar Init ioL „CorNo, . DEllVfgING CARgl£g
Fochogat •Waighl C lo i i Chach DaKfiplion of A i ix l t t . Spaciol Morki. ond Cflcapliont Swbiac) le Sactien 7 of coftdi i ieni, if Ihit th ipmani i t lo ba dalivafad lo Iha contionao wirhovt racowrta on iho
FULL DRUMS coniignor. Iha coniignor tholl t ign iha
No ($wb|oci lo CoffadioA) 0( Iota Column
GALS.ORLBS. ^ Tha cornar thol l net moka dalivary of ih i i ihipntant without poymant of fraight ond oil othar lawful chorgat. DIRTY EMPTY DRUMS
CLEAN EMPTY DRUMS
Stgnotwa of Contignor INCHES COMP. # 1 If chorgai ora to ba prapoid wnta
INCHES COMP. # 2 or t lon ip hara. "To ba f r apo id . '
INCHES COMP. # 3
^ r f J. .1 L . - .
CROSS
TARE
' r # — ^ tacaivad $ to app ly in p r t p e y m a n i of tha chorgat en Iha propar ty daicrtbad haraon.
* • ' ^ • ^ ' *
NET Aganf er Coihiar. far . .
Iha ofnount prapoid.)
TW e9r«ad or dKbrvr f nlu« of Hta propartjr i t Wroby ipKificaKy itolad br itw ihippar to bo net wcoading $ P»f Chorgai odvoncad S
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. Shipper -Agant
Per ' - ^ f a r . Permanent pojtoffice oddreu of shipper LAZY LANE, SOUTHINGTON, CONN. 06489
C D C D C D C D
301 SCALE
BRAINARD INDUSTRIAL PARK 8667
HARTFORD, CONN. 06114
CERTIFIED WEIGHT TICKET
GROSS
TARE
NET
Name of carrier
Vehicle identificatioa ^̂ ax̂ Name of shipper
Origin of shipment / - ^
DettinaUon of thjpment ( f ^ ̂ A f < D ^ ^ ^ y '^F^:^ G r o t weight of loaded vehicle, without the crew thereon z:^ Tare weight of vehicle, without the crew thereon, including full
fuel tank, and all necessary pads, chains, dollies, hand trucks,
and otherye^uipment.
B/L No. 9fy/
CD
CD
CO
"y 4P
Peb.vuarv 1 , 1030 sor.vEnTS KECOVI-:RY .SKIIVIa: OF N!:W I'M^LAND
• CX&I-OVF.-R 1-JW-E Benjamin Moore M i l f o r d , Mass .
Ti;
OFFICE COPY
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D , I N C . CUSTOM DISTILLATIONS LAZY LANE • SOUTHINGTON, CONN. 06489 PHONE 203-628-8084
FOR INDUSTRY
SOLD TO SHIP TO
1086 Benjamin Mooire & COe
49 Summer Street
Milford, MA 01757
D A T E S H I P P E D V I A P R E P A I D C O L L E C T I N V O I C E D A T E OUR O R D E R N O . Y O U R O R D E R N O .
2 / 2 0 / 8 0 - / SESNE . X_. , . 2 / 2 8 / 8 0 9 4 8 1 / 2 2 J 18403 — " — Q U A N T I T Y - - - - • _ , D E S C R I P T I O N . . _ _ . U N I T P R I C E A M O U N T
; . . ; 12570 -°*^3Ucac= M i n e r a l S p i r i t s , . 5 4 % I 3 8 7 . 8 0 , r : ^ r , GALS. BY PRODUCT • - . . • ' ' . 2 3 > , ^ '=* ; : .2050 -.. 471*50.^-;;:.;:5 • GALS. OR LBS. CRUDE PROCESSED . 4 6 2 0 ;'-.•:.-.y^:;\i-V..
S6 . .-• » • " . ' • • . ' . * » • y . ••
' "%YIELD " ' ' ' ' " " V - • - - ...- . ... , DRUMS RECONDITIONED __ , ' '" •
'..; D e l 2 / 2 0 ?• •.•;...._..: 240.00""^=^=
. 2 1 9 9 . 3 0 - ._ "_ • w - • ' . .
' < » • • - w : , - • • ' . - . . • - . .,.-- .̂ .. —, - • # ' . - : . ' i » c > . . v a i , » - ^ . , . !• . • • • . , . r , •--' . . ^ , . - . . . , . . - . - H V . ;.•• 1 • - r .n. . . . t 1 -. ; :,• ' • i »• •.;, ' ^ • J • " i r t i w . » ; • « • - • -, r"-**- • Cf t A - ; * - ' • ^ - • » ^ , . . » . . - M A • . - . •*^- . .
• " • • • • — . — — ; ' — ' — ;
' : " • ! . V . . ' . . . ^ . 1 - . V . ., • . . r D e t e n t i o n s l i p e n c l o s e d " " • " • - • - ' • • • • • • • • • • • - • - - - . - ^ ~ . - . . . . i . . ^ ^ r : . ^ : ^ ~ : - - " ^ - . . : ' • . • - . . • - • . . •.•.•.;: - ^ • . . . • . - . = - , - . T . - r i ^ - i . . -J
V ^ ' ; • • ^ • " • • • ; ' • - • • • ^ • • . • • - " .
• . • • ; r : •; v . : : . . r ' ' } - : r i . i . : : ^ i ' y •
• I • I V t ; I t 2 O 0 S Y L V A N S T R E E T . L I N C i N . N J C O S S
P H O N E ; iroiI S£2.20-:>O
^ • H i ^ ^ 4 < l y CI A
]
SOLVENTS RECOVERY SERVICE
OF N E W ENGLAND, INC.
P.O. BOX 362
SOUTHINGTON. CONN. 06489
TELEPHONE: (203) 621-8383
TELECOPIER: (203) 621-0810
April 24, 1990"
Dear Bulk Customer:
We have been notified of a price increase by each of the
three cement and lightweight aggregate kilns utilized by-
Solvents Recovery Service of New England, Inc, (SRSNE).
These kilns claim increased operating costs and ongoing
expenses related to compliance with Environmental
Regulations. I think we all can relate to both.
Effective June 1, 1990, SRSNE must increase our base
price for bulk waste received at our Southington, Connecticut
facility to $0.39 per gallon. BTU, chlorine and water
surcharges will remain the same.
In a related matter, it has been two (2) years since
SRSNE increased transportation rates. Since that time, our
drivers have received two (2) well deserved raises, insurance
rates have increased each year (in spite of our over one
million miles of accident-free driving), and diesel fuel
prices have been as high as $1.69 per gallon.
Effective June 1, 1990, the attached Transportation Rate
Schedule will apply.
If you have questions, please call our Customer Service
Department or your Technical Sales Representative. We
appreciate your past patronage and look forward to working
with you in the future.
Very truly^ft5urs.
Kenneth W. Knight
Vice President
KWK/els
Attachment
00U03B
SOLVENTS RECOVERY SERVICE OF
NEW ENGLAND, INC.
TRANSPORTATION RATES
EFFECTIVE JUNE 1, 199 0
DRUMS DRUMS DRUMS BULK
1-19 20-49 50-T/L TANK TRUCK
CATE ONE-WAY
GORY MILES
1 0-29 170 195 225 275
2 30-49 195 225 260 310
3 50-69 255 290 330 380
4 • 70-89 310 350 400 450
5 90-109 370 420 470 530
6 110-129 430 480 540 610
7 130-149 500 555 615 690
8 150-169 560 625 685 770
9 170-189 625 695 755 850
10 190-209 695 760 825 925
11 210-229 760 830 895 1010
12 230-249 845 900 970 1095
13 250-269 925 975 1040 1150
14 SPECIAL
T/L = TRUCK LOAD
Pricing based on 40,000 pounds maximum load.
Above pricing includes one (1) hour free loading time on tankers,
box vans and LTL shipments. Additional time, if needed, will be
invoiced at.$50 per hour.
Vacuum unit charge $85 per hour while on your site.
Weekend & holiday pickups will be invoiced at rate plus 1/2.
All charges invoiced subject to a 5% insurance surcharge.
All shipments must comply with 40 CFR 268.7 (Notification of
Shipment of Restricted Hazardous Waste) and 40 CFR 172.205
(Identification of Reportable Quantities of Listed Hazardous-
Substances) and be accompanied by an appropriate State Manifest.
^̂,,,.
01)0037
SOLVENTS RECOVERY SERVICE
OF NEW ENGLAND, INC.
P.O. BOX 362
SOUTHINGTON. CONN. 06489
TELEPHONE: (203) 621-8383
TELECOPIER: (203) 621-0810
August 18, 1989
Dear Customer;
As you know, the Hazardous Waste Transporter Fee for all
hazardous wastes manifested or logged for transport in the
Commonwealth of Massachusetts has been assessed at 9.2 cents per
gallon (0.92 cents/pound).
We have been advised that the Commonwealth has increased
this fee to 18.2 cents per gallon (1.82 cents/pound) beginning
on October 1, 1989. Our invoices will reflect this increase for
all wastes that we pick up after October 1st.
We recognize that the costs and responsibilities for the
conscientious management of hazardous wastes are escalating and
we are working to offset these with improved efficiences, new
equipment and processing. We appreciate the confidence you
place in us and we intend to continue to provide prompt and
reliable service to meet your waste management needs.
Kenneth W. Kn^g
Vice Presiden
KWK/e ls
SuKfti-'''
00003S
S O L V E N T S R E C O V E R Y S E R V i C I
O F H E V i E N G L A N D , I N C .
PO BOX 362
SOUTHINGTON, CONN. 06489
TELEPHONE (203) 621-8383
TELECOPIER (203) 621-0810
May 26, 1989
Dear Valued Customer:
On January 6th, 1989, you received a letter from SRS
notifying our customers of " a significant price increase for
drums destined for thermal destruction at Marine Shale (MSP).
My letter also stated that we v.'culd beciin invssticjstincr
additional options as well as continue to negotiate with MSP.
As a direct result, we are pleased to announce a $50 per
drum PRICE REDUCTION on all "ID" Suffix PINs, effective June
1, 1989. Line item 5a and 5b on the attached price list
reflects this reduction. Please note that special handling
solids (contaminated concrete, steel, valves, grating, piping
and steel rods) remain a problem for MSP and are now
surcharged. Please let us know if you have demolition debris.
We have begun consolidating sludges that are debris free.
These sludges may be shredded, ground and liquified into cement
kiln type fuel. This labor intensive operaton demands similiar
pricing to MSP type drums , but allows the use of solids for
their BTU content. Beneficial re-use and energy recovery is
what RCRA is all about.
We will continue negotiating volume discounts with offsite
TSDs like MSP as well as continue our development of SOLIDS-TO
-FUEL programs in an ongoing effort to make SRS your most
economically feasible and environmentally sound waste disposal
option.
Please call your Technical Sales Representative or our
Customer Service Department, if you have any questions.
Kenneth W. Knight
Vice President Sales u
KWK:cp
price reduction
000039
S 0 1 . V Z M T S R E C O V E R Y S E R V I C E
SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC.
DRUM DISPOSAL PRICE SCHEDULE
EFFECTIVE FEBRUARY i, 1989
1. (FD or DD) Organic liquid and viscous sludges in 55 gallon
drums containing basically non-halogenated solvents or oils
(12,500 BTU/# minimum and 2% maximum halogens).
a. less than 1" unpumpable solids $ 65/dr.
b. 1"-12" dispersible viscous sludge 95/dr.
c. 12"-24" dispersible viscous sludge 125/dr.
d. over 24" dispersible viscous sludge 155/dr.
a-d applicable surcharges 9a, b, c
e. consolidated non-dispersible solids for
thermal destruction and/or energy recovery. 425/dr.
2. (HD) Organic halogenated liquids and viscous sludges
in 55 gal. drums containing over 25% halogenated
compounds (primarily FOOl and F002 waste streams)
V. a. less than 1" unpumpable solids $300/dr.
b. 1"-12" dispesible viscous sludge 330/dr.
c. 12"-24" dispersible viscous slduge 360/dr.
d. over 24 " dispersible viscous sludge 390/dr.
a-d applicable surcharge 9c
e. consolidate non-dispersible solids for $495/dr.
thermal destruction and/or energy recovery
3. (CD) Recoverable Solvent
Single spent solvent with dissolved case by case
solids or high boiling liquids
4. (GD) Solids for Landfill
a. 55 gallon drum $145/dr.
b. Overpack 195/dr.
5. (ID) Solids for Thermal Destruction and/or energy recovery
~ a. 55 gallon drum ' * $375/dr. b. Overpack * 525/dr.
«̂. c. reserved
v«.- * Revised 6/1/89
O O U O K ^
SOLVENTS RECOVERY SERVICE
d. subpart "O" incineration 55 gal/dr. case by case
e. subpart "O" incineration 30 gal.fiber case by case
pak
Applicable surcharge 9c
6. (ED) Empty Drums
7. Aqueous Waste
8. Reserved
9. Surcharges:
a. Heat Content
- less than 1" unpumpable solids $ 25/dri
1. 10,000 to 12,499 BTU/#
2. 7,500 to 9,999 BTU/#
3. 5,000 to 7,499 BTU/#
4. 2,500 to 4,999 BTU/#
5. 1,250 to 2,499 BTU/#
Halogen Content
1. 2.1-4%
2. 4.1-7%
3. 7.1-10%
4. 10.1-15%
5. 15.1-20%
6. 20.1-25%
Over 25% see Group 2
c. Shipping Quantity/Per Order
1. 1 - 3 Drums
2. 4 - 9 Drums
10. Miscellaneous Other Charges
a. Overpack Drums
b. Foreign materials not listed in HWDS
i.e., cans, rags, bottles,plastic liners
c. Waste Stream Approval
d. 30 Gallon Drum=75% of 55 gallon price
e. Addition of absorbent to meet landfill
criteria
case by case
$ 10/dr,
2 0/dri
50/dr,
100/dr,
150/dr,
$ 2 5/dr.
50/dr.
75/dr.
120/dr.
175/dr.
225/dr.
$ 50/dr.
20/dr.
$ 50/dr.
100/dr.
$100/stream
$ 25/bag
Please note that an insurance surcharge of 5' is assessed on
all bill charges.
000041
Follow The Leaders
ARINE SHALE PROCESSORS, INC.
MEET SOME OF MSP'S CUSTOMERS
FORTUNE 500 TOP TEN (8 of Top 10)
1. General Motors 2. Exxon 3. Ford Motor Compony 5. Mobil 6. General Electric 7. Texaco 6. AT&T
10. Chrysler Corporation
GOVERNMENT AGENCIES
1. Dept. of Justice- Oct.! 988 2. CIA-Aug.1988 3. Dept. of Energy-Mar. l 989 4. Dept. of Defense - Dec.1988 5. Dept. of State- Dec.1988 6. DEA- Dec.1988 7. Dept. of Agri. - Aug.1988 8. Coast G u a r d - O c t . l 988 9. N A S A - N o v . ! 988
ENVIRONMENTAL COMPANIES
1. Westinghouse 2. GSX Chemical Services 3. M a t l o c k , (a Rollins company)
4. Combustion Engineering 5. O.H. Materials 6. Thermal-Kern 7. Rho-Chemical 8. Solvents Recovery Services 9. IT Corporation
Those kinds of companies are very concerned these days about liability, and that's not a trivial matter. It's not something to be ignored if these large companies are sending their hazardous waste to that facility (MSP).
Mr. Joel Hi rschorn, Congressional Of f i ce of Technology Assessment, in a statement to the Christ ian Science Mon i to r ' s W o r l d M o n i t o r on March 9, 1989.
MSP'S FINISHED PRODUCTS ARE N O N - H A Z A R D O ^ IS THEIRS?
ARSENIC 0.0 0.3 5.0 MERCURY 0.0 0.0 0.2 SELENIUM 0.0 0.0 1.0 CHROMIUM 0.0 - ,0.1 5.0 CADMIUM 0.0 ; y - ^ ^ 1 ̂ mm LEAD 0.4 ^ ^27 ;2 ] BARIUM 0.8 0.4 100.00 BTU/lb. ND KQ^m. N/A
* Actual TCLP results in PPM for aggregate proiduced by MSP, anid samplecJ anid tested by the Louisiana Depar tmen t o f Env i ronmenta l Qua l i ty on November 23, 1988;
** Actual TCLP results in PPM and BTU per/Lb. from incinerator ash received by MSP.
Sales of MSP's slagged aggregate have averaged 100 tons per day during March 1989.
'^^JSi'if''.^ POLLUTION LIABILITY INSURANCE ^ .' s.,"..,.. ^'^.-^
MSP HAS IT! DO THEY? \CAtA::AL,..:.:m^^^^^^^ Afte'r risk assessment, MSP's limits were increased on March"16, 1989,T6 $5,000,000/$5,000,6b0
.-«-ViTf^* ** 1 ̂
- -̂ - •• • per occurrence/aggregate for an additional premium of $31,000 • - ' - . ' . . . . . (Insurance certificate providecJ on request) ; ^"r'^
> ^ ' MSP's gross revenues for the first quarter 1989 are the highest ever!
ENVIRONMENTALVf SAFE
. Marin* Shal* Proc»i»or», Inc. • 110 James Drive Wejt, Suite 120 • St. Rose, LA 70087 • 504 465-3300 • 1.800-USA-MSPJi "Ottffb'Js Circle No. 118 on Reader Service Card I
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D . I N C .
P.O BOX 362
SOUTHINGTON, C O N N . 06489
TELEPHONE: (203) 621-8363
TELECOPIER (203) 628-0810
Dear Valued Customer:
We believe, Solvents Recovery Service of New England's
Transportation Service is second to none. Our driver's are
well trained, courteous and service oriented to all of our
customers. We have upgraded our equipment to include a new
vacuum tanker to reduce the schedule backlog.
It has been over two (2) years since SRS has increased
New England transportation rates. I have attached a chart
designed to standardize our drum and bulk rates based on
miles from our Southington, Connecticut facility.
The price increase is less than 5% average and will be
effective July 1, 1988.
If you have any questions please call your Technical
Sales Representative or our Customer Service Department. We
appreciate your past patronage and look forward to serving
your solvent recovery and waste disposal needs in the near future.
Sintf'erely ,
enneth W. Knight
ales Manager
K W K : c m b
000043
S O L V E N T S R E C O V E R Y S E R V I C E
SOLVENTS KECOVERY SERVICE OF NEW ENGLAND, INC.
TRANSPORTATION RATES
EFFECTIVE JULY 1, 1988
Number of Drums
Category Mi los 1-19 20-49 50- TL
1 0-29 170 195 225
2 30-49 195 225 260
3 50-69 255 290 330
4 70-89 310 350 400
5 90-109 370 420 470
6 110-129 430 480 540
7 130-149 500 555 615
8 150-169 560 625 685
9 170-189 625 695 755
10 190-209 695 760 825
11 210-229 760 830 895
12 230-249 845 900 970
13 250-269 925 975 1040
14 Special
T/L= Truck Load
Tank truck rate is same as T/L.
Pricing based on 40,000 pounds maximuni load.
Above pricing includes one (1) hour free loading time on tankers,
box vans and LTL shipments. AdditiorTdl time, if needed, will be
invoiced at ?5D per hour.
Vacuum unit charge $85 per hour while on your site.
All charges invoiced subject to a 5% insurance surcharge.
All shipments must comply with 40 CFR 268.7 (Notification of ship
ment of restricted hazardous waste) and 40 CFR 172.205 (Identification
of reportable quantities of listed hazardous substances) and be
accompanied by an appropriate state manifest.
000044
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D . I N C .
P O BOX 3 6 2
S O U T H I N G T O N C O N N 0 6 4 8 9
P H O N E i 2 0 3 i 6 2 1 8 3 8 3
October 15th. 1987.
Dear Customer:
Attached are two compliance memoranda addressing
regulatory requirements. The first refers to an annual
update of Hazardous Waste Data Sheets. The second refers to
a notification form that must be attached to the manifests
accompanying all future shipments of "restricted" hazardous
wastes .
Compliance with both of these is mandated under RCRA
rules. Will you please ensure that these are brought to the
attention of the person or department responsible for
regulatory compliance.
Very truly yours.
— >^v=^^C^^
James R. Hulm
Vice President
JRH:dap
Attachments
000045
S O L V E N T S R E C O V E R Y S E R V I C E COMPLIANCE MEMORANDUM
October 1, 1987
Re: Hazardous Waste Data Sheet - Annual Update
The RCRA rules require that the waste analysis that we
receive for each waste stream from each of our customers
must be updated annually. We must also remind you that the
Product Identification Number (PI #) we have assigned to
each of your wastes defines a unique stream. If the nature
of your waste changes or if you add a new stream , we must
have a new Hazardous Waste Data Sheet.
The attached is a list of the PI numbers for which we
have your Hazardous Waste Data Sheets on file. Blank
Hazardous Waste Data Sheets are also attached with the PI
numbers entered at the top right hand corner of each sheet.
We have taken this opportunity to update our Hazardous
Waste Data Sheets to Incorporate some of the recent
regulatory requirements You will notice that we are
including reference to the reportable quantity regulations
and have asked you to use this form for SARA Title III
notification. This is a requirement that we be notified of
any materials that are listed in Appendix A of 40 CFR Part
355
Please fill out a new Sheet for each stream that you
still generate and for any new or changed streams. Note the
instructions on the back side of the Hazardous Waste Data
Sheet, particularly the requirement that each space must be
filled in. If the information is not available or has not
been determined, please note N.A. or N.D. This is a uniform
requirement for all Treatment, Storage and Disposal
Facilities. We are subject to inspection by the EPA and the
DEP and will have no choice but suspend processing your
waste until we have a current Hazardous Waste Data Sheet on
file. We will put this policy into effect on December 1st.
If you have any questions, please call your sales
representative .
Attachments
U 0 0 0 4 B
S O L V E N T S R E C O V E R Y S E R V I C I COMPLIANCE MEMORANDUM
October 1. 1987
Re: Notification of Form to Accompany Manifest Re: Shipment
of a "Restricted" Waste
On July 8th the EPA published their most recent rules limiting
the use of landfills for certain specified wastes. At that time they
included the "California List" in their prohibition. In effect this
expanded on the restrictions and notification requirements we advised
you of in June. We have revised the notification form we suggested
you use and have attached copies of two forms for your use to this letter. We suggest you make xerox copies of these forms for future shipments.
Please note that the notification form is just as important as the manifest and must accompany every shipment of a "restricted"
waste . We are prohibited from accepting anv such waste that is not
accompanied by both the manifest and the notification.
Two forms of notification are attached, one is required when
restricted wastes are shipped to treatment facilities the other when
the waste is shipped for land disposal.
1. Notification of shipment of a hazardous waste restricted from
land disposal.
This is required under 40 CFR 268.7(a)(1) and puts the
treatment facility operator on notice that the hazardous waste
contains a restricted component. It also reminds the operator
of the level to which the contaminant must be removed before any
treatment residues can be land disposed.
Notification of shipment of a restricted waste meeting treatment
standards .
This is required under 40 CFR 268.7(a)(2). It informs the
disposal facility operator that the waste contains a restricted
component that is, or has been treated to be. below the
treatment standard. This must be certified by the generator and
supported either by attached analytical date or by specific
reference, including date and P.l. number, to the Hazardous
Waste Data Sheet you have submitted.
If you have any questions, please call your sales representative.
Attachments 0^^0047
.R,S. or NE\4 ENGLAND INC
392-00 BENJAMIN MOORE COMPANY PG BOX 416 ^9 SUMNER STREET MILFORD MA 01757
PIN DESV-RIPTION
007032-FB RQ UAGTE PETROLEUM DISTILLATE
HAZARDOUS WASTE DATA SHEET n National SOLVENTS RECOVERY SERVICE OF NEW ENGLAND, INC. Association
of Solvent Lazy Lane, Southington, CT 06489 203-621-8383 Recyclers
Transportation Permit #Solid Waste Facility CT DEP/HWM 131-032 CTD.E.P. #CT-HW-148 p.i.# EPA ID# CTD 009717604
GENERATOR AND WASTE IDENTIFICATION | SALESMAN
WASTE DESCRIPTION GENERATOR
ADDRESS
GENERATING PROCESS CITY. STATE, ZIP
TECHNICAL CONTACT
USEPA HAZ WASTE » | | | TITLE
STATE HAZ WASTE • | i | TEL »( ) EXT
LISTED HAZARDOUS SUBSTANCE 49 CFR 172 101 GENERATOR EPA ID »
RO BILL TO
DOT PROPER SHIPPING NAME ADDRESS
CITY. STATE. ZIP
HAZARD CLASS UN/NA. TEL • ( ) EXT
WASTE QUANTITY
QUANTITY UNIT TIME INTERVAL QUANTITY UNIT CONTAINER SIZE AND TYPE
SHIPMENT FREQUENCY PER VOLUME IN STORAGE IN
DESCRIPTION
PHYSICAL STATE D LIQUID O SEMI-SOLID D SOLID TOTAL SOLIDS WT % SUSPENDED SOLIDS WT %
PHASES/LAYERING • UNILAYER D BILAYER D MULTILAYER BTU/» ASH% WATER WT % SP.GR
VISCOSITY D HIGH D li«EDIUM D LOW FLASH POINT "F TYPE
TYPE OF SOLIDS D ORGANIC Q INORGANIC D MIXED PH RANGE FROM TO VAP PRES mm Hg (g 24°C
ODOR D NONE D MILD D STRONG BOILING POINT "C FREEZING POINT "C
C O M P O S I T I O N INCLUDE WATER MUST ADD TO 100% METALS CONTENT PPM BY WT. TOTAL/PPM IN FREE LIQUID
COMPONENT s ARSENIC / SELENIUM / CADMIUM / THALLIUM / CHROMIUM VI / COPPER / LEAD / BARIUM / MERCURY / ZINC / NICKEL 1 / ' SUPPORTING INFORMATION
TOTAL % CHLORINE TOTAL % SULFUR
PESTICIDES D YES n NO HERBICIDES D YES D NO PCBs D YES D NO
AVAILABLE ANALYTICAL DATA ATTACHED D YES O NO
MATERIAL SAFETY DATA SHEETS ATTACHED D YES D NO
IDENTIFY ANY SUBSTANCE IN THIS WASTE LISTED IN SARA TITLE Ml
' SEE 40 CFR 356 App A SPECIAL HANDLING INSTRUCTIONS
CERTIFICATION THE UNDERSIGNED HEREBY CERTIFIES THAT THE ABOVE INFORMATION INCLUDES AN ACCURATE DESCRIPTION OF THE NATURE AND SOURCE OF THE
MATERIAL; THE PHYSICAL PROPERTIES AND CHEMICAL COMPOSITION HAVE BEEN FULLY DESCRIBED USING ALL AVAILABLE INFORMATION AND THAT
ALL KNOWN OR SUSPECTED HAZARDS HAVE BEEN DISCLOSED; THE INSTRUCTIONS ON THE BACK OF THIS FORM H A V E ' B E E N READ AND UNDERSTOOD
ALL SAMPLES SUBMITTED HAVE BEEN TAKEN IN ACCORDANCE WITH SAMPLING PROCEDURES SET FORTH IN 40 CFR 261. THESE SAMPLES MUST BE
OUALIFIED AS CONFORMING TO THIS HAZARDOUS WASTE DATA SHEET AND AS BEING TREATABLE IN SRS's FACILITY THE CHARGE FOR THIS IS $100 THE
UNDERSIGNED AGREES TO ACCEPT. HONOR AND PAY SRS's INVOICE FOR THIS SERVICE.
SIGNATURE
V ^ ^ ^ .AB REPORT ISSUED ON
^PPROVED FOR PROCESSING ON ^PPHOVED FOR QUOTATION ON
3Y oiHl0 4'3 SALESMAN
WHITE. CUSTOMER FILE CANARY. LABORATORY PINK: SALESMAN GOLDENROD GENERATOR
COMPLIANCE MEMORANDUM SOLVENTS RECOVERY SERVICE
October 1, 1987
Re: Notification of Form to Accompany Manifest Re: Shipment
of a "Restricted" Waste
On July 8th the EPA published their most recent rules limiting
the use of landfills for certain specified wastes. At that time they
included the "California List" in their prohibition. In effect this
expanded on the restrictions and notification requirements we advised
you of in June . We have revised the notification form we suggested
you use and have attached copies of two forms for your use to this
letter. We suggest you make xerox copies of these forms for future
shipments .
Please note that the. notification f orm is just ap important as
the manifest and must accomoanv every shipment of a "restricted"
waste. We are orohibited from accepting anv such waste that Is not
accompanied bv both the manifest and the notification.
Two forms of notification are attached , one is required when
restricted wastes are shipped to treatment facilities the other when
the waste is shipped for land disposal.
1. Notification of shipment of a hazardous waste restricted from
land disposal .
This is required under 40 CFR 268.7(a)(1) and puts the
treatment facility operator on notice that the hazardous waste
contains a restricted component. It also reminds the operator
of the level to which the contaminant must be removed before any
treatment residues can be land disposed.
2. Notification of shipment of a restricted waste meeting treatment
standards.
This is required under 40 CFR 268.7(a)(2). It informs the
disposal facility operator that the waste contains a restricted
component that is, or has been treated to be, below the
treatment standard. This must be certified by the generator and
supported either by attached analytical date or by specific
reference, including date and P.I. number, to the Hazardous
Waste Data Sheet you have submitted.
If you have any questions, please call your sales representative.
Attachments U^iOOO'-^
SOLVENTS RECOVERY SERVICE
V NOTIFICATIONOTIFICATIONN OOFF SHIPMENSHIPMENTT OOFF AA HAZARDOUHAZARDOUâ i£iSTE RESTRICTED FROM LAND DISPOSAL
GENERATOR:
ADDRESS:
MANIFEST #:
PI #:
I . Idble_£CH£_^Ccnclilutnt in Wi ExLract 'i. 0 _ C f R _ ^ 6 8 . i l
W.i.';r cw.it e r e A l l O t h e r C o n r f - n t r i i t i o n ( I n mg/1) Conl l i n i n g Sp e n t
Sp'.-nt o l v e n tsf 001,.f005. Sp.;ni._Solv
SOLVENTS R E C O V E R Y SERVICE
NOTIFICATION OF SHIPMENT OF A RESTRICTED WASTE MEETING TREATMENT STANDARS^
CD GENERATOR:
ADDRESS:
MANIFEST # II. "California List" 40 CFR 2flfi.3?
r~| (1) Liquid hazardous wastes have a pH less than or equal to two
PI #: (2.0).
r1 (2) Liquid hazardous wastes containing polychlorlnated blphenyls
(P(iBe) at concentrations greater than or equal to 50 ppm.
I . Tiil>le.-C£W£ -_C&iiijLllu!;DL_la.Jiijsli_ExLraiLl CKR 268 l U • (3) Liquid hazardous wastes that are primarily water and contain halogenated organic compounds (HOCs) in total concentration
W.Tr.t (̂ wat trs All Other greater than or equal to 1,000 rag/1 and less than 10,000 mg/l C o n c e n t r a t i o n ( I n m g / 1 ) ConlHlnlng Spent HOCs.
Spent Solvent
yaate.a
ExLiact AO
f.0 Q U i ) 0 ̂ S v-; ;i r _Sttl-VLen Lfi Siii.VinLa III. "California Llat" RCRA Section 3nn4fd^
Ac et on 0.05 0.59 • (A) Liquid hazardous wastes, including free liquids associated with
n -Buty 1 alcohol 5.0 5.0 any aolld or sludge, containing free cyanides at concentrations
Ca rbon disulfide 1.05 4.81 greater than or equal to 1,000 ng/l.
Ca rbon tetrachloride .05 .96
Ch loro benzene .15 .05 Q (B) Liquid hazardous wastes, Including free liquids associated with
Cr esol B (and creoyllc a d d ) 2.82 .75 any solid or sludge, containing the following metal (or
Cy cloh exanone .75 elements) or compounds of these metals (or eleaents) at .125
1 ,2-dl chlorobenzene concentrations greater than or equal to those specified below: .65 .125
Et hyl acetate ..05 .75
Et hyle benzene .05 .053 (1) arsenic and/or compounds (as As) 500 fflg/1;
Et hyl ether (ii) cadmium and/or compounds (as Cd) 100 mg/1; .05 .75
(111) chromium (VI and/or compounds (as Cr VI) 500 mg/1; In obut a n d 5.0 5.0
Me than ol .25 .75 (iv) lead and/or compounds (as Pb) 500 ag/1;
Me thyl ene chloride .20 .96 (v) aercury and/or compounds (aa Hg) 20 mg/1;
He thyl ene chloride (from the phar (vl) nickel and/or compounds (as Ni) 134 mg/1:
mace utlcal industry) 12.7 .96 (vil) seleniuin and/or compounds (as Se) 100 ag/1: and
(vlil) thallium and/or compounds (as Th) 130 mg/1. He thyl ethyl ketone 0.05 0.75
Me thyl Isobuty1 ketone 0.05 0.33
The attached analysis shows that this waste meets or has been treated NI t rob enzene 0,66 0. 125
to the standard listed above. rldl ne 1.12 0.33
Te t rac hloroethylene 0.079 0.05
CERTIFICATION To luen e 1 . 12 0.33
1 .1 ,1-Trichloroethane 1.05 0.41
I certify under penalty of law that I personally have examined and am 1 ,2,2- Trlchloro-1,2,2-trlfluroethane 1.05 0.96
Tr familiar with the waste through analysis and testing or through Ichl oroethy lene 0.062 0.091
knowledge of the waste to support this certification that the waste Tr Ichl orofluoromethane 0.05 0.96
complies with the treatment standards specified in 40 CFR Part 268 Xy lene 0.05 0. 15
Subpart D and all applicable prohibitions set forth in 40 CFR 268.32
FQ20-F023 and Fn?f,-Fn?fi UastPR or RCRA 3004(d). I believe that the information I submitted is true, CiiiULeiLLx.ailtm accurate and complete. I an aware that there are significant
penaltlea for aubmitting a false certification, Including the HxCDD-All Hexachlorodlbenzo-p-dloxlns
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D , I N C .
P O ROX 3 6 2
S O U T H I N G T O N COMN 0 6 i l 8 9
P H O N E i 2 0 3 i 6 2 1 B 3 8 3
November 9, 1987
Dear Customer:
The Connecticut Department of Environmental Protection
(DEP) has informed us that beginning January 1, 1988 they
will only accept the Connecticut "C" Series manifest for
shipments received at our Southington , Connecticut ,
facility. The State will be sending Connecticut generators
a letter of notification in the near future. Manifests can
be ordered from:
Department of Environmental Protection
Division of Hazardous Waste
Manifest Sales Office
122 Washington Street
Hartford, Connecticut 06106
They are 25
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D . I N C .
f O ROX 3 6 2
S O U T H I N G T O N C O N N 0 6 4 8 9
P M C N C I 2 0 3 > 6 2 1 . 8 3 8 3
June 30, 1987
OO0892
BEN.) AM IM MQORE COMl--piNY
FT) P.O.X 41(S
49 SUMNER STREET
M-TI-.F-ORD
MA 0:1757
ATTNt AL WORSHAM
Dear Customer:
Attached are two compliance memoranda dated 6/17/87 and
6/26/87 addressing recent regulatory requirements. The
first refers to the requirement that waste generators notify
TSDF facility operators of the shipment of restricted
materials. The second refers to the need to identify
containers holding more than a certain reportable quantity
of specific hazardous substances. All future shipments of
hazardous waste are affected by these rules. Will you
please ensure that these shipments are in compliance.
Very truly yours.
/^e^l^L. James R. Hulm
Vice President
JRH:dap
Attachments
OUUUD';
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E ^ V E N G L A N D , I N C .
P O ROX 3 6 2
S O U T H I N G T O N C O N N 0 6 4 8 9
P H O N C I 2 0 3 I 6 2 1 . 8 3 8 3
COMPLIANCE MEMORANDUM June 17, 1987
Re: Notification of Shipment of Restricted Hazardous
Waste as Required Under 40 CFR 268.7
The November 8th landfill ban makes a critical
distinction between waste streams based on use not
composition. The ban restricts specifically the FOOl to
F005 wastes which are described as spent solvents and still
bottoms. Attached are the definitions from 40 CFR part 261
of the F wastes and a clarification of what constitutes a
"spent solvent."
The landfill ban also required generator notification
of the shipment of restricted wastes. This requirement has
been almost universally misinterpreted or ignored. The
notification required is that all shipments of Restricted
hazardous waste (F001-F005) .to any recycling, treatment or
disposal facility carry with them notification by the
generator of the landfill ban treatment standards in Subpart
D of 40 CFR 268.
The EPA has responded to the confusion that this
stipulation caused by issuing a final rule correction. This
was published in the Federal Register on 6/4/87 at 52 FR
21010 and became effective immediately. The correction
acknowledges that ambiguous language in the rule could have
been improperly construed and revised the notification
requirements. The revised rule is now in effect and all
future shipments must be in compliance.
This means that even though virtually no FOOl to F005
wastes are headed for landfill, since they are banned, each
shipment of any F001-F005 waste must be accompanied by the
notification required under 40 CFR 268.7. We have attached
a form of certification that satisfies these requirements.
Please review the attached definitions and attach a signed
copy of this certification to the manifest for all future
covered shipments. We will attach a copy of this
certification to the hazardous waste data sheet we hold in
your file.
Attachments 0 00-055
W h i c h EPA waste codes are affecteci by the
b a n ?
001—The following spent halogenated solvents used degreasing: tetrachioroethylene, trichloroethylene,
methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solutions listed in F002, F004 and F005; and still bottoms from the recovery of those spent solvent mixtures.
F002—The following spent halogenated solvents:
tetrachioroethylene, methylene chloride, trichloroethy
lene, 1,2,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2,-trifluoroethane, ortho-dichlorobenzene
and trichlorofluoromethane; all spent solvent mix
tures/blends containing, before use, a total of ten per
cent or blends containing, before use, a total of ten
percent or more (by volume) of one or more of the
above halogenated solvents or those solvents listed in
FOOl, F004 and F005, and still bottoms from the
recovery of these spent solvents and spent solvent
mixtures.
F005—The following spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, '^yclohexanone, and methanol; all spent solvent mix-ures/blends containing, before use, only the above
spent non-halogenated solvents and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in FOOl, F002, F004 and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
F004—The following spent non-halogenated solvents:
cresols and cresylic acid and nitrobenzene; all spent
solvent mixtures/blends containing, before use, a total
of ten percent or more (by volume) of one or more of
the above non-halogenated solvents or those solvents
listed in FOOl, F002, and F005; and still bottoms from
the recovery of these spent solvents and spent sol
vent mixtures.
F005—The following spent non-halogenated solvents; toluene, methyl ethyl ketone, carbon disulfide, isobutanoi and pyridine, all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in FOOl, F002 and F004, and still bottoms from the recovery of these spent solvent mixtures.
^What is the (difference between a spent solvent (F waste) and other solvent wastes?
A solvent is considered "spent" when it has been
used and is no longer fit for use without being
regenerated, reclaimed or otherwise reprocessed. On
the other hand, process wastes where solvents were used as reactants or ingredients in the formulation of commercial chemical products are not spent solvents. The products themselves are not covered. December 31, 1985 Federal Register.
A solvent that has not been used but is being discarded also would not be considered a "spent" solvent and would not be affected by the November 8 solvent ban. It may be a " P " or " U " waste which will be considered at a later date by U.S. EPA. These wastes are currently scheduled to be evaluated by EPA by August of 1988.
Are all F001-F005 wastes banned from land disposal on November 8, 1986?
No. EPA has granted a 2 year nationwide variance on certain wastes due to inadequate incineration and treatment capacity to treat these banned wastes. The following wastes will not be banned until 1988:
• Solvent wastes of small quantity generators (1001000 kilograms of hazardous waste per month).*
• Solvent wastes generated from any remedial or response action taken under §104 or 106 of CERCLA or any corrective action taken under RCRA.
• Solvent wastes containing less than 1 % (10,000 ppm) total F001-F005 solvent constituents in a solvent-water mixture, a solvent containing sludge or a solvent-contaminated soil.
00005B
Re: Notification of Shipment of Restricted Hazardous
Waste - As Required Under 40 CFR 268.7
Generator :.
Address:
1. Manifest #
2. EPA Hazardous Waste #.
3. This waste contains solvents listed in Table CCWE
40 CFR 268.41. These must be treated to Table CCWE
listed standards prior to land disposal.
4. Attached is available analytical data.
Date Authorized Representative
000057
S O L V E N T S R E C O V E R Y S E R V I C E
O F N E W E N G L A N D . I N C .
P O BOX 3 6 2
B O U T M I N C T O N C O N N 0 6 4 8 9
P H O N E I 2 0 3 1 6 2 1 . 8 3 8 3
COMPLIANCE MEMORANDUM June 26, 1987
Re: Identification of Reportable Quantities of Listed
Hazardous Substances Required Under 49 CFR 172.205
This memorandum is intended to clarify the DOT
requirement that any shipping container of 110 gallons or
less, or any bulk transporters, that contain more than a
specified amount (reportable quantity) of a hazardous
substance be identified.
The new DOT regulations, effective July 1st, 1987, are
designed to ensure that carriers of any hazardous substance
covered by the Comprehensive Environmental Response ,
Compensation and Liability Act (the CERCLA list) can provide
the National Response Center with specific identification in
the event of a spill or release. They have done this by
identifying the CERCLA hazardous substances and mixtures in
an appendix to the 49 CFR 172.101 list of reportable
quantities. Any materials on this list that are either
present in one container in an amount in excess of the
listed reportable quantity or, when in a mixture or
solution, are at a greater concentration than that shown
below for a given corresponding RQ, must be identified.
Concentration bv Weight
RO pounds (kJloErams) Percent PPM
5000 (2270) 10 100.000 1000 (454) 2 -20.000 100 (45.4) 0.2 2.000 10 (4.54) 0.02 200 1 (0.454) 0.002 20
Identification will be by an entry on the label for
containers of less than 110 gallons and on the manifest for
both drums and bulk. This entry must include the notation
RQ and either the specific listing or, in the case of
characteristic wastes (Ignitable, Corrosive, Reactive, EP
Toxic) the wording "EPA Ignitability," "EPA Corrosivity,"
"EPA Reactivity," "EPA EP Toxic." For example RCRA waste
number DOOl has an RQ of lOOi*. The correct US DOT
0 '.> 0 U 5 b
COMPLIANCE MEMORANDUM SOLVENTS RECOVERY SERV.C.
June 26. 1987
Page 2
description in No. 11 of the uniform manifest for a liquid
would be:
RQ Waste flammable liquid NOS (EPA Ignitability)
UN 1993.
For a spent solvent mixture F003 the correct entry
would be:
RQ Waste flammable liquid NOS (F003)
UN1993
This entry must include "F003" despite the fact that F003
must also be entered in Item I.
There is some confusion in the listing of the F
wastes. The RQ for FOOl and F002 is 1#, for F003 and F005,
100# and for F004 , l.OOOi*. However these are the RQ' s for
the lowest listed RQ of each individual constituent , see
attached. The conflict arises between whether an F003
waste , a listed hazardous substance , that is spent toluene
also listed should be labelled as a "reportable quantity"
because there is 100# of F003 in a drum or not labelled
because the RQ for spent toluene is 1,000)?.
This conflict can be resolved by labelling all F wastes
as reportable quantities, RQ before the shipping name,
followed by FOOl through F005 in parenthesis after the name.
Labelling all F wastes with "RQ" followed by FOOl
through F005 in parenthesis after the shipping name will
satisfy the regulation.
The U series of wastes are compound specific. Once It
has been decided that each containe