0,617

LAW OFFICES OF

DEO^TPKICEacRHQADS™" ——— "'QUNSCfc CENTS* !

"WClTGk* 01540 237

TOOO 0. JQHNSTONJAM£SJ.MAAINOGEORGE C.OBWEN

FAX (COS) CO- J2i9' « AW*w« town, aox xo *

"

»»..•-, .April 4, 1391

Roseann M. Histretta, SsquiraRegional CounselEPA Region III341 Chestnut StreetPhiladelphia, PA 19107.

He: 3?ran si.ea.ilDear Ks. Kistratta:

_j_. _ . ... n-n

. TC2 at tb« Transicoil s a t w « a ispecific location of one Sm TraSSS J?*-1 ! and th*table to ascertain, would hS « ff5 J.?0!? o£ whica w« eKarc asked me to convey to yS ?a»? J?* SX/?S ««*»ctorc ase me to coney to ya» cor.investigation - that ' SieoSi21i% ?«istance of t&a follow upassistance to EPA? Conducted . » «» event that it may be Jf.

One inaiviaual ("ff.I.") has been continuously —y*-z»^at Transicoil since 1953 except for a short period of tizre in ths1970s-when the sanufacturing operation was temporarily shxrt down.Throughout that period, he was eaployad as a maintenance mechanicin charge of kaeping aquipsent operational and of dispensing rawTCS and disposing of spent TCS. Because ka«M^^ T"running1* for all of til--t-t- " ~ has a vary

vasts cont-ac-a-as.3 cont.ac,a.. ,ls a specific day on which thrae

EP/-05

"WiCM

*•

Bosaann &. Kistrstta, SsquireApril 4, 1391Page 2

full 55-gallon drums of spent TC2 could not be emptied into theholding tank because it was full. He was ordered by hissupervisor ts dump the contents onta a grassy area outside theplant. IT,Tr's'recollection is spacific bscause fee objected toth« dumping but was overruled by his boas. To this day, he

' recalls" the location, tha method, the quantity, the generalweather conditions and tlte fact that vegetation was almostimmediately impacted. Recant sampling indicates that TCS wasdetected in that araa.

N.I. recalls other standard practices during the1953-1976 time period that would suggest reasons for TC2contamination, but none as specific as the one cited. We wereunable to question jr.I. rs supervisor because ha diad a faw years

j later. Another individual, however, who worked very closely with| JT.I. throughout that period, confirmed that N.I. was disturbed by

having baan ordarad to dump TCS; confirmation i$ based on] conversations that took placa in 1969.

' That other- individual corroborates the standardpractices, such as the emptying of small containers ef spent TCSaround the property, referred to by N.I. A third employeerecalls a specific incidence in the mid 1960s of a spill of TCEonto the floor; it was washed into a floor drain that led to aportion of the exterior of the plant at which higher levels ofTCS are found. - - i

; These facts dictate that one or two companies and up toI five individual owner/operators should be subject to CERCLA| liability in addition to the present owner and the landlord, weI have additional details in our possession,, but they pertain sore.[ . to credibility than to substance. We are not attempting to'{ conceal information, but rather are hesitant because of our

concern about potential individual liabilities. If you areinterested in pursuing the above facts, kindly contact se so thatwe can discuss the least problematic method of disclosure.

Very truly yours,i 'i

A. Patrick tTuiciaronei i

bcc:unarc L. Gre*nbergw

• \

BR000505

TRANSICOIL, INC. SITE, POTENTIALLY RESPONSIBLE PARTY SEARCHTES Vm WORK ASSIGNMENT No. CO3152

INTERVIEW SUMMARY

Name: GEORGE DOANAlHIiation: Current Employee

Transicoil Inc.2560 General Armistead Ave.Trooper, PA 19403

Telephone: (215)539-4400

Date Interviewed: August 24, 1993Type of Interview: In person

On August 24, 1993, Mr. Doan was interviewed at his place of employment byMichael McCloskey of Tri-State Enterprise. Mr. Chambers was interviewed as partof the Potentially Responsible Party search currently being conducted under WorkAssignment No.CO3152 involving the Transicoil, Inc. Site (Site), WorcesterTownship, Montgomery County, Pennsylvania. Also present during this interviewwere the following individuals:

• Gary Morton Civil Investigator, U.S. Environmental ProtectionAgency

• Mark M. Johnson Vice President, Transicoil, Inc.• Paul D. Harper Director of Environmental Affairs, Eagle-Picher

Industries• Marc L. Greenberg Attorney, Eagle-Picher Industries

During the course of this interview, Mr. Doan. responded to questions based onguidelines provided by the U.S. Environmental Protection Agency for currentemployees.

Mr. Doan explained that he has worked at Transicoil, Inc. from mid-1959 to thepresent, except for the two years he was in the Army from 1960 to 1962. Mr. Doanstated that he has worked in the Motor Assembly Department in the manufacturingplant during his entire employment at the Site.

When asked about the types of waste and waste disposal practices at the Site, Mr.Doan stated that Trichloroethylene (TCE) was .used as a degreaser and cleaningsolvent at the Site until the tnid-1970's.' ^

ENFORCEMENT CONFIDENTIAL

AR000506

INTERVIEW SUMMARYGEORGE DOANAUGUST 24, 1993(continued)

Mr. Doan stated that TCE was stored in 55-gaIlon drums outside the ManufacturingKant sad was brought into the plant in 2-gallon buckets when needed for cleaning.According to Mr. Doan, these 2-gallon buckets had open tops, and TCE sometimessplashed on the ground and floor when an employee brought the TCE inside the plant.Mr. Doan stated that in the mid-1970's Transicoil, be. began using safety bucketswith locked tops and this type of spillage ceased to be a problem. Mr. Doan statedthat when the Assembly Department was finished using the TCE, the waste waspoured into a holding tank. Mr. Doan stated that he was unaware of how Transicoil,Inc. disposed of waste in the holding tank. Mr. Doan stated mat TCE m replacedTCE as the degreasing agent during the 1970's, however, he could not recall thespecific year this replacement occurred.

When asked the names of other substances used in the manufacturing process, Mr.Doan stated that he was not aware of any other substance. . ]

When asked if he was aware of any other occasions of TCE spillage, Mr. Doan statedthat in die mid to late 1960's a 5-gallon pan of TCE spilled onto the floor of themanufacturing plant and the contents were washed into the floor drain.

When asked the names of other Site employees who would have informationregarding the types of waste used and waste disposal practices engaged in at the Site,Mr. Doan provided the following:

• Arnold Vincent Retired and lives in Philadelphia.• Gary Shaw Retired and lives in Philadelphia.

A(?OG0507

COMMONWEALTH OF PENNSYLVANIA :: ss.

COUNTY OF MONTGOMERY :

GEORGE DOAN, of full age, being duly sworn according to

oath, deposes and says:

1. X am currently employed as Group Leader - Assembly

at the Transicoil manufacturing facility in Trooper,

Pennsylvania. Except for a two year period of time in 1960-1962

when I served in the Army and for a short period of time during

the early 1970's when the manufacturing operation was shut down,

I was employed at Transicoil's former location on Trooper Road in

Worcester, Pennsylvania ("Worcester Plant") from October of 1959

to August 31, 1990. During that period, X held a number ofpositions.

2. I recall that we used trichloroethylene as a

degreaser and for occasional cleanup at the Worcester Plant

throughout the 1960's.3. X specifically recall that on one occasion in the

mid- to late-1960's, a shallow pan of approximately, five gallons

of trichloroethylene which was being used to decrease dirty parts

spilled onto the floor; its contents spilled into and were washed

into the floor drain.

.=~i

GEORGE DOANSWorn to and Subscribedto before me this d*nday of AflA.L- . 1991.

s , ./ 0 <

4R0005Q,8_.

TRANSICOIL, INC - SUE, POTENTIALLY RESPONSIBLE PARTY SEARCHTES Vffl WORK ASSIGNMENT No. C031S2

INTERVIEW SUMMARY

Name: RICHARD DOWNINGAffiliation: Retired Employee

Transicoil, Inc.2560 General Armistead Ave.Trooper, PA 19403

Telephone: (215)539-4400

Home: 431 East Spruce StNomstown, PA 19401

Telephone: (215)279-0220

Date Interviewed: August 24, 1993Type of Interview: In person

On August 24, 1993, Mr. Downing was interviewed at his place of employment byMichael McCloskey of Tri-State Enterprise. Mr. Downing was interviewed as part ofthe Potentially Responsible Party search currently being conducted under WorkAssignment No. COS 152 involving Transicoil, Inc., Worcester Township,Montgomery County, Pennsylvania (Site). Also present during this interview weredie following individuals: |

• Gary Mortem: Civil Investigator, U.S. Environmental Protection.Agency.

• Mark M. Johnson: Vice President, Transicoil, Inc.

• Paul D. Harper Director of Environmental Affairs, Eagle - PicherIndustries.

• Marc L. Greenberg: Attorney, Eagle - Picher Industries.; *»* I

During the course cf this interview Mr, Downing responded to questions based ohguidelines provided by the U.S. Environmental Protection Agency for currentemployees. !

ENFORCEMENT CONFIDENTIAL

INTERVIEW SUMMARYRICHARD DOWNINGAUGUST 24, 1993(continued)

Mr. Downing explained that he has worked for Transicoil, Inc. since late 1952. Mr.Downing stated that he initially worked at the Transicoil, Inc. plant located at 104Grant St., in New York City as a General Maintenance man and moved to the Site inWorcester Township in late 1953. Mr. Downing indicated mat the president ofTransicoil, Inc. at this time was William Kenderson who is deceased. Mr. Downingstated that from 1953 to 1956 he worked as a laborer in the Maintenance Departmentand his duties consisted of general clean-up, painting buildings, and minor repairs tobuildings. He indicated that he was trained as an electrician in 1955 and became anelectrician in the Maintenance Department in 1956. His dudes men consisted ofrepairing of plant machinery.

When asked the names of liquid substances used at the Site and how these substanceswere used and disposed of, Mr. Downing stated mat solvents were used to cleanmachinery and that trichloroethylene (TCE) was used as the solvent at the Site untilthe mid-1970s when Transicoil, Inc. began purchasing chloroediane SM anddiscontinued the use of TCE. Mr. Downing stated that the solvents were used toclean the machinery in the Manufacturing Department. According to Mr. Downing,1-5 gallon buckets were filled with the solvent from a 55-gallon drum. The bucketswere carried into the Manufacturing Plant, machinery was cleaned by soaking parts inthe bucket, and the used solvents were poured into a 1000-gallon holding tank locatedon die southwest side of the Manufacturing Building. Mr. Downing indicated thatsome of die used solvent would, on occasion, be spilled when it was poured into dieholding tank. He further stated that in die 1960s, TCE was used to clean paintbrushes and the used TCE was poured on die ground.

When asked die name of die company diat supplied solvents to die Site, Mr. Downingstated diat he recalled seeing die name Textile Chemical Company on some of diedrums. . -

When asked die names of transporters diat removed waste from me holding tank, Mr.Downing indicated diat he recalled Ron Ziegler Company as one of die sewagehaulers. Mr. Downing further stated diat Ron Ziegler would pump out the sewageholding tank at die Site, and on at least one occasion in die early 1970s, he sprayeddie liquid on die ground on die west side of die plant property. Mr. Downing statedthat he could smell solvent when Mr. Ziegler sprayed die liquid.

ENFORCEMENT CONFIDENTIAL

INTERVIEW SUMMARYRICHARD DOWNINGAUGUST 24, 1993(continued)

When asked if he was aware of any other instances when solvent was spilled, Mr.Downing indicated diat he was told by Quintoo ViteDi that 3 of the 55-gallon drumsof used TCE were emptied on me ground on die west side of die Site in die late1960$. ;

1 , i

When asked die names of other transporters of waste at die Site, Mr. Downing statedthat several different companies were used over die years. However, he could not.recall their names.

'- jWhen asked die names of other employees who would have knowledge of die wasteand waste disposal practices at die Site, Mr. Downing provided die following:

• John Kusma: CarpenterI

• George Stormton: Maintenance Employee

« Sam Nungassen Supervisor

AROQ051 !

AFYTDAVTT'

COMMONWEALTH OF PEHNSTLVANXA :: 98.

COUKTY OF MONTGOMERY :

RICHARD DOWNING, of full age, being duly sworn according

to oath/ deposes and says:

1. X am. currently employed as a maintenance mechanicat the Transicoil manufacturing facility in Trooper,

Pennsylvania. I have been employed by the same company since

approximately 1953; until August 31, 1990, it was located cm

Trooper Road in Worcester, Pennsylvania ("Worcester Plant").

2. I specifically recall that we used solvents at the1

Worcester Plant as degreasers and for occasional cleanup. For

several years beginning in 1953, the solvent we used was shipped» • •

in large drums on which the word "Trichloroethylene" was clearlyprinted. After that, Transicoil switched to another solvent

which was snipped in large drums on which the word^ "Chloroathane

SM" was clearly printed.

3. X remember that for several years drums of waste

solvent which had been. shipped in drums marked"Trichloroethylene" were stored outside at the Worcester Plant.

4. In the late 1960s whan Wes Keats was ay supervisor,X was told that thrae 55-gallon drams full of usedtrichloroethylene solvent were spilled directly onto the ground

at the Worcester Plant. <i •

5. For several years beginning in the mid-1950s,

employees regularly cleaned paint brushes in a container of

solvent which was then emptied onto the ground behind the build-ings at the Worcester Plant.

8. A degreaser unit was installed outside the build-

ings at the Worcester Plant at one time and was used for a number

of years to reclaim solvent. Used solvent was poured into the

unit and heated; the part which evaporated was then cooled and

the condensation was collected. The reclaimed solvent was thenI

put into a drum which had been attached to the unit. I recall

that used trichloroethylene solvent was spilled on occasion as itwas being poured into and removed from the unit. ; The spills went

onto the ground. -7. For several years, a variety of solvents and

! 'thinners were spread onto papers that were placed & a pile on

the ground behind the buildings at the Worcester Plant in order

to facilitate burning of the papers.8. X also remember at least one occasion on which a

sewage haular sprayed onto tna ground liquid which had been

4f?0005i3

pumped from a sewage holding tank at the Worcester Plant

which smelled like solvent.

Sworn to and Subscribedto before ma this *2k*""day of IVfr^rfcik* . 1990,..

• v 0

RICHARD DOWNING

- 3 -

AROOO-SU

TRANSICOIL, INC - STTE, POTENTIALLY RESPONSIBLE PARTY SEARCHTES VDD[ WORK ASSIGNMENT No. C03152

INTERVIEW SUMMARY

Name: QUINTON C. V1TELLI |Affiliation: Current Employee

Transicoilf Lie.2560 General Armistead Ave.Trooper, PA 19403

Telephone: (215)539-4400, ! • •

Home: 208 Hamilton St.Norristown, PA 19401

i i

Date Interviewed: August 24, 1993Type of Interview: In person

On August 24, 1993, Mr. Vitelli was interviewed at his place of employment byMichael McCloskey of Tri-State Enterprise. Mr. Vitelli was interviewed as part ofthe Potentially Responsible Party search currently being conducted under WorkAssignment No. C03152 involving Transicoil, Inc., Worcester Township,Montgomery County, Pennsylvania (Site). Also present during mis interview werethe following individuals:

• Gary Motion: Civil Investigator, U.S. Environmental ProtectionAgency.

• Mark M. Johnson: Vice President, Transicoil, Inc.

• Paul D. Harper Director of Environmental Affairs,Eagle - Picher Industries.

• Marc L. Greenberg: Attorney, Eagle - Picher Industries.

During the course of this interview Mr. Vitelli responded to questions based onguidelines provided by the U.S. Environmental Protection Agency, for currentemployees.

Mr. Vitelli explained that he worked for Transicoil, Inc. since July 1953, and was atthe Site location until it closed in 1990. Mr. Vitelli stated that he had been amaintenance mechanic during his entire employment at the Sits. Mr. Vitelli explainedthat his duties included maintenance and repair of buildings and equipment at the Site.

ENFORCEMENT CONFIDENTIAL |

AR0005I5

INTERVIEW SUMMARYQUINTON C. VITELLIAUGUST 24, 1993(continued)

When asked about the types of waste mat were generated at the Site and the wastedisposal practices used, Mr. Vitelli staled thai solvents were used as degreasers andfor occasional cleanup. Mr. Vitelli stated that until the mid-1970s, trichloroethylene(TCE) was used as the solvent and was stored in 55-gallon steel drums. Mr. Vitelliexplained that machinery was cleaned with this solvent in pans and the waste fromthis cleaning was poured into a 1,000 gallon holding tank located on the west side ofthe Manufacturing Building. Mr. Vitelli stated mat 2-3 times per year the holdingtank would be emptied into a tanker truck operated and owned by Ron Ziegler fromGardnerville, Pennsylvania. Mr. Vitelli stated mat Ron Ziegler would also pump the

• liquid from the sewage holding tank. Mr. Vitelli stated that Ron Ziegler wouldoccasionally spray the contents from the sewage holding tank on the east side of theSite grounds and that on at least one occasion he smelled solvent Mr. Vitelli was notaware if this was done regularly by Mr. Ziegler or how many times the sewageholding tanks were emptied by Mr. Ziegler. Mr. Vitelli stated that in the late 1970s -early 1980s Ron Ziegler was no longer used and waste was removed by R.W. Eakinand the Chemelene Corporation.

v

Mr. Vitelli was asked if he was aware of any other instances when liquid waste wasdisposed of or spilled on the grounds at the Site. Mr. Vitelli stated that until the mid-1970s it was common practice to clean paint brushes by soaking them in buckets ofTCE and paint thinner. This was done on the grounds on the west side of theManufacturing Building. According to Mr. Vitelli, the contents of the buckets wouldbe poured out on the ground after the cleaning was completed. Mr. Vitelli could notrecall how many times this occurred. Mr. Vitelli further stated that in late 1969 hewas directed by his supervisor to pour 3 full 55-gallon drums of used TCE on thegrounds on the west side of the manufacturing plant and mat he complied. Mr.Vitelli stated that this supervisor's name was Wes Keats and mat Mr. Keats isdeceased. Mr. Vitelli was unaware if this was done more than once. Mr. Vitelli alsostated that paint thinner and TCE were used to bum paper trash on the ground on thewest side of the Manufacturing Building. Mr. Vitelli stated that this practice wasdiscontinued in the early 1970s.

When asked the names of other individuals who would have information regarding thetypes of waste and waste disposal practices at the Site, Mr. Vitelli identified thefollowing individuals:

• Anthony Tometta: Former Transicoil, Inc. employee who worked inthe Lamination Department and' is presently employed by the UpperMarion School District.

ENFORCEMENT CONFID

(continued)

worked in the

4ROGQ5I7

XtTPI DAVIT

COMMONWEALTH OF PENNSYLVANIA :: ss.

COUNTY OF MONTGOMERY :

QUEHTON VITELLI, of full age, being duly sworn accordingto oath, deposes and says:

1. I am currently employed as a maintenance mechanicat the Transicoil manufacturing facility in Trooper,Pennsylvania. Except for a short period of time during the early

1970s when the manufacturing operation was shut down, I 'was

employed at Transicoil's former location on Trooper Road in

Worcester, Pennsylvania ("Worcester Plant") from approximate!;July 1, 19S3 to. August 31, 1990. Ky general duties an'

responsibilities for Transicoil have remained essentially the

• same since the original date of my employment.

2. I specifically recall that we used solvents at theWorcester Plant as degreasers and for occasional cleanup. From1953 into the 1970s, the solvent we used, was shipped in large

drums on which the word "Trichloroethylene• was clearly printed.

In the late 1970s,-Transicoil switched to another solvent which

was shipped in large drums on which the word "Chloroethane SM"was clearly printed.

a

3. For the first two or three years of my employment,1 i

I recall that the drums which were marked "Trichloroethylena"

were stored outside at the Worcester location and exposed to

natural elements. During the late 1960s and early- 1970s, drumsI i

of waste solvents and coolants were stored outside and exposed tothe elements.

, i

4. In approximately 1969, three 55-galion drums fulli i "

• ' !of used solvent (the same product which was shipped in drums

; i

marked "Trichloroethylene") were spilled directly onto the ground• i i •

at the Worcester Plant.5. For several years beginning in the mid-1950s,

employees regularly cleaned paint brushes in a container of

solvent which was then emptied onto the ground behind the build-

ings at the Worcester Plant.6. A degreaser unit was installed outside the build-

.ings at .the Worcester Plant at one time and was used for a number

of years to reclaim solvent. Used solvent was poured into theunit and heated; the part, which evaporated was then cooled andthe condensation was collected. The reclaimed solvent was then

i

put into a drum which had been attached to the unit. I do not

recall observing any .spills of solvent near this unit, but no. > i

containment measures were in place to capture any.

7. For several years ending some time in the 1970s, a

variety of solvents and thinners were spread onto papers thatwere placed in a pile on the ground behind the buildings at the

Worcester Plant in order to facilitate burning of the papers.

- 2 -

L

8. I also remember at least one occasion on which

sewage hauler sprayed onto the ground liquid which had

pumped from a sewage holding tank at .the Worcester Plaint andwhich smelled like solvent.

QUINTON VITELLI

Sworn to and Subscribed •to before me this 2*7**day of LW.vdN? . . 1990.

i

e

-• 3 -