REPORT ON

FUSION PAPERBOARD CLOSURE PLAN

130 INLAND ROAD
VERSAILLES, CONNECTICUT, 06383
BY
Haley & Aldrich, Inc.
Rocky Hill, Connecticut
FOR
Fusion Paperboard
Versailles, Connecticut
File No. 41382-971
12 September 2014
11 September 2014
File No. 41382-971
Fusion Paperboard
130 Inland Road
Versailles, Connecticut 06383
Attention: Susan Stucker
Subject: Fusion Paperboard Closure Plan
130 Inland Road
Versailles, Connecticut 06383
Dear Ms. Stucker:
Haley & Aldrich, Inc. (Haley & Aldrich) prepared the subject Facility Closure Plan detailing the
activities associated with the ceasing of operations at the Fusion Paperboard Connecticut, LLC Facility
in Versailles, Connecticut. The attached Facility Closure Plan is in response to the 26 August 2014
letter from Oswald Inglese, Jr., Director Water Permitting and Enforcement Division Bureau of
Materials Management and Compliance Assurance, Connecticut Department of Energy &
Environmental Protection (CTDEEP). The attached plan addresses the ten items outlined in the two-
page attachment to the referenced CTDEEP letter.
Discussions with CTDEEP regarding conceptual plans for the closure of the wastewater treatment
system are ongoing and will be detailed in a separate plan. We have also included an anticipated
schedule for the remaining closure activities as part of the closure plan. Please note that the 26 August
letter requests that this plan be submitted for approval on or before 12 September 2014.
We would like to thank all the Fusion personnel who assisted us in developing the closure plan. Please
contact us if you have any questions or comments.
Sincerely yours,
HALEY & ALDRICH, INC.
Nagi R. Alla
Assistant Project Manager
Clayton M. Orwig
Client Leader
Enclosures
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Haley & Aldrich, Inc.
100 Corporate Place
Suite 105
Rocky Hill, CT 06067
Tel: 860.282.9400
Fax: 860.721.0612
HaleyAldrich.com
TABLE OF CONTENTS
Page
LIST OF TABLES ii
LIST OF FIGURES ii
1. INTRODUCTION AND SITE HISTORY 1
2. SITE OPERATIONS 1
3. PLANT SHUTDOWN 2
3.1 Production Equipment Disposition 2
3.2 Wastewater 2
3.3 Virgin Chemicals 3
3.4 Raw Materials 3
3.5 Gas Cylinders 3
3.6 Production Solid Waste 3
3.7 Miscellaneous Equipment/Material Disposition 3
3.8 Hazardous Waste Disposal 4
3.9 Oils/Greases Disposition 4
3.10 Ionizing Radiation Equipment 4
3.11 WWTP Decommissioning 4
4. SCHEDULE 5
TABLES
FIGURES
APPENDIX A - CTDEEP Letter Dated 26 August 2014
i
LIST OF TABLES
Table No. Title
I Fusion Paperboard Closure Inventory
LIST OF FIGURES
Figure No. Title
1 Project Locus
2 Site Plan
ii
1. INTRODUCTION AND SITE HISTORY
The Fusion Paperboard Mill is a recycled paperboard mill located at 130 Inland Road in Versailles,
New London County, Connecticut (refer to Figure 1 for the Project Locus). The Facility is located in a
mixed industrial/residential area of Versailles, Connecticut. A Site Plan is provided as Figure 2.
The Fusion Paperboard Mill was previously owned by Cascades Boxboard Group- Connecticut LLC,
Versailles Mill (Cascades). Cascades also manufactured paperboard materials using 100% post-
consumer paper products at the facility. Prior to Cascades, the mill was formerly owned and operated
by Sprague Paperboard (a wholly owned subsidiary of Caraustar Industries, Inc.), International Paper
(IP), and the Federal Paper Board Company (Federal). Federal built the mill in 1962 on a 500-acre site
that originally had been developed for three mills at the beginning of the 20th century. In 1996, Federal
merged with IP, and in 1999, Sprague purchased the mill from IP. In 2006, Sprague sold the mill to
Cascades. In 2011, Cascades sold the mill to Fusion.
2. SITE OPERATIONS
Fusion produced recycled cardboard and other specialty grades paperboard products with 100%
recycled fibers from waste paper. This facility was one of the key components of an essential recycling
infrastructure to reduce land filling of used fibers. Manufacturing recycled boxboard required
mechanically breaking down waste paper in the presence of water to form a liquid pulp. The pulp was
then cleaned by removing impurities such as dirt, plastic, extruded polystyrene, staples and other
foreign matter. After cleaning, the pulp was refined using a mechanical process to break down
individual fibers before sending the fibers to the paper machine. The pulp was spread on a porous
fabric that allowed for the removal of water, forming a wet sheet. This sheet was then dewatered and
dried and a white clay coating was added on top for printing purposes. The facility manufactured rolls
of paperboard sheet which it sent to customers that performed the conversion including printing, cutting
and folding.
During the course of manufacturing, the facility generated both wastewater and solid waste. The mill
pre-treated wastewater onsite in its treatment plant (WWTP) prior to being discharged to the City of
Norwich Public Utilities Water Pollution Control Facility. Normal production operations at Fusion
Paperboard included the collection of fibrous pulpy water through floor drains and sumps throughout
the facility. The facility is constructed with a basement, floor drains and sumps for the express purpose
of capturing and recycling all water within the facility. The collected water was filtered and recycled
into the product feed material. This was accomplished at the save-all unit, which is a rotating filter
system that captures the fibers and incorporates them into the product. The save-all also routed
excess water and pulp to the WWTP. The wastewater went through both primary and secondary
treatment. The primary treatment consisted of two dissolved flotation units located in the facility to
remove total suspended solids (TSS). After the primary treatment, a gravity system conveyed the
wastewater from the mill to the flocculator. The wastewater was pumped directly to the secondary
treatment consisting of biological oxidation demand (BOD) removal. BOD removal consisted of two
steps: biological degradation and TSS removal. The system used an aerated stabilization basin for
biological degradation. Originally the process employed three basins, but it was reported that Cascades
reconfigured the treatment system and took two ASBs out of service in 2009. The present system used
only one ASB (ASB#3).
Solid waste generated consisted of impurities such as dirt, plastic, extruded polystyrene, staples and
other foreign matter in the incoming raw material (recycled paper). These were generated at the pulp
1
machine. The waste material went from the pulp machine to the cleaners and screened to separate the
waste based on size. This process generated waste paper machine rejects (smaller material) and tails
(sheets of paper approximately 6 to 12 inches wide and several feet long). The paper machine rejects
were sent through a squeeze press machine where the rejects were drained of water before being sent to
an off-site facility for disposal. The tails generated were also sent to an off-site facility for disposal.
3. PLANT SHUTDOWN
On 23 July 2014, Fusion announced the cessation of all manufacturing operations. After shutdown on
13 August 2014, Fusion personnel started planning for removal of all virgin and waste chemicals,
solvents, oils and any other process materials at the facility, arranging for return to vendors or disposal
off-site. It is anticipated that the process will be completed by 22 September 2014.
There is an inventory of all chemicals, solvents, oils and other process materials included as Table I.
All waste and virgin chemicals are staged in the warehouse prior to being returned or sent for disposal.
Used oil and greases are staged in the Tow Motor Shop prior to shipment. The inventory includes the
anticipated or actual method of disposal, treatment or destination for each item that is currently in the
facility. Once an inventoried item is actually shipped out, the tracking spreadsheet will record the
actual quantity and final destination. Bills of Lading, manifests and weight tickets will be retained at
the Fusion facility and submitted to the appropriate agencies as required.
3.1 Production Equipment Disposition
All of the facilitys production equipment as listed below has been sold to a Buyer (Confidential
Business Information). As part of the agreement between Buyer (Confidential Business
Information) and Fusion, the equipment will be removed within six months beginning 22
September 2014 and concluding in February of 2015. The equipment sold to Buyer
(Confidential Business Information) is listed below:
Paperboard machine (in its entirety);
Ionizing radiation equipment (part of the paperboard machine);
Pulp processing equipment (in its entirety);
Coating and mixing equipment (in its entirety);
Laboratory equipment (in its entirety);
Powerhouse equipment (in its entirety);
Rolling stock (in its entirety, including forklifts, facility vehicles, etc.); and
Tools and hardware (in their entirety).
3.2 Wastewater
The wastewater discharge from all of the process equipment was previously collected and
recycled in the manufacturing process and ultimately treated at the wastewater pretreatment
system as described above. Wastewater generated after shutdown consists of wash water from
floors and rinse water from tanks. Fusion also has nine bulk tanks containing coatings used in
the production of paper. The contents of the coating bulk tanks will be pumped out into totes
or to a tanker truck for return to the supplier. The tanks will be rinsed and the initial rinse
water will be collected and properly characterized before being disposed. The tanks will then
be rinsed twice with approximately 200 to 300 gallons of water per tank. Fusion filed for a
wastewater pre-treatment permit modification with CTDEEP and received approval on
2
29 August 2014 for the second and third rinse waters to be treated in the WWTP prior to being
discharged to City of Norwich POTW.
Fusion started implementing the cleaning in early August and plans to complete it by end of
September. Fusion estimates generating approximately 1 million gallons during this process.
3.3 Virgin Chemicals
Most of the virgin chemicals are housed in totes in the warehouse. The bulk tanks containing
virgin chemicals are located in the basement. The unused virgin chemicals will be returned to
the vendor. Any unreturnable chemicals will be moved to the waste storage area in the
warehouse and profiled prior to disposal at an authorized disposal facility. Fusion anticipates
completing this process by 22 September 2014.
3.4 Raw Materials
Raw materials including baled or loose cardboard present in the warehouse and the facility yard
will be sold to separate entities. The various entities are listed on Table I. The raw material
storage area (facility yard) will be cleaned after all the raw material has been shipped out to
prevent storm water contamination.
3.5 Gas Cylinders
Calibration, welding and specialty gas cylinders used in the maintenance area and the
powerhouse will be returned to the vendor as listed on Table I. Fusion is determining the final
destination for the fire protection and first aid medical gas cylinders present in various locations
of the manufacturing plant.
3.6 Production Solid Waste
This waste includes the paper machine rejects, tails and coating chemicals that were removed
from the equipment after shutdown. The paper machine rejects and tails were collected outside
in the west end of the manufacturing building in containers. The rejects along with the tails
were generated daily during routine production. These waste streams have been profiled and
sent off for disposal. Invoice records of pickup quantities and dates are being maintained and
summarized in the inventory. The waste coating chemicals were pumped from the equipment
into totes and staged with the other waste before being profiled for disposal.
3.7 Miscellaneous Equipment/Material Disposition
Miscellaneous equipment including various pumps and tanks were rented from outside entities.
This equipment will be returned to the original owner. Miscellaneous scrap wood and scrap
metal at the facility is collected and will be shipped for recycling.
3
3.8 Hazardous Waste Disposal
Hazardous waste generated from closure included waste aerosols and miscellaneous small
quantities of flammable and corrosive liquids. Additional miscellaneous chemicals in small
quantities are being collected in the Tow Motor Shop and the powerhouse prior to being
classified by a Tradebe lab pack chemist and picked up by Tradebe Treatment and Recycling
LLC for disposal. The individual streams are listed along with the quantities in the inventory
spreadsheet Table I. Parts cleaning solvents from the maintenance area were pumped into
drums and picked up by Safety-Kleen for disposal.
3.9 Oils/Greases Disposition
Drums containing virgin oil and greases will be returned to the vendor. Used oil from the
manufacturing plant and the powerhouse will be pumped directly into a tanker truck by Tradebe
Treatment and Recycling Northeast, LLC for disposal. Drums containing grease that have been
opened will be picked up for disposal. Used Oily Rags & Absorbents (Grease) from cleaning
equipment will be collected in drums for disposal.
The one million gallon above ground storage tank (AST) holding No. 6 fuel oil next to the
powerhouse is estimated to contain approximately 50,000 gallons. Fusion is seeking options to
sell the oil.
3.10 Ionizing Radiation Equipment
Fusion Paperboard Connecticut, LLC utilized three x-ray devices as part of the papermaking
machine. These three devices included five sealed sources of radioactive material. The
equipment was leased from Metso Automation USA, Inc. and Fusion maintained a Certificate
of Use with CTDEEP for the Radioactive Material and Industrial X-Ray Device Registration.
The three devices (five sources), their serial numbers and specific source information are:
The five sources will be transferred to Buyer (Confidential Business Information). Buyer
(Confidential Business Information) will be returning the five sources to Metso Automation
USA, Inc. for storage following all required and appropriate notifications and preparations for
their ultimate removal and transportation.
3.11 WWTP Decommissioning
The plan for decommissioning of the WWTP, including the characterization and disposal of the
wastewater sludge, is being closely coordinated with CTDEEP. It is anticipated that the
wastewater treatment system will need to operate through the facility closure process and the
lagoon sediment and sludge treatment and disposal project. The assessment is ongoing and the
Device Source
Model # Serial # Location Isotope Serial #
BWM-T 20395356 After Dryer Kr-85 TK929
Kr-85 TK930
BWM-T 21747191 Reel Kr-85 7577BX
Kr-85 7578BX
BWM-H 18725523 Wet Press Sr 90 GI608
4
plant staff are discussing the regulatory and programmatic requirements with CTDEEP as part
of an ongoing process. The initial results of the sludge samples collected by CTDEEP in all of
the lagoons (ASBs and polishing lagoons) indicate the sludge is nonhazardous. Fusion will
conduct additional sampling to characterize the sludge and estimate its volume.
Fusion Paperboard will present conceptual plans for decommissioning the WWTP and the
handling and disposing of the sludge and sediment. Detailed plans and cost estimates will be
developed for submittal and approval of CTDEEP once the conceptual approach is agreed
upon.
4. SCHEDULE
Closure activities are currently in progress including implementation of the closure plan. Below is an
anticipated schedule for additional closure activities.
Activities Anticipated Completion
Disposition of Materials/Waste at the Facility 22 September 2014
Closure Plan for the three Aerated Stabilization
Basins/two Polishing Lagoons
17 October 2014
Outstanding Notices of Violation 31 October 2014
Equipment Removal February 2015
WWTP Decommissioning To Be Determined
Permit Revocations 29 September 2014- 13 March 2015
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5






















TABLES



























Page1of4
TABLEI
FusionPaperboardClosureInventory
FusionPaperboard,Versailles,CT
Name
Numberof
Containers
TypeofContainer Quantity Units Location/AreaStored PlanforRemoval FinalDestination
WeldingGas 52 Cylinders Maintenance/Powerhouse Return AirgasUSA,LLC
KOFilm80 15 Totes 30,000 Pounds Warehouse Sold
IngredientIncorporated(Logistics
ManagementSystems)
DTEPM220Oil 3 Drum 165 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
DTEExtraHeavyOil 1 Drum 55 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
MobilSHCGear310Oil 3 Drum 390 Pounds TowMotorShop Return L.F.PowersCo.,Inc.
PolyrexEMOil 1 Drum 120 Pounds TowMotorShop Return L.F.PowersCo.,Inc.
MobilSHC634Oil 1 Drum 55 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
DTE732Oil 2 Drum 110 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
DTE24Oil 3 Drum 165 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
DTEHeavyMediumOil 2 Drum 110 Gallons TowMotorShop Return L.F.PowersCo.,Inc.
SHCPM460Grease 3 Drum 224 Pounds TowMotorShop Return L.F.PowersCo.,Inc.
MobilSHCGear220 Drum 390 Pounds TowMotorShop Return L.F.PowersCo.,Inc.
300gallonemptyverticalroundtank 1 Tank TowMotorShop Return L.F.PowersCo.,Inc.
330gallonhorizontaltank 1 Tank TowMotorShop Return L.F.PowersCo.,Inc.
550gallonroundtanks 3 Tank TowMotorShop Return L.F.PowersCo.,Inc.
HuskyDiaphramPump 1 Pump TowMotorShop Return L.F.PowersCo.,Inc.
Unibins(UsedOilyRags&Absorbents) 2 Totes 660 Gallons TowMotorShop Disposal
TradebeTreatmentandRecyclingNortheast,
LLC
EmptyNitricOxide/NitrogenGas 5 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullNitricOxide/NitrogenGas 4 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
EmptyOxygen/NitrogenGas 1 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullOxygen/NitrogenGas 10 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullNitricOxide/OxygenGas 1 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullArgonGas 1 Cylinders(60") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullNitrogenGas 1 Cylinders(60") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullOxygenGas 1 Cylinders(48") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FullAcetyleneGas 1 Cylinders(36") Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
SoBind
TM
BalanceLVHSoyPolymer 17/17 Bags/Pallets 13,301 Kilogram Warehouse Return Solae,LLC
Polyco3103NPEmulsion 14 Totes 40,000 Pounds Warehouse Sold Buyer(ConfidentialBusinessInformation)
KaoglossPlus(Tank1) 3 TankTruck 79,520 Pounds Warehouse Sold Buyer(ConfidentialBusinessInformation)
KaoglossPlus(Tank2) 1 Tank 6,500 Gallons Basement Sold Buyer(ConfidentialBusinessInformation)
UsedOilandLubricants 2 TankTruck 5,047 Gallons TowMotorShop Disposal
TradebeTreatmentandRecyclingNortheast,
LLC
HALEY&ALDRICH,INC.
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Page2of4
Name
Numberof
Containers
TypeofContainer Quantity Units Location/AreaStored PlanforRemoval FinalDestination
RCRAEmptyDrums(Containedusedoiland
grease)
28 Drum 525 Pounds TowMotorShop Disposal
TradebeTreatmentandRecyclingof
Bridgeport,LLC
UsedOilyRags&Absorbents(Grease) 1 WoodenBox 300 Pounds TowMotorShop Disposal
TradebeTreatmentandRecyclingof
Bridgeport,LLC
UsedCoatingsSolidified 1 WoodenBox 1,600 Pounds Warehouse Disposal
TradebeTreatmentandRecyclingof
Bridgeport,LLC
Batteries(Acid,Alkaline) 5 Drum 240 Pounds TowMotorShop Disposal NorthCoastServices,LLC
EmptyHydrochloricAcidDrums 13 Drum 425 Pounds FlocculatorBuilding Return Univar
EmptySodiumHypochloriteDrums 8 Totes 1,400 Pounds FlocculatorBuilding Return Univar
EmptyFerricChlorideDrums 6 Drum 150 Pounds Powerhouse Return Univar
RhoplexRM232D 2 Totes 4,665 Pounds Warehouse Return RohChem
Basoplast3535 1 Totes 3,144 Pounds Warehouse Sold BASFCorporation
Percol292 4 Totes 8,172 Pounds Warehouse Sold BASFCorporation
SolarPBlueCP 1 Totes 2,337 Pounds Warehouse Sold BASFCorporation
PaperMachineRejects 22 DumpTrailer 458 Tons WestCornerofManufacturingPlant Disposal WillimanticWastePaperCO.,INC.
PaperMachineTails 1 DumpTrailer 17 Tons WestCornerofManufacturingPlant Disposal WillimanticWastePaperCO.,INC.
AllProductionEquipment ManufacturingPlant/Powehouse Sold Buyer(ConfidentialBusinessInformation)
ProductionEquipmentWashwaterand
Rinsate
1,000,000 Gallons ManufacturingPlant Treatment/Discharge
NorwichPubliclyOwnedTreatmentWorks
(POTW)
EthyleneGlycol 15 Totes 4,500 Gallons ManufacturingPlant Disposal
TradebeTreatmentandRecyclingNortheast,
LLC/KroppEnvironmentalContractorsInc
PartsCleaningSolvents 2 Drum 38 Gallons Maintenance Disposal SafetyKleenSystems,Inc.
WasteAerosols 1 Drum 30 Pounds Powerhouse Disposal TradebeTreatmentandRecyclingLLC
LabPack(Gasoline,OilBasedPaint,Honing
OilPetroelumDistillates,DenaturedAlcohol,
N,NDimethylformamide,Ink,LinseedOil,
MethylAlcohol,ContactCementMethyl
EthylKetone,Toluene,PipeJointCompound,
Isopropanol)
1 Drum 200 Pounds Powerhouse Disposal TradebeTreatmentandRecyclingLLC
LabPack(Diisopropylamine,BrokenGlass
Diisopropylamine,Hexamethylenetetramine,
Isopropanol,HydroxylamineHydrochloride)
1 Drum 5 Pounds Powerhouse Disposal TradebeTreatmentandRecyclingLLC
LabPack(SulfuricAcid,DemineralizedWater) 1 Drum 6 Pounds Powerhouse Disposal TradebeTreatmentandRecyclingLLC
HALEY&ALDRICH,INC.
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September2014
Page3of4
Name
Numberof
Containers
TypeofContainer Quantity Units Location/AreaStored PlanforRemoval FinalDestination
MiscellaneousEquipment(pumpskids) 2 ManufacturingPlant Return RegionalCommerceCenter
#6FuelOil(liquid) 1 VerticalAST 50,000 Gallons Powerhouse Sold/Disposal KroppEnvironmentalContractorsInc
#6FuelOil(solidtankbottomstills) 1 VerticalAST 2 Tons Powerhouse Sold/Disposal KroppEnvironmentalContractorsInc
PropaneTanks 3 HorizontalAST 3,000 Pounds Various Maintain Forklifts
DieselFuel 1 HorizontalAST 1,000 Gallons DieselFuelUnloadingArea Maintain EquipmentRefuelling
DieselFuel 1 HorizontalAST 275 Gallons MillRawWaterIntakeBuilding Maintain BackupFireProtectionWaterPumps
DieselFuel 1 HorizontalAST 275 Gallons OldMillBuilding Maintain BackupFireProtectionWaterPumps
MineralOilDielectricFluid(MODF) 14 Transformers 7,501 Gallons Various Maintain
RadiationSources 1 Gauge 5
Sealed
Source
PapermakingMachine Return MetsoAutomationUSA,Inc.
ScrapMetal#1 1 DumpTrailer 40,000 Pounds Powerhouse(covered) Recycle M&JAutoRecycling
ScrapMetal#2 1 DumpTrailer 40,000 Pounds FacilityYard Recycle CalamariRecyclingCo.,Inc.
ScrapWood#1(Pallets) 1 DumpTrailer 15,000 Pounds Powerhouse(covered) Recycle WillimanticWastePaperCO.,INC.
ScrapWood#2(Pallets) 1 DumpTrailer 15,000 Pounds FacilityYard Recycle WillimanticWastePaperCO.,INC.
OCCOldCorrugatedCartonsBaled PavedLot 330 Tons FacilityYard Sold Buyer(ConfidentialBusinessInformation)
OCCOldCorrugatedCartonsBaled PavedLot 280 Tons FacilityYard Sold RockTennCompany
OCCOldCorrugatedCartonsBaled PavedLot 390 Tons FacilityYard Sold CanusaHershmanRecyclingCompany
OCCOldCorrugatedCartonsLoose PavedLot 300 Tons FacilityYard Disposal
WheelabratorLisbonResourceRecovery
Facility
AdditionalSpecialtyGasCyclinders TBD Cylinders Powerhouse/Maintenance Return LindeElectronicsandSpecialtyGases
FirstAidMedicalGases TBD Cylinders 10 FirstAidLocations Return AirgasUSA,LLC
AdditionalLabPacks TBD TBD TBD TBD Powerhouse Disposal
TradebeTreatmentandRecyclingNortheast,
LLC/KroppEnvironmentalContractorsInc
BulkSodiumHydroxide 1 Tank 1,378 Gallons Powerhouse Disposal TradebeTreatmentandRecyclingLLC
SodiumHypochlorite 2 Totes 375 Gallons Powerhouse Disposal TradebeTreatmentandRecyclingLLC
BulkSulfuricAcid 1 Tank 614 Gallons Powerhouse Disposal TradebeTreatmentandRecyclingLLC
SodaAsh 1 Drum 30 Gallons PumphouseB Disposal TradebeTreatmentandRecyclingLLC
Bulk1754Phophate 1 Tank 270 Gallons Powerhouse Disposal TradebeTreatmentandRecyclingLLC
"TIPURE"RPSVANTAGE TBD Tank 2,500 Gallons Basement Sold Buyer(ConfidentialBusinessInformation)
CartabondLSZLIQ 3 Totes 8,250 Pounds Warehouse Return Archroma
AcronolS504 TBD Tank 5,300 Gallons RailCar Sold Cascades
Sunbond3410 TBD Tank 4,500 Gallons Basement Sold Buyer(ConfidentialBusinessInformation)
LopaquePlus 2 Tank 3,000 Gallons Basement Sold Buyer(ConfidentialBusinessInformation)
CartaCoat 5 Totes 11,000 Pounds Warehouse
HALEY&ALDRICH,INC.
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September2014
Page4of4
Name
Numberof
Containers
TypeofContainer Quantity Units Location/AreaStored PlanforRemoval FinalDestination
FirstRinsatefrom9BulkTanks("TIPURE"
RPSVANTAGE,CartabondLSZLIQ,Acronol
S504,KaoglossPlus,Sunbond3410,Polyco
3103NPEmulsion)
TBD Tank TBD Gallons Basement Disposal
TradebeTreatmentandRecyclingNortheast,
LLC/KroppEnvironmentalContractorsInc
WSM192 5 Totes 11,175 Pounds Warehouse Return DuboisChemicalsInc.
CL206 2 Totes 5,292 Pounds Warehouse Return Chemtreat
FO180 2 Totes 4,404 Pounds Warehouse Return Chemtreat
FE212 2 Totes 4,712 Pounds Warehouse Return Chemtreat
FE111 1 Totes 2,298 Pounds Warehouse Return Chemtreat
CL2250 1 Totes 2,356 Pounds Warehouse Return Chemtreat
BL1283DRM 1 Totes 458 Pounds Warehouse Return Chemtreat
AF4810 8 Totes 5,292 Pounds Warehouse Return Axchem
Notes:
""NotApplicable
"TBD"TobeDetermined
HALEY&ALDRICH,INC.
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FIGURES




























SCALE: 1:24,000
SEPTEMBER 2014 FIGURE 1
PROJECT LOCUS
130 INLAND ROAD
VERSAILLES, CONNECTICUT
4
1
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9
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1

1
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U.S.G.S. QUADRANGLE: NORWICH, CT
SITE COORDINATES: 4137'24"N,722'34"W
SITE
ASB-1
ASB-2
ASB-3
POLISHING
POND 1
POLISHING
POND 2
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PAPERMILL
POND
POWERHOUSE
PAPER MACHINE
REJECTS/TAILS
STORAGE AREA
FACILTY
YARD
#6 FUEL
OIL TANK
OFFICES
MANUFACTURING PLANT
(WAREHOUSE,
MAINTENANCE, BASEMENT,
TOW MOTOR SHOP)
N
W E
S
0 300 600
APPROXIMATE SCALE IN FEET
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FIGURE 2
130 INLAND ROAD
VERSAILLES, CONNECTICUT
SITE PLAN
SCALE: AS SHOWN
SEPTEMBER 2014
NOTE
1. BASE PLAN BASED ON ESRI-GIS IMAGE.

APPENDIX A

CTDEEP LETTER DATED 26 AUGUST 2014