SL^i

December 22 1992

5DMS DOCID 450010 Westvaco

Certified Mail - Return Receipt Requested

Ms Marilyn K Goldberg U S Environmental Protection Agency P 0 Box 221A70 Chantilly VA 22022

Re Solvents Recovery Service of New England (SRSNE) Superfund Site in Southington CT

Dear Ms Goldberg

This is in response to the December 7 1992 CERCLA Section 104(e) request that Westvaco received on December 10 1992 That request seeks information and documents relating to the site for the time period 1955 shy1980 Our records retention policy dictated that most of those records that would be responsive to your request have been destroyed However a few records in the 1979 - 1980 time frame have been discovered and they have been enclosed along with this response

The documents that we have located are summarized below showing the EPA date the Westvaco date the EPA volume the Westvaco volume and the discrepancy between the two

EPA Date W Date EPA Volume W Volume A

04-25-79 04-25-79 3080 2530 -550 10-09-79 10-09-79 1650 1650 0 12-07-79 12-06-79 1375 1375 0 01-31-80 01-31-80 2365 1595 770

04-11-80 1760 +1760 08-11-80 08-13-80 2090 2090 0

+1210

Total Westvaco volume should now be 175397 gallons after adding these 1210 gallons to the earlier total of 174187 gallons (See the Transactional Review Form letter dated November 13 1992)

All of the data displayed above were obtained from our Flexible Packaging plant in Springfield MA This corresponds to the EPA Form 1 Page 1 allocation for Westvaco US Envelope Division (Springfield MA) It is to be noted that Westvaco has two plants in Springfield a Flexible Packaging Plant and an Envelope plant Given that we have records that indicate the shipments came from Flexible Packaging we can distinguish between the two plants However this not the general case so we can not identify with exactitude the source of the waste shipments from Springfield Therefore in Form 1 for Springfield the waste type is ^bullraquoraquo-

Westvaco Building 299 Park Avenue New York NY 10171 Telephone 212 688 5000

described as if it came from either Flexible Packaging opound Envelope but not both

Errors in the Form 1

The first two dates listed on the Form 1 for Westvaco US Envelope Division (Springfield MA) do not have the correct year It appears that through some default mechanism of your computer unknown years become 00 Westvaco believes that the identity of those years are as follows The transaction date EPA lists as 02-11-00 should be 03-11-81 This date corresponds to a shipment of 2310 gallons of waste to SRSNE from Springfield It should not be listed as a pre-1980 shipment Please refer to EPA documents 0401761 0401762 and 4000073 for clarification Similarly the transaction date that EPA lists as 03-18-00 can be explained The date should be corrected to 03-18-81 wherein 330 gallons of waste were shipped to SRSNE from Springfield It also should not be listed as a pre-1980 shipment Please refer to EPA documents 0401763 0401764 and 4000074 for clarification

Another error occurs on the Form 1 for Westvaco US Envelope Division (Enfield CT) The only listing is for the transaction date of 10-20-80 wherein 1815 gallons of waste is attributed to Enfield However the same 1815 gallons is also attributed twice to Springfield for the same date on the Form 1 for Westvaco US Envelope Division (Springfield MA) This is a triple count To correct the situation the Enfield shipment should be deleted along with one of lines for the Springfield shipments Please refer to EPA documents 0036970 and 0401788 and it will become clear to you

Another error appears on the Form 1 for US Envelope (Enfield CT) transaction date 04-18-66 The gallon volume is mistakenly listed as 5000 when it should be 500 Please refer to EPA document 0037300 for clarification

All of these errors were pointed out with specificity in the Transactional Review Form letter that Westvaco sent to you on November 13 1992 It is enclosed for your convenience It is Westvacos understanding that the allocation stands as pointed out in Transactional Review Form letter namely that the waste gallonage attributed to Westvaco is 174187 plus the additional 1210 discovered above for a total of 175397 Your confirmation in this matter would be appreciated

In the future could you please address all correspondence to RH Dickinson Westvaco Corporation Project Director Corporate Environmental Safety and Health 299 Park Avenue New York NY 10171 Doing so will eliminate much delay in future matters

-2shy

I trust that this response is sufficient to discharge Westvacos immediate responsibilities in this matter

Very truly yours

J bull - f 1 shy

Frank Murphy Attorney

FJMkah Goldberg

ENCLOSURE B

Solvents Recovery Service of New England 104(e) Information Request Form for Generators

1 Name of Respondent Westvaco Corporation

2 Date Information Request Completed December 21 1992

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 mdash 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 identify and provide complete information on any additional transactions which do not appear on Form 1 or transactions which are in some manner incorrectly 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 Foirm 1 (ie 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 (eg current employee - environmental manager past employee - maintenance department etc) Attach extra pages if necessary

(continued)

Name James Cimaglio

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9797

Relation to Respondent Environmental Manager

Name Ronald Frederick

Address 311 Industry Avenue

Springfield MA

Phone No (413) 787-9793

Relation to Respondent Buyer at Flexible Packaging Plant Springfield MA

Name Richard Laffargue

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9755

Relation to Respondent Former Production Superintendent at Enfield Envelope Plant

Name Edward Neiman

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 736-7211

Relation to Respondent Former Production Superintendent at Springfield Envelope

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

described as if it came from either Flexible Packaging opound Envelope but not both

Errors in the Form 1

The first two dates listed on the Form 1 for Westvaco US Envelope Division (Springfield MA) do not have the correct year It appears that through some default mechanism of your computer unknown years become 00 Westvaco believes that the identity of those years are as follows The transaction date EPA lists as 02-11-00 should be 03-11-81 This date corresponds to a shipment of 2310 gallons of waste to SRSNE from Springfield It should not be listed as a pre-1980 shipment Please refer to EPA documents 0401761 0401762 and 4000073 for clarification Similarly the transaction date that EPA lists as 03-18-00 can be explained The date should be corrected to 03-18-81 wherein 330 gallons of waste were shipped to SRSNE from Springfield It also should not be listed as a pre-1980 shipment Please refer to EPA documents 0401763 0401764 and 4000074 for clarification

Another error occurs on the Form 1 for Westvaco US Envelope Division (Enfield CT) The only listing is for the transaction date of 10-20-80 wherein 1815 gallons of waste is attributed to Enfield However the same 1815 gallons is also attributed twice to Springfield for the same date on the Form 1 for Westvaco US Envelope Division (Springfield MA) This is a triple count To correct the situation the Enfield shipment should be deleted along with one of lines for the Springfield shipments Please refer to EPA documents 0036970 and 0401788 and it will become clear to you

Another error appears on the Form 1 for US Envelope (Enfield CT) transaction date 04-18-66 The gallon volume is mistakenly listed as 5000 when it should be 500 Please refer to EPA document 0037300 for clarification

All of these errors were pointed out with specificity in the Transactional Review Form letter that Westvaco sent to you on November 13 1992 It is enclosed for your convenience It is Westvacos understanding that the allocation stands as pointed out in Transactional Review Form letter namely that the waste gallonage attributed to Westvaco is 174187 plus the additional 1210 discovered above for a total of 175397 Your confirmation in this matter would be appreciated

In the future could you please address all correspondence to RH Dickinson Westvaco Corporation Project Director Corporate Environmental Safety and Health 299 Park Avenue New York NY 10171 Doing so will eliminate much delay in future matters

-2shy

I trust that this response is sufficient to discharge Westvacos immediate responsibilities in this matter

Very truly yours

J bull - f 1 shy

Frank Murphy Attorney

FJMkah Goldberg

ENCLOSURE B

Solvents Recovery Service of New England 104(e) Information Request Form for Generators

1 Name of Respondent Westvaco Corporation

2 Date Information Request Completed December 21 1992

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 mdash 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 identify and provide complete information on any additional transactions which do not appear on Form 1 or transactions which are in some manner incorrectly 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 Foirm 1 (ie 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 (eg current employee - environmental manager past employee - maintenance department etc) Attach extra pages if necessary

(continued)

Name James Cimaglio

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9797

Relation to Respondent Environmental Manager

Name Ronald Frederick

Address 311 Industry Avenue

Springfield MA

Phone No (413) 787-9793

Relation to Respondent Buyer at Flexible Packaging Plant Springfield MA

Name Richard Laffargue

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9755

Relation to Respondent Former Production Superintendent at Enfield Envelope Plant

Name Edward Neiman

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 736-7211

Relation to Respondent Former Production Superintendent at Springfield Envelope

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

I trust that this response is sufficient to discharge Westvacos immediate responsibilities in this matter

Very truly yours

J bull - f 1 shy

Frank Murphy Attorney

FJMkah Goldberg

ENCLOSURE B

Solvents Recovery Service of New England 104(e) Information Request Form for Generators

1 Name of Respondent Westvaco Corporation

2 Date Information Request Completed December 21 1992

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 mdash 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 identify and provide complete information on any additional transactions which do not appear on Form 1 or transactions which are in some manner incorrectly 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 Foirm 1 (ie 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 (eg current employee - environmental manager past employee - maintenance department etc) Attach extra pages if necessary

(continued)

Name James Cimaglio

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9797

Relation to Respondent Environmental Manager

Name Ronald Frederick

Address 311 Industry Avenue

Springfield MA

Phone No (413) 787-9793

Relation to Respondent Buyer at Flexible Packaging Plant Springfield MA

Name Richard Laffargue

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9755

Relation to Respondent Former Production Superintendent at Enfield Envelope Plant

Name Edward Neiman

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 736-7211

Relation to Respondent Former Production Superintendent at Springfield Envelope

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

ENCLOSURE B

Solvents Recovery Service of New England 104(e) Information Request Form for Generators

1 Name of Respondent Westvaco Corporation

2 Date Information Request Completed December 21 1992

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 mdash 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 identify and provide complete information on any additional transactions which do not appear on Form 1 or transactions which are in some manner incorrectly 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 Foirm 1 (ie 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 (eg current employee - environmental manager past employee - maintenance department etc) Attach extra pages if necessary

(continued)

Name James Cimaglio

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9797

Relation to Respondent Environmental Manager

Name Ronald Frederick

Address 311 Industry Avenue

Springfield MA

Phone No (413) 787-9793

Relation to Respondent Buyer at Flexible Packaging Plant Springfield MA

Name Richard Laffargue

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9755

Relation to Respondent Former Production Superintendent at Enfield Envelope Plant

Name Edward Neiman

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 736-7211

Relation to Respondent Former Production Superintendent at Springfield Envelope

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

(continued)

Name James Cimaglio

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9797

Relation to Respondent Environmental Manager

Name Ronald Frederick

Address 311 Industry Avenue

Springfield MA

Phone No (413) 787-9793

Relation to Respondent Buyer at Flexible Packaging Plant Springfield MA

Name Richard Laffargue

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 787-9755

Relation to Respondent Former Production Superintendent at Enfield Envelope Plant

Name Edward Neiman

Address 2001 Roosevelt Avenue

Springfield MA

Phone No (413) 736-7211

Relation to Respondent Former Production Superintendent at Springfield Envelope

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

FORM 1 Page l

Solvents Recovery Service of New England Weatvaco US Envelope Div (Springfield NA)

Transaotion Oallon Waste Type (3) NameAddress MaaeDeacrlptlon of Who Dnte (1) Voluae (2) of Transporter Selected the B l f (4)

021100 231000 SKSNE Westvaco

031800 33000 SRSNE Westvaco

120878 258500 SRSNE Westvaco

020779 231000 SRSNE Westvaco

042579 308000 SRSNE Westvaco

100979 165000 SRSNE Westvaco

120779 137500 SRSNE Westvaco

013180 236500 SRSNE Westvaco

061280 198000 SRSNE Westvaco

081180 209000 SRSNE Westvaco

SEE ATTACHED AND EXPLANATION ENCLOSED IN COVER LETTER Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG W^ |p Disposal Service - broker l i )

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

FORM 1 - ADDITIONAL TRANSACTIONS Page

Solvents Recovery Service of Hew England Westvaco US Envelope Div (Springfield MA)

r r a n s a c t i o n)a te (1)

Gal lon Volumdash

Waste Type (2)

(3) NameAddress of T r a n s p o r t e r

NaaeDesor ip t ion of Who s e l e c t e d t h e B i t e (4)

04-11-80 1760 Waste ink and b K b l N t

solvent mixture

j I J L J V

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographlc printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

^ ^ Uf ()

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

FORM 1 Page 2

Solvents Recovery Service of New England Westvaco US Envelope Div (Springfield MA)

Transaction Gallon Waste Type (3) NameAddress NameDescription of Who Date (1) Volume (2) of Transporter selected the Bite (4)

102080 181500 3K3iNi web Lvauu

102080 181500 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in the mixture from this location

This is an obvious double count

SEE EXPLANATION ENCLOSED IN COVER LETTER

( ) ( ) (i

FORM 1 Page l

Solvents Recovery Service of New England Westvaco US Envelope Div (Enfield CT)

Transaction Gallon Waste Type (3) NameAddress MaaeDesorlptlon of Who Date (1) Volume (2) of Transporter Selected the Blf (4)

102080 181500 SRSNE wescvaco

(3) Theeh Waste Type would have likely been a mixture of waste ink and solvents used in flexographic t rinting operations Solvents in use at that time were ethyl alcohol and cellosolve WasteP lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

SEE EXPLANATION ENCLOSED IN COVER LETTER

Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg- XYZ Chemical Company - generator ABC Waste Trucking - transporter EFG I kte Disposal Service - broker i

( )

FORM 1 Page l

Solvents Recovery Service of New England US Envelope (Enfield CT)

Transaction Gallon Waste Type (3) NameAddress NameDesorlptlon of Who Date (1) volume (2) of Transporter selected the Bite (4)

041866 500000 SRSNE Westvaco

080466 176000 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

SEE EXPLANATION ENCLOSED IN COVER LETTER

Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company generator ABC Waste Trucking - transporter EFG Wa-te Disposal Service broker

1 ( )

FORM 1 Page l

Solvents Recovery service of New England US Envelope (Springfield MA)

Transaction Gallon Waate Type (3) NameAddress NameDescription of Who Date (1) Volume ill of Transporter selected the B l f (4)

SRSNE Westvaco 010974 126500

SRSNE Westvaco 070177 115500

SRSNE Westvaco 081277 192500

SRSNE Westvaco 091477 137500

103177 126500 SRSNE Westvaco

120977 220000 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in

Notesth^ mixture from this location (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company generator ABC Waste Trucking - transporter EFG TT e Disposal Service broker

lt )

FORM 1 Page l

Solvents Recovery service of New England US Envelope (Springfield MA)

Transaction Gallon Waate Type (3) NameAddress NameDescription of Who Date (1) Volume ill of Transporter selected the B l f (4)

SRSNE Westvaco 010974 126500

SRSNE Westvaco 070177 115500

SRSNE Westvaco 081277 192500

SRSNE Westvaco 091477 137500

103177 126500 SRSNE Westvaco

120977 220000 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

The Waste Type from Flexible Packaging in Springfield would have likely been waste ink and solvent mixture from flexographic and gravure printing and coating operations Solvents would have included ethyl alcohol isopropyl alcohol methanol n-propyl alcohol n-propyl acetate ethyl acetate and toluene Most likely no cleaners and little if any lubricating oil would have been included in

Notesth^ mixture from this location (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs documents This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company generator ABC Waste Trucking - transporter EFG TT e Disposal Service broker

lt )

FORM 1 Page 1

Solvents Recovery Service of New England Westvaco (Enfield)

Transaction Gallon Waste Type (3) NameAddress NameDesorlptlon of Who Date (1) Volume (2) of Transporter Selected the Bite (4)

032179 194100 SRSNE Westvaco

(3) The Waste Type would have likely been a mixture of waste ink and solvents used in flexographic printing operations Solvents in use at that time were ethyl alcohol and cellosolve Waste lubricating oil and waste printing press parts cleaner might also have been blended in small amounts with the waste ink

Notes (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 generators facility (particularly if the transaction was brokered by another party) and therefore may not match exactly with your records EPA expects you to make your best efforts to correlate your records with EPAs docviments This is to prevent double-counting of shipments in EPAs 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 manufacturers name

(4) eg XYZ Chemical Company - generator ABC Wastraquo Trucking - transporter F V( kEFGG ee Disposal Service - broker ( ) i )