Wednesday, September 13, 2017

Chronology of Events Connected with the UCONN Landfill and Chemical Pits Remediation: 1960 to 2017

Introduction

The University of Connecticut operated a sanitary landfill and chemical pits just north of its main campus in Mansfield, Connecticut from 1966 until 1982 when the Connecticut Department of Environmental Protection ordered these disposal sites closed.  The history of this landfill and the contentious debates about its impact upon the health of Mansfield residents and their drinking water has become a classic example of government mismanagement of public health and environmental issues.  The University of Connecticut is an agency of the State of Connecticut and as such has enjoyed some of the extra-legal privileges that are often given by its sister agencies - the Department of Public Health and Department of Environmental Protection.  The chronology of events over the last fifty years clearly shows state agencies (i.e. Dept. of Public Health and Dept. of Environmental Protection) taking a desultory approach to the enforcement of state laws with limited use of their inspection and oversight functions.  This chronology reveals the importance of citizen action in holding government agencies and polluters responsible for their actions.

For years the University of Connecticut (UCONN) operated with little environmental oversight by its own administration.   While the university operated a sewage treatment plant and a public drinking water supply for nearly 100 years and a landfill and chemical pits for approximately sixteen (16) years, the university did not retain environmental staff to oversee its vast regulatory responsibilities until 2002. Most American universities began hiring environmental staff with regulatory experience in the 1980s and early 1990s.  In contrast, UCONN relied on attorneys and generalists to deal with its environmental regulatory issues until the burdens of compliance and frequency of code violations became overwhelming and a total embarrassment to the university administrators.

It is rare to compile a history of a landfill closure project such as this attached timeline.  Most Americans would rather bury their waste and forget about it.  The reason this chronology was prepared is to underscore the importance of citizen involvement in the design, development and closure of sanitary and hazardous waste landfills.  All too often, these regulatory processes are of little interest to citizens – until there is clear evidence of a public health threat.
Limits of Plume as of 2013: Note: Earlier Limits of 
Plume in the 1960s and 1970s Were Never Quantified

A review of the landfill’s history suggests five key lessons learned:

Landfills Should Be Banned In Connecticut:  The notion that waste should not be buried never occurred to our forefathers or to those who approved the UCONN landfill and chemical pits.  A sustainable future depends on the elimination of waste through source reduction, recycling and reuse.  Landfills are a No – No.  While this lesson has already been learned by Connecticut environmental regulators, it was not understood at the time UCONN granted approval to establish a landfill by the Connecticut Department of Health.

Environmental & Public Health Agencies Border on the Dysfunctional:  While the State of Connecticut has some excellent regulatory controls over sanitary and hazardous waste disposal operations, there is little funding available to inspect, monitor and conduct thorough multi-media audits of environmental “bad actors.”  This state of affairs has emerged over several decades as the Department of Environmental Protection has gradually lost funding for many of its essential functions.  The lesson learned is that citizen involvement is an essential pre-requisite for the proper functioning of state environmental regulations. The squeaky wheel gets the grease.

UCONN is Not to be Trusted as Long as it Has the Powers of a State Agency:  While UCONN is a state agency and presumably operates in the public interest, this belies the reality that it is a major corporation with business interests in sharp contrast with those of its neighbors in Mansfield.  Mansfield citizens overwhelmingly voiced their disapproval of UCONN’s approach to the closure of its landfill and chemical pits.  This distrust continues even today – largely because UCONN’s mission is less about the public interest and more about its own self-interest.

Landfill Closures are a Life-Time Process and Continue to Pose Health Risks.  It took UCONN twenty seven (27) years to complete its landfill closure process and it now is responsible for maintaining the integrity of the landfill closure system for another thirty years (i.e. circa 2036).  While many citizens would like to forget about this landfill, the following chronology makes it clear that citizens must be ever vigilant about any activities that may directly or indirectly affect the discharge of contaminated effluent from the former landfill and chemical pits.  Any developments located near to the former landfill and chemical pits can influence groundwater and surface water patterns which in turn can influence the pattern and intensity of leachate discharge.  The University of Connecticut never placed land use restrictions on property downgradient of the former landfill and chemical pits – even though this was recommended by their consultants.

Untold Health Consequences from Exposure to Contaminated Drinking Water.   While UCONN and the Connecticut DEP spent enormous amounts of money on documenting groundwater contamination, all of this work was done many years after the real time drinking water exposures occurred to nearby residents. From 1966 to 1982 contaminated groundwater downgradient of the landfill may have polluted many more wells than were identified by subsequent testing regimens.  With the leachate plume traveling at a speed of 1.3 miles per year, the public health impacts of UCONN’s landfill will never be known – even though there is extensive anecdotal evidence that many neighbors succumbed to various forms of cancer and other diseases prior to, during and subsequent to the landfill and chemical pits closure. The full human and environmental consequences of the landfill will never be told because the most egregious exposures occurred long before any testing was undertaken.

Date
Description
Reference
1960s
UCONN Incinerates Most Radioactive Waste
Some radioactive waste is also poured down the drain and some is buried in landfill. Historical records, interviews with Poultry Science Dept., School of Pharmacy, and six other science departments as well as an interview with the UCONN Director of Environmental, Health & Safety confirm extensive period of irresponsible low level radio-active waste disposal.
Haley & Aldrich, Comprehensive Hydro-geologic Investigation and Remedial Action Plan, Addendum No. 2, July 2004
September 1, 1965
CT Department of Health Services (DHS) Regulates Landfills.
The state legislature authorizes DHS to regulate refuse disposal plants and none can be built without the agency’s approval.
Connecticut State Legislature, Public Act No. 508, September 1, 1965
May 23, 1966
Site for Landfill is Purchased by UCONN.
UCONN purchases 102.7 acres of wooded land from Claude & Anna Costello which becomes the site of future landfill.
Haley & Aldrich Report, May 9, 2000
November 1966
DHS Approves UCONN Disposal Site.
CT Department of Health Services (DHS) determines the 102.7 acre property is suitable as a waste disposal area provided it complies with state health codes and other conditions. From 1966 to 1989, the landfill operates under the DHS inspection and/or permit program with sporadic DHS oversight and limited UCONN accountability.
Haley & Aldrich Report, May 9, 2000 and Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
December 1966
Chemical Dumping Begins at UCONN.
UCONN faculty & staff begin dumping chemicals and waste over a 15 acre area on land formerly owned by Costello. Chemical pits were not brought to the attention of DHS and continued in operation until 1978. Four chemical pits were established by the Chemistry Department.  Chemicals disposed included; acids, ethers, peroxides, cesium and other heavy metals, cyanide, arsenic, solvents, chlorinated hydrocarbons, ammonium hydroxide, mercury, toluene, acetone, benzene, herbicides and pesticides (including experimental pesticides).
Haley & Aldrich Report, May 9, 2000
March 12, 1970
UCONN Receives Landfill Permit.
CT Department of Health Services grants UCONN permit to operate a landfill. Landfill regulations of that era were inadequate by modern landfill management standards.  While Congress enacted the Resource Conservation & Recovery Act in 1970 this regulation would not have had any bearing on UCONN’s landfill permit.
Haley & Aldrich Report, May 9, 2000
June 25, 1971
In response to Earth Day 1970, and other environmental concerns, the state legislature creates the Connecticut Department of Environmental Protection. Their mission includes solid waste management.
Department of Energy and Environmental Protection Website accessed July 22, 2017. Public Act No. 872, An Act Creating a Department of Environmental Protection, adopted June 25, 1971
Undated – (probably early 1970s)
DEP Lets UCONN Keep Chemical Pits.
DEP allows UCONN to keep chemical pit on a short term basis.  It is not clear what authority DEP inspector had to make such a determination.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
August 27, 1974
DEP Inspection Determines Hazardous Waste Dumped.
DEP inspects UCONN’s chemical pits and determines pesticides, acids, bases and other chemicals were dumped in.  Inspector notes that a fire truck was routinely used whenever chemical fires broke out in the chemical pits.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
August 23, 1976
DEP Orders UCONN to Close & Cover the Chemical Pits.
The two year delay after the 1974 inspection suggests DEP did not make UCONN’s chemical pits a priority enforcement.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
October 21, 1976
Commonly referred to as RCRA, this law is our nation’s primary law governing the disposal of solid and hazardous wastes.  Congress passed RCRA on October 21, 1976 to address the increasing problems the nation faced from our growing volume of municipal and industrial waste. RCRA, which amended the Solid Waste Disposal Act of 1965, set national goals for: 1) Protecting human health and the environment from the potential hazards of waste disposal;
2) Conserving energy and natural resources; 3) Reducing the amount of waste generated; 4) Ensuring that wastes are managed in an environmentally-sound manner. This law ended the practice of open dumping.
Public Law 94-580, known as RCRA, adopted October 21, 1976.
1979
UCONN Disobeys DEP Orders.
Disregarding DEP order, UCONN continues to dump in chemical pits.
Haley & Aldrich Report, April 2001
December 11, 1980
Responding to numerous environmental disasters like Love Canal, Congress passes the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) which creates joint and several liabilities for owners of contaminated properties.
Public Law 96-510, known as CERCLA, adopted December 11, 1980.
December 18, 1980
UCONN Geologist Reveals History of Chemical Pollution.
Dr. Robert Black, UCONN geology professor, independently releases historical research that identifies the location, depth, use and time frame of chemical pits as well as the chemicals disposed.
Haley & Aldrich Report, May 9, 2000
May 1981
UCONN Professor Declares Private Wells Polluted.
Dr. Black independently releases a report titled, “Environmental Impact of the Chemical Waste Disposal Site of the University of Connecticut” which reveals the sampling and analysis of four private wells and monitoring wells. Copper and chromium were detected above drinking water standards at four private wells.
Haley & Aldrich Report, May 9, 2000
August 19, 1981
DEP says UCONN Dump Should Close.
DEP official says the site is not suitable because leachate dumps into the Cedar Brook which leads to the Willimantic River. “It is putting leachate into a stream that is too small to handle the pollution and it is located too close to a lot of wells.”
Hartford Courant, DEP Says UCONN Dump Should Close, August 19, 1981, p. B6C
January 31, 1982
Waste War Heats up at UCONN.
A hazardous waste incinerator is proposed to eliminate chemical waste.  Courant staff writer stirs town-wide concerns over UCONN’s plan to build a big chemical incinerator with state legislation exempting their actions from Siting Council Review.
Leonard Bernstein, Waste War Heats Up at UCONN, Hartford Courant, January 31, 1982, p. B1.
August 30, 1982
DEP issues a Consent Order to close Chemical Pits.
DEP orders necessary investigative studies to determine the scope of contamination and requires all work to be completed within 15 months. This order came eight years after DEP found reasonable cause to close these pits.
Haley & Aldrich Report, April 2001 and DEP Consent Order, dated August 30, 1982, signed by Stanley Pac. DEP Commissioner.
October 15, 1982
Solid Waste Permit Issued for UCONN Landfill.
DEP issues solid waste permit to UCONN for its landfill closure plan.  UCONN objects to groundwater sampling schedule since it interferes with the planned groundwater monitoring planned by its consultant.
Haley & Aldrich, Comprehensive Hydro-geologic Investigation and Remedial Action Plan, Volume 8, October 2002
December 17, 1982
UCONN Violates DEP Wetlands Regulations.
DEP cites UCONN with wetlands violations and non-compliance with its November 17, 1980 NPDES permit. UCONN was burying sewage sludge in a wetlands contrary to the clearly stated limitations of its NPDES permit.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
January 1983
Student Predicts Dump Releases Vast Quantities of Leachate.
Tim Welling, a student of Dr. Black continues groundwater sampling and releases sampling results and leachate flushing simulations – estimating the landfill generates 24 million liters of leachate annually – a reasonably accurate forecast of what would be documented some 20 years later when UCONN began controlled and measured leachate discharge to their sewage treatment plant.
Haley & Aldrich Report, May 9, 2000
January 13, 1983
UCONN Contracting Procedures Delay Cleanup.
Hartford Courant reports UCONN to search for source of pollution coming from landfill but delays in contracting have held up this project. Over 125 tons of trash are dumped weekly into the landfill. Contaminated water is suspected to have leached from the landfill or sewage treatment plant.
Jeff Weingart, UCONN to Search for Source of Pollution, Hartford Courant, January 13, 1983, p. E1.
May 5, 1983
UCONN Ordered to Test Private Wells.
DEP orders UCONN to re-test private wells forcing it to spend $70,000. These are same two polluted wells that had previously been tested by the town of Mansfield.
UCONNN to Spend $70,000 for Tests of Polluted Wells, Hartford Courant, May 5, 1983
January 13, 1984
Town Health Office Notifies Kardestuncer of Contamination.
Mansfield Health Officer Charles Bradley notifies Mr. Kardestuncer that the samples extracted from his drinking water well on September  8, 1983 and November 30, 1983 confirm benzene is present at 9 micrograms per liter – far above the 1 microgram per liter maximum safe level set by Connecticut drinking water standards.
Charles Bradley letter to Salahattin Kardestuncer, January 13, 1984
February 5, 1984
Mansfield Town Manager Notified of Well Contamination.
Town Health Officer notes that the Kardestuncer residence has benzene at nine (9) times above acceptable level.
Charles Bradley memo to Martin Berliner, February 3, 1984
May 1, 1984
Dept. of Health Services Releases Water Monitoring Results.
Groundwater sampling results for five (5) apartment complexes along Hunting Lodge Road in September 1982 are declared as either “none detected” or “satisfactory.” The Dept. of Health Services acknowledges the contamination of one domestic well on Hunting Lodge Road, indicating that the source of the contamination is still unknown.
James Ericson, Dept. of Health Services, letter to Charles Bradley, Mansfield Sanitarian, May 1, 1984
July 19, 1984
Benzene Discovered in Private Well.
Consulting Environmental Engineers (CEE) studied seepage into private wells.  A total of 5 of the 15 private wells tested on Hunting Lodge Road were contaminated including one with benzene found at 8 times the safe level.
Steven Gield, Firm studying Effects of Seepage into Wells, Hartford Courant, p. E1,
1985
Size of Landfill Plume Grows.
UCONN Graduate student Ruth Izraeli determines that the downgradient plume extends 2,100 feet south of the landfill and is 600 feet wide, the equivalent of about 29 acres of contaminated land. She also found the leachate plume traveled exceedingly fast at 19.3 feet day on the southern edge of the landfill. While her work is rarely mentioned by UCONN’s consultants, this study clearly reveals the degree of down-gradient danger this landfill posed for Mansfield residents during the early years before any sub-surface investigation was conducted.  A simple calculation shows the leachate plume traveling at the above calculated rate would travel 1.3 miles a year!
Haley & Aldrich Report, May 9, 2000 and Ruth Izraeli, Water Quality and Hydrogeological Investigations at the University of Connecticut Waste Disposal Area, 1985
1985
Nearly 300,000 Cubic Yards Dumped in Landfill.
UCONN estimates over 18,000 cubic yards of material was deposited annually during the years 1970 to 1985. There were 19 waste cells, each up to 45 feet wide and 250 feet long or as much as 213,750 square feet (about 5 acres).  This after-the-fact estimate represents 50% less waste than that reported by the Hartford Courant staff writer in 1983.
Haley & Aldrich Report, May 9, 2000
1985
Volatile Organic Compounds are detected near Homes.
Volatile Organic Compounds (VOCs) are found in the vicinity of private homes/apartments on Hunting Lodge Road.
Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
May 1985
DEP Approves the Consultant Closure Report.
The Consulting Environmental Engineers (CEE) report is approved by the DEP Water Compliance Unit. According to the original Consent Order this report was due November 30, 1984.
Environmental Impact Evaluation for UCEPI Research Park Project, p. 3-70.
October 1985
Uncontrolled Chemical Dumping is Confirmed.
An unknown individual was found to have dumped toluene at the landfill.
Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
September 3, 1986
Chemical Pit Closure Plan Approved.
Connecticut DEP approves a plan for closure of the UCONN chemical pits.
Haley & Aldrich Report, April 2001 and DEP letter of approval dated September 3, 1986
November 25, 1986
State Law Requires Polluters to Provide Potable Water.
A State Law passed in 1985 allows DEP to order those responsible for well water contamination to provide bottled water while working toward a final solution.  While an important legislative development, it does not address those residents of Hunting Lodge Road whose water was contaminated before 1985. At the time this Hartford Courant article was written UCONN officials claim that the waterline for Hunting Lodge Road was 75% complete at a cost of $249,000.
Steve Gield & Daniel Jones, Homeowners Often Pay the Price of Pollution, Hartford Courant, November 25, 1986, p. D1
December 1, 1986
EPA Declares Connecticut DEP to be “State Lead” for Landfill.
Perhaps lacking time and resources, the Federal Environmental Protection Agency (EPA) decides that the Connecticut Department of Environmental Protection will be responsible for all decision making with respect to the UCONN landfill remediation.
Environmental Impact Evaluation for UCEPI Research Park Project, p. 3-70.
December 11, 1986
Five Contractors Bid on Cleanup.
Hartford Courant reports five bids are received for the chemical pit remediation.
Steve Gield, Five Bids Received in Pits, Hartford Courant, December 11, 1986
February 18, 1987
Chemical Pits Dump Cleanup Begins.
Contractor prepares to excavate UCONN chemical pits dump site.
Steve  Gield, Contractor Prepares to  Excavate Chemical Dump Site, Hartford Courant, February 18, 1987
February 21, 1987
UCONN asks State Legislature for up to $125,000 to cover cost of extending waterline to serve an additional 40 homes.  Connecticut Attorney General Rules UCONN can provide water to private homes.
Steve Gield, Homeowners Get Water Service from UCONN, Hartford Courant, February 21, 1987, p. B4E
May 21, 1987
UCONN Spends $430,000 for Initial Cleanup.
Clean Harbors is paid $430,000 to dig up hazardous wastes buried for years at UCONN landfill.  The contractor claims hazardous waste is completely removed but future investigations would prove otherwise.
Steve Gield, Contractor Digs Up Hazardous Wastes Buried for Years at UCONN landfill, Hartford Courant, May 21, 1987
July 1, 1987
UCONN Lawyers Strong Arm Mansfield Residents.
Residents are angered by UCONN’s offer to provide potable water on the condition that the university place an option on their homes (i.e., the right of first refusal at the time of sale).
Steve Gield, Residents Angered by Offer, Hartford Courant, July 1, 1987
August 17, 1987
DEP Declares Soil Removal was Adequate.
The DEP Hazardous Waste Management Section formally documents that soil removal was adequate and successfully removed identified contamination. Eight days later DEP declares the cleanup was completed in compliance with the DEP approved plan.  This conclusion would be declared short sighted some ten years later.
Environmental Impact Evaluation for UCEPI Research Park Project, p. 3-70.
September 14, 1987
Eight Houses are Tied into UCONN Waterline.
Eight residences along Hunting Lodge Road are provided with a hook-up to UCONN waterline. Residents served are located 105, 115, 122, 125, 131, 134, 135 and 146 Hunting Lodge Road.
Summary Table of Hunting Lodge Road Residents That Received Tie-in to UCONN Water System, September 14, 1987 – Filed with Eastern Highlands Health District
September 28, 1987
Chemical Pits Cleanup Approved by Connecticut DEP.
DEP issues Letter of Compliance approving Clean Harbor’s closure of the chemical pits & removal of 5,400 cubic yards of contaminated soil.
Haley & Aldrich Report, April 2001
1987
40 Homes Receive Potable Water From UCONN.
UCONN installs a public water supply to 40 homes on Hunting Lodge Road.
Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
February 28, 1990
DEP Adopts Enhanced Solid Waste Disposal Regulations.
The Connecticut Department of Environmental Protection adopts “state of the art” landfill closure regulations designed to ensure leachate is collected. Liners are required to cap existing solid waste landfills.
TITLE 22A, Environmental Protection, Department of Environmental Protection, Solid Waste Management, Adopted February 28, 1990, Sec. 22a-209-14. Disposal of residue.
1990
UCONN Improperly Dumps Bulky wastes.
Bulky wastes were discovered by DEP in violation of previous orders.
Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
June 26, 1991
DEP Inspects Landfill & Finds Improper Disposal Practices.
DEP is notified of illegal PCB drum disposal.  On-site DEP inspection the next day suggests only grease was disposed which was also an illegal action.  No sampling was undertaken to confirm the constituents that were disposed.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
1996
UCONN Consultant Declares Previous Cleanup Unacceptable.
An Earth Tech Report prepared ten years after the 1987 landfill closure concludes that Clean Harbor’s closure was not adequate. It lacked the required fill cover and missed hazardous waste deposits due to sloppy remediation practices.
Haley & Aldrich Report, May 9, 2000
June 3, 1998
Environmental Organizations Demand EPA Intervention.
Mansfield Common Sense, a local environmental group, teams up with PEER and Toxics Action Center to request EPA intervention and enforcement action against UCONN for its chemical pits.
Letter from Ayla Kardestuncer, et. al. June 3, 1998
June 9, 1998
DEP and UCONN Attempt to Pre-empt Citizen Initiative.
Art Rocque, DEP Commissioner and Phil Austin, UCONN President request EPA to independently evaluate chemical pit cleanup actions.  This effort, six days after PEER’s letter to DeVillars was clearly an effort to pre-empt citizens’ seeking intervenor status in the failed remediation.
Rocque/Austin letter to John DeVillars, EPA Administrator, Region 1, June 9, 1998
June 13, 1998
News media Paints DEP & EPA as Soft on Compliance Issues.
Hartford Advocate reports on UCONN’s failure to comply with federal and state environmental laws and suggests DEP Commissioner and EPA Region 1 Administrator were to blame for not inspecting and enforcing these laws
Jayne Keedle, When it Acid Rains, It Pours, Hartford Advocate, June 13, 1998, p. 13
June 26, 1998
DEP Issues Landfill Consent Order to UCONN
This turn of events would not have happened without Mansfield residents taking a leadership role to “jump start” the proper closure process for this simmering toxic brew of chemicals.
Art Rocque Letter to Mayor Michael Schor, June 26, 1998
June 1998
DEP Blamed for Chemical Pit Mess.
PEER faults Connecticut DEP Commissioner for stalling on chemical pit remediation
PEER Newsletter, Summer 1998 Issue
June 1998
Health District Begins Water Sampling.
Eastern Highlands Health District begins sampling tap water at up to 90 homes in four sampling events revealing 12 properties or homes have polluted drinking water.
Haley & Aldrich, Comprehensive Hydro-Geologic Investigation and Remedial Acton Plan, Addendum No. 2, July 2004
July 1998
Landfill Closure Specifications Updated.
Earth Tech provides UCONN with updates on the Solid Waste Closure Technical Specifications.
Earth Tech Report, July 1998
July 14, 1998
Concerned Citizen Claims UCONN is a Bad Actor.
Pharmacist Greg Cichowski contends UCONN has failed to implement a DEP consent order that was issued 13 years ago. He urges intervenor status rather than cooperation with UCONN.
Brenda Sullivan, Landfill Procedures Opposed, Hartford Courant, July 14, 1998
July 27, 1998
Mansfield Officials OK EPA Public Involvement Process.
Mansfield Town Council unanimously votes to support an EPA public participation process as part of the landfill closure plan.
Martin Berliner, Town Mgr., letter to Thomas Callahan, Govt. & Community Relations, UCONN dated July 29, 1998
July 29, 1998
Health District Expert Declares Many Wells Contaminated.
Eastern Highlands Health District presents results of water testing to residents indicating that 12 of 82 private wells are contaminated.
Eastern Highlands Health District, Remarks of Kenneth Dardick, MD, Medical Advisor, July 29, 1998
August 11, 1998
Local Pharmacist Calls for Citizens to Speak Up.
Pharmacist Greg Cichowski issues a letter to neighbors requesting them to send letters to DEP to ensure that all citizen concerns are part of the record and so that a citizen participation process can be established. He provides 48 questions that need resolution.
Greg Cichowski letter dated August 11, 1998 to Mansfield Neighbors
August 12, 1998
EPA Official Encourages Mansfield to accept EPA Role
EPA invites Mansfield’s Town Manager to host a public outreach meeting on the UCONN landfill.
Linda Murphy, EPA Office of Ecosystem Protection, letter to Martin H. Berliner, August 12, 1998
August 27, 1998
EPA Administrator Plays Down EPA’s Authority.
John DeVillars, EPA Region 1 Administrator contends that EPA can only play a limited role in the chemical pits remediation – deferring to Connecticut DEP.  However, DeVillars does commit to a public outreach and participation effort as a means to cool citizen outrage with UCONN’s desultory administration of the closure plan.
DeVillars letter to Mayor Michael Schor, August 27, 1998
August 31, 1998
Tired of Half Truths, Citizens Issue Their Own Landfill Facts.
Citizens’ UCONN Landfill Fact sheet is issued to reflect town residents’ viewpoint on neglected facts including their assertion that the landfill was a hazardous waste site – not a solid waste facility. They also assert that UCONN does not know the full extent of the problem nor does it want to know. Fact sheet issued concurrent with DEP town meeting on landfill held in Mansfield Town Hall.
Citizens’ UCONN Landfill Fact Sheet, dated August 31, 1998
September 14, 1998
Landfill Regrading Plan Approved by DEP.
Michael Harder, Director of Permitting and Enforcement approves the UCONN landfill regrading plan
Harder letter to Mark A Emmert, Chancellor & Provost of University Affairs, September 14, 1998
Fall of 1998
UCONN Hires Regina Villa Associates for Public Relations.
Facing serious public concerns about the landfill and chemical pits, UCONN retains the services of Regina Villa Associates to manage public relations. UCONN maintains their services until December of 2006.
Email correspondence from Nancy Farrell, Chief Executive Officer, Regina Villa Associates, July 24, 2017
October 2, 1998
Chronicle Editorial Board Urges UCONN to Comply.
Willimantic Chronicle editorial board supports need for landfill compliance despite State Rep. Denise Merrill claiming she was unconvinced about the landfill being a problem and her asking why UCONN has been singled out.
Dump Compliance is the Issue here, Willimantic Chronicle, October 2, 1998, p. 6
October 17, 1998
UCONN Officials Surprised Radioactive Waste was Buried.
Hartford Courant reports that radioactive waste was once kept at the UCONN landfill.  UCONN officials are surprised that a radio-active waste storage site once existed at the landfill. Richard Sherman of Mansfield Common Sense, stated, “The fact that UCONN doesn’t understand its own radioactive waste disposal history is consistent with what they didn’t know about the chemical-waste disposal history, and that is not reassuring.”
Daniel P. Jones, Radioactive Waste Once Kept at Landfill, Hartford Courant, October 17, 1998, Section B, p.1
October 17, 1998
UCONN is fined $36,000 for Landfill Violations.
UCONN fails to meet DEP consent order deadlines. Art Rocque, taking the heat from Mansfield citizens realizes he needs to get tough on UCONN.
Barbara Jordan, DEP Fines UCONN $36,000, Hartford Courant, October 17, 1998, p.1
October 21, 1998
Residents Remain Deeply Distrustful of UCONN.
Willimantic Chronicle reports that despite talks, Mansfield residents are still mistrustful of UCONN’s management of the landfill/chemical pits closure. A total of 50 residents attended, including 25 members of Mansfield Common Sense.  Citizens expressed the need for more reliable information about past dumping practices and a greater role for citizen input.
Barbara Jordan, Despite Talks, residents still mistrustful over landfill, Willimantic Chronicle, p. 3
October 31, 1998
Connecticut Green Party Condemns DEP & EPA.
Amy Vas Nunes, Co-Chair of the Connecticut Green Party writes an editorial to the Willimantic Chronicle calling the UCONN landfill a superfund site and urging UCONN to provide public water to all those living in the area.  She pans the public involvement process as a “public relations snow job.”
Amy Vas Nunes, Co-Chair of the Connecticut Green Party, UCONN Landfill is Superfund Site, Willimantic Chronicle, October 31, 1998, p. 6
October 1998
UCONN Releases Preliminary Groundwater Results
UCONN releases results of Geo-probe Groundwater Investigation at the Landfill which provides limited evidence of contamination - revealing a limited investigation due to an inappropriately narrow scope of work. This technique is normally used for a preliminary assessment. Future geo-technical investigations would expand upon this preliminary work.
Haley & Aldrich Report, October 1998
November 20, 1998
Chronicle Editorial Board Urges UCONN to Install Waterline.
Editorial Board of the Willimantic Chronicle calls on UCONN to extend the water line to protect public health for those living downgradient of the landfill.  The Board suggests Mansfield pay for the extension and then work out reparations with UCONN later on.
Willimantic Chronicle, It’s Time to extend UCONN’s water line, November 20, 1998, p. 6
November 27, 1998
DEP Calls for Private Well Testing at 50 Homes.
Hartford Courant reports that DEP will test the water at 50 residences that may have been affected by the UCONN Landfill and chemical pits. This is a follow-up testing regime to that undertaken by the Eastern Highlands Health District at over 100 residences.
Brenda Sullivan, Water Wells to be Tested, Hartford Courant, November 27, 1998, p. B6
December 22, 1998
Mayor of Mansfield Urges UCONN to Provide Water.
Michael Schor, Mayor of Mansfield, urges UCONN to provide potable water to affected residents – or at least begin the planning and analysis to make this possible
Michael Schor, Mayor, letter to Michael Emmert, UCONN Chancellor and Provost, dated December 22, 1998
January 30, 1999
Citizens Call for UCONN to Do More Study.
UCONN invites public comments on the draft scope of study for the hydro-geological investigation of the landfill and chemical pits. Over 30 comments or submissions were received from citizens seriously concerned about UCONN’s commitment to remediation.
Response to Comments Document, January 30, 1999
June 18, 1999
UCONN Required to Expand its Investigation.
DEP issues revised scope of study for hydro-geological investigation to address six new issues – many of which reflect the concerns of Mansfield residents expressed at the January 30, 1999 public hearing.
Michael Harder, DEP Director of Permitting and Enforcement, letter to Mark Emmert, UCONN Chancellor
May 9, 2000
Study Reveals Contamination Follows Bedrock Fractures.
UCONN submits final preliminary Hydro-geological Investigation Report to DEP indicating the landfill leachate affects groundwater, surface water and sediment.  Study team does not believe any threats exist to health of abutters that require immediate action. Haley & Aldrich also point to chemicals that have penetrated fractured bedrock and have migrated along fracture lines which will require more study.
Haley & Aldrich Report, May 9, 2000
June 9, 2000
Federal Health Agency Declares No Public Health Concern.
Agency for Toxic Substances and Disease Registry (ATSDR) releases Health Consultation report for UCONN landfill/chemical pits. ATSDR identifies low level contamination in 24 of the private wells sampled. ATSDR states none of them pose a public “health concern” from a long or short term exposure.  Undoubtedly, citizen lack of confidence in UCONN’s and DEP’s past performance with the landfill/chemical pits led to the request for ATSDR intervention.
ATSDR, Health Consultation Report, June 9, 2000
November 26, 1999
Connecticut Dept. of Health Releases Health Consultation.
The Connecticut DPH releases its “Health Consultation” report concluding that While low levels of some volatile organic compounds were identified in 21 of the private wells sampled, none of the compounds were identified at levels that would present any public health concern from either long or short term exposure. However high levels of lead and sodium were found in two wells that require further sampling. The findings of this Health Consultation were presented to the public during a public meeting on June 8, 1999.
“Health Consultation” prepared by Connecticut Department of Public Health Under Cooperative Agreement with the Agency for Toxic Substances and Disease Registry, November 26, 1999.
August 16, 2000
Sloppy Cleanup Calls for More Trench Work.
UCONN begins trenching program based on identification of additional missed contamination by Clean Harbors in 1987.
Haley & Aldrich Report, April 2001
September 13, 2000
Trench Work Continues as Contamination Expands.
UCONN begins second round of trenching after finding even more contamination.
Haley & Aldrich Report, April 2001
December 5, 2000
UCONN Agrees to More Water Sampling.
UCONN agrees to sample any domestic wells at homeowner’s request. Sixteen homeowners accept UCONN’s offer. Tests extend to 21 additional wells. Three wells tested above acceptable drinking water criteria.
Haley & Aldrich, Comprehensive Hydro-geologic investigation and Remedial Action Plan, Addendum No. 2, July 2004
February 22, 2001
Five Wells Serving Six Residences to be Given Potable Water.
Art Rocque, DEP Commissioner, Orders UCONN to provide potable water to six properties on North Eagleville Road found to have polluted wells.
Letter to John D. Peterson, Chancellor, UCONN, from Art Rocque, DEP Commissioner, February 22, 2001
April 2001
UCONN releases results of Trench Testing Program.
UCONN releases results of Test Trenching Program at former chemical pits.
Haley & Aldrich Report, April 2001
July 10, 2001
Six Residences Hooked up to UCONN Water.
DEP approves water main extension to six residences on North Eagleville Road.
EP Consent Order SRD-101, July 10, 2001
October 2001
Dozens of Chemicals Found above Regulatory Standards.
UCONN releases conceptual model for shallow groundwater, surface water, and soil gas sampling as part of the landfill closure assessment. Report indicates 46 chemicals found above Remediation Standard Regulations (RSR). Report declares that the principal groundwater migration pathway from former chemical pits is through fractured bedrock. Dense Non-Aqueous Phase Liquids (DNAPL) are the principal contaminants of concern. DNAPLs are “sinkers” and were found in high concentrations in the deep bedrock wells.
Haley & Aldrich Report, October 2001
December 26, 2001
UCONN releases Poorly Prepared Health Risk Assessment.
EPONA Associates retained to conduct risk assessment. Their calculations are poorly documented and without scholarly integrity.  They conclude that soil contact does not pose an excess lifetime cancer risk.
Haley & Aldrich, Comprehensive Hydro-geologic
Investigation and Remedial Action Plan, Volume 8, October 2002
January 2002
Separatist Road Residence Hooked Up to Waterline.
One resident on Separatist Rd is connected to UCONN water system.
Interview with Alison Hilding, July 23, 2017
January 31, 2002
EPA Contractor Declares Citizen’s Don’t Trust UCONN.
EPA’s Public Involvement Process Coordinator declares that UCONN’s credibility with the community has not improved over the last 3 years despite public involvement process.  The public continues to lack confidence in UCONN’s ability to remediate without regulatory oversight.
Marion Cox, Resource Associates, Memo to DEP and EPA, January 31, 2002
September 20, 2002
UCONN Establishes an Office of Environmental Policy.
Attorney Richard Miller is selected for this post after a distinguished career with Northeast Utilities and the CT Business & Industry Association.
Karen Grava, Environmental Director Appointed, UCONN Advance, September 23, 2002
Fall 2002
Land Use Restrictions Recommended for Chemical Pits.
UCONN’s consultants recommend restrictions on the use of land where the former chemical pits were located. However, this important recommendation is not listed as one of the required elements of the landfill closure plan (see UCONN Update dated April 2004).
UCONN Update, Landfill Remediation Project, Fall 2002, p. 2.
January 2003
UCONN Study Recommends Purchase of Downgradient Land.
In an effort to protect public health, UCONN’s draft final Hydrogeological Investigation of the landfill and chemical pits recommends attempting to purchase downgradient property to prohibit future development. There is no evidence that this recommendation was ever implemented.
June 5, 2003
Remedial Action Plan Approved by DEP.
DEP approves UCONN’s comprehensive hydro-geological Investigation Report & Remedial Action Plan.
Minutes of the Mansfield Town Council, December 8, 2003, p. 20
November 26, 2003
Seven Residents Accept UCONN Water.
Seven residents accept public water and agree to abandon their wells on North Eagleville & Meadowood Roads.
Minutes of the Mansfield Town Council, December 8, 2003, p. 22
Fall 2003
In response to public comments, UCONN makes documents available in a digital format at the website titled;
www.landfillproject.uconn.edu
UCONN Update, Landfill Remediation Project, Fall 2003, p. 6.
January 26, 2004
UCONN Submits Revised Closure Plan.
In December 2003, DEP issued a letter commenting on the Closure Plan and requesting a revised Closure Plan, which UConn prepared and submitted in January 2004. The revised closure plan affirms that post-closure monitoring will continue for at least 30 years. Quarterly sampling is required under the Remediation Standard Regulations (RSRs); however, UConn can petition the DEP to reduce sampling frequency after post-closure conditions are well-established.
UCONN Update, Landfill Remediation Project, April 2004, p. 1.
May 2004
Six more Residences are Connected to UCONN Water System.
At DEP’s direction, UCONN is ordered to provide potable water to six residences as part of the final landfill closure approval.
UCONN Update, Landfill Remediation Project, April 2004, p. 4.
June 30, 2004
UCONN Submits Wetland Plan to Army Corps of Engineers.
UCONN submits wetland mitigation and remedial action implementation plan for UCONN landfill & former chemical pits.
Haley & Aldrich, Wetland Mitigation Plan submitted to Cori, Rose, at U.S. Army Corps of Engineers, June 30, 2004
November 22, 2004
DEP Approves Landfill Closure Plan.
Connecticut DEP approves UCONN’s landfill closure plan based on documents prepared by Haley & Aldrich.
Haley & Aldrich, Project Manual, Volume 3, Summary of Permits Related Documents Remedial Action Plan Implementation, July 2005
January 2005
Wetlands Hearing Held on Landfill’s Impact on Wetlands.
DEP permit hearing is held on the wetlands filling and mitigation plan.
UCONN Update Landfill Remediation Project, December 2005, p.2  found in the Mansfield Town Council Minutes of  January 9, 2006, p. 11
May 25, 2005
Wetlands Permit Issued to UCONN.
U.S. Army Corps of Engineers permit is issued for wetlands work near the UCONN landfill.
Haley & Aldrich, Project Manual, Volume 3, Summary of Permits Related Documents Remedial Action Plan Implementation, July 2005
August 2005
Landfill Specifications Finalized.
Haley & Aldrich completes specifications for Remedial Action Plan.
Haley & Aldrich, Project Manual, Volume 1 of 4 – Specifications Remedial Action Plan Implementation, August 2005
December 2005
Long Term Monitoring to Last 30 Years.
UCONN states in the January 9, 2006 issue of the UCONN Update Landfill Remediation Project Newsletter that the long term monitoring plan (LTMP) is to last for 30 years.
UCONN Update Landfill Remediation Project, December 2005, p.5  found in the Mansfield Town Council Minutes of  January 9, 2006, p. 14
January 30, 2006
Land Use Restrictions Placed on UCONN’s F Lot.
Haley & Aldrich submit construction completion report for the F Lot disposal area indicating closure occurred in November 1999 and complies with applicable regulations. Report indicates permanent land use restrictions placed on F lot precluding its use for residential use and for drinking water.  The F lot is a separate closure project from that of the landfill and the chemical pit closures.
Haley & Aldrich, Construction Completion Report F Lot Disposal Area, January 2006
November 29, 2006
Groundwater Sampling Continues to Find Volatile Organics.
Haley & Aldrich, UCONN’s contractor, submit the long term monitoring plan Sampling Round #1. The report indicates Volatile Organic Compounds (VOC) detected in deep bedrock monitoring wells above groundwater protection criteria. A total of only 18 more Sampling Rounds are released by UCONN over the next seven years even though it declared that groundwater sampling would last 30 years (see December 2005).
Haley & Aldrich, Long Term Monitoring Plan Sampling Round #1, November, 2006
June 2007
Landfill Leachate Treated at Waste Water Plant.
Temporary pumping of leachate from landfill is sent to UCONN’s wastewater treatment plant (WWTP). Enormous quantities of leachate require treatment at the WWTP.  The volumes of treated leachate at the WWTP are consistent with the estimates made by Welling in the early 1980s.
CT ACHMM Newsletter, August 2007, p.  7.
March 5, 2009
Community Water Wells Proposed Downgradient of Landfill.
Keystone Companies LLC, an Avon company managed by Anthony P. Giorgio, requests the Dept. of Public Utility Control for permission to install a community water system immediately downgradient of UCONN landfill on Hunting Lodge Road.
Kemberley Santopietro, Dept. of Public Utility Control, letter to Anthony Giorgio acknowledging receipt of application for certificate of pubic convenience and necessity for a community water system, March 5, 2009
December 11, 2009
Mason Associates submits Wetland Mitigation Monitoring Report #2 that confirms 1.83 acres of wetlands was created to replace the amount lost; an additional 2.97 acres of wetlands was restored and 12.4 acres of wetlands was enhanced as required by Army Corps permit requirements.
Mason Associates Wetland Mitigation Monitoring Report #2, 2009
December 15, 2009
Based on a Connecticut DEP approval letter dated December 15, 2009 and prompted by UCONN’s request to halt progress reports, no further public reporting is provided.
Patrick Bowe, Director of DEP Remediation Division to Richard Miller, Director, Office of Environmental Policy, dated December 15, 2009
April 27, 2011
Keystone Co. LLC Submits Request for Community Water.

Mark Lewis, CT DEP letter to Lori Mathieu,  June 21, 2011
June 21, 2011
CT Dept. of Public Health Denies Community Water System.
Lori Mathieu, Public Health Section Chief, CT Department of Public Health, denies Mr. Giorgio’s application for the Revised Phase 1-A application that had been received April 27, 2011. On this same date, the CT DEP raises serious concerns with the impact of the revised community well locations (i.e., they are closer to the landfill than the first application) on domestic wells in the area. The developer’s wells are expected to accelerate the downgradient movement of landfill leachate.
Lori Mathieu, Public Health Section Chief, CT Dept. of Public Health, to Kimberley Santopietro, Dept. of Public Utility Control, June 21, 2011 and Mark Lewis, CT DEP letter to Lori Mathieu,  June 21, 2011
September 21, 2011
Keystone Withdraws its Community Well Application.
Community concerns with water contamination derail this proposal. The proposal was officially withdrawn on September 30, 2011. However, on this same date Keystone submits a revised application also confusingly titled Phase 1-A (Keystone should have given it another name to make it easier for historians to follow this confusing process).
John Betkoski, Hearing Officer receives Motion to Withdraw Application, September 27, 2011
October 28, 2011
Senator Don Williams Objects to Keystone LLC Application.
Senator Donald Williams objects to the Keystone Companies LLC revised application submitted September 21, 2011 and implores Commissioner Mullen to preserve the integrity of the landfill cap “while ensuring an adequate water supply free from contamination for local residents.”
Donald Williams, Senator, 20th Senatorial District, to Commissioner Jewel Mullen, CT Public Health,  October 28, 2011
November 14, 2011
Eastern Highlands Health District Fights Keystone LLC Wells.
Robert Miller, Director of Health of EHHD opposes the Keystone Companies LLC Ponde Place application to install a community water system wells immediately downgradient of the UCONN landfill and chemical pits on a 45 acre parcel located on Hunting Lodge Road.  Miller notes the significant drop in water levels at landfill monitoring wells and private owned domestic water wells near the proposed development during Keystone’s test pumping. He notes that the developer’s proposal will accelerate the movement of contaminants toward wells downgradient of the landfill.
Robert Miller, EHHD Director, letter to Eric McPhee, CT Dept. of Public Health, date November 14, 2011
November 21, 2011
CT Dept. of Public Health Rejects Keystone’s LLC Application.
The Keystone LCC Ponde Place application is rejected for many reasons including its potential impact on drawing the landfill plume southwestward toward Hunting Lodge Road and many nearby residential wells. While this rejection stopped Keystone’s development proposal, later developments, including UCONN’s contractual authority to extend sewer and water service to residential areas of Mansfield, suggests Keystone’s Ponde Place development proposal will soon be re-activated.
Lori Mathieu, Public Health Section Chief, CT Dept. of Public Health, to Kimberley Santopietro, Dept. of Public Utility Control, November 21, 2011
April 24, 2012
Volatile Organics Remain in Bedrock Wells after 16 Rounds.
Long Term Monitoring Plan Round #16 groundwater sampling continues to reveal volatile organic compounds in the deep bedrock monitoring wells.
Haley & Aldrich, Long Term Monitoring Plan Round #16, April 2012
May 1, 2012
Health District Director Not Concerned about VOC results.
Robert Miller, Eastern Highlands Health District, reviews the results from Landfill Monitoring wells Sampling Round #16 and notifies Town Manager Hart that, in his opinion, the results do not indicate immediate or imminent threat to health.
Robert Miller memo to Matthew Hart, May 1, 2012
November 26, 2013
Bedrock Contamination Remains after 19 Sampling Rounds.
Long Term Monitoring Plan Round #19 continues to reveal volatile organic compounds in the deep bedrock monitoring wells with fracture lines pointing toward a southerly plume direction.
Haley & Aldrich, Long Term Monitoring Plan Round#19, November 2013
July 6, 2017
Total Cleanup Estimated at $35 Million.
Pharmacist Greg Cichowski indicates that UCONN is alleged to have spent over $35 Million to remediate the chemical pits and landfill.
Interview with Cichowski, July 6, 2017

Research Methods:
Details on the sources and methods used in this research can be found by clicking on Notes on the Research Supporting this Blog.

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